# Regulatory Oversight Report for Nuclear Power Generating Sites: 2017

## Executive summary

This report describes the regulatory oversight and safety performance of nuclear power plants (NPPs) and adjacent waste management facilities (WMFs) in Canada in 2017. For certain topics, updates on developments in 2018 are also described. This is the first CNSC regulatory oversight report to cover both NPPs and WMFs. The WMFs and the NPP at Gentilly-2 were not covered by a regulatory oversight report for 2016.

The following lists the facilities located at the same site that are governed by a single CNSC licence and assessed together in this report.

• Darlington Nuclear Generating Station (DNGS) and Tritium Removal Facility
• Darlington Waste Management Facility (DWMF) which includes the Retube Waste Storage Building
• Pickering Nuclear Generating Station (PNGS)
• Pickering Waste Management Facility (PWMF)
• Point Lepreau Nuclear Generating Station (PLGNS) and Solid Radioactive Waste Management Facility
• Western Waste Management Facility (WWMF) and Radioactive Waste Operations Site-1
• Gentilly-2 Facilities
• Bruce A Nuclear Generating Station, Bruce B Nuclear Generating Station, and the Central Laundry and Maintenance Facility are located at the same site and are also governed by a single CNSC licence. However, because of some differences in how programs are implemented at these facilities, Bruce A and Bruce B are assessed separately in this report.

The CNSC’s substantial regulatory effort for NPPs and WMFs in 2017 included activities related to licence renewals for NPPs and WMFs, and compliance verification activities such as inspections, desktop reviews, and surveillance and monitoring. The licensing decisions and compliance activities identified follow-up activities, findings and corrective actions that CNSC staff monitored during 2017. CNSC staff continue to follow up on developments and corrective actions that were not concluded by the end of 2017.

The licensing and compliance activities were conducted in the context of robust regulatory requirements. The requirements include those found in CNSC regulatory documents and CSA Group standards, which continued to evolve in 2017, as both organizations published new and revised documents. NPP and WMF licensees were in the process of implementing various new requirements in 2017, and CNSC staff were satisfied with the progress made overall.

CNSC staff concluded that the NPPs and WMFs operated safely in 2017. This conclusion was based on detailed staff assessments of findings from compliance verification activities for each facility based on the 14 CNSC safety and control areas (SCAs). The conclusion was supported by safety performance measures and other observations.

Important performance measures and observations included the following:

• The NPP and WMF licensees followed approved procedures and took appropriate corrective action for all events reported to the CNSC. No events above Level 0 on the International Nuclear and Radiological Event Scale were reported to the International Atomic Energy Agency (IAEA).
• NPPs and WMFs operated within the bounds of their operating policies and principles.
• There were no serious process failures at the NPPs. The number of unplanned transients and trips in the reactors was low and acceptable to CNSC staff. All unplanned transients in the reactors were properly controlled and adequately managed.
• Radiation doses to the public were well below the regulatory limits.
• Radiation doses to workers at the NPPs and WMFs were below the regulatory limits. The annual average effective radiation dose to workers at NPPs and WMFs remained low in 2017.
• The frequency and severity of non-radiological injuries to workers were very low.
• No radiological releases into the environment from the NPPs and WMFs exceeded the regulatory limits.
• Licensees met the applicable requirements of Canada’s international obligations; the safeguard inspection results were acceptable to the IAEA.

CNSC staff assessments of the SCAs for the NPPs and WMFs are summarized in the ratings in the following tables. The rating categories used by CNSC staff in these assessments are:

FS
fully satisfactory
SA
satisfactory
BE
below expectations
UA
unacceptable
Canadian NPP safety performance ratings for 2017
Safety and control area Bruce A Bruce B DNGS PNGS Point Lepreau Gentilly-2
Management system SA SA SA SA SA SA
Human performance management SA SA SA SA SA SA
Operating performance FS FS FS FS SA SA
Safety analysis FS FS FS FS FS SA
Physical design SA SA SA SA SA SA
Fitness for service SA SA SA SA SA SA
Radiation protection FS FS SA SA SA SA
Conventional health and safety FS SA FS FS FS SA
Environmental protection SA SA SA SA SA SA
Emergency management and fire protection SA SA SA SA SA SA
Waste management FS FS FS FS SA SA
Security SA SA SA SA SA SA
Safeguards and non-proliferation SA SA SA SA SA SA
Packaging and transport SA SA SA SA SA SA
Overall rating FS SA FS FS SA SA
Canadian WMF safety performance ratings for 2017
Safety and control area DWMF PWMF WWMF
Management system SA SA SA
Human performance management SA SA SA
Operating performance FS FS FS
Safety analysis FS FS FS
Physical design SA SA SA
Fitness for service SA SA SA
Conventional health and safety FS FS FS
Environmental protection SA SA SA
Emergency management and fire protection SA SA SA
Waste management SA SA SA
Security SA SA SA
Safeguards and non-proliferation SA SA SA
Packaging and transport SA SA SA
Overall rating SA SA SA

## 1 Introduction

The Regulatory Oversight Report for Canadian Nuclear Power Generating Sites: 2017 provides the Canadian Nuclear Safety Commission (CNSC) staff’s assessment of the overall safety performance of Canadian nuclear power plants (NPPs) and the adjacent waste management facilities (WMFs) for 2017.

Section 1 of the report provides introductory material that explains this report, the licensed facilities that are covered and the CNSC’s regulatory framework and practices.

Section 2 of the report provides background information that serves as context for the assessments. Although the assessments for each site are provided in section 3, some assessments of groups of licensees, where appropriate, appear in section 2. For example, section 2 compares safety performance data for multiple licensees. It also contains general assessments of all licensees as a whole in the area of security, since the information presented in section 3 for individual sites is limited.

Section 3 contains the individual assessments for each facility or site. In sections 3.1 and 3.2, the NPP and WMF on the same site are regulated under separate CNSC licences, and those subsections contain separate assessments of the NPP and WMF. This report uses headers to identify the information and assessments related to the two facilities. In sections 3.3 and 3.6, because the NPP and WMF on the same site are licensed together, they are assessed together. The safety assessments of the NPPs and WMFs are described in more detail in section 1.4.6.

Sections 2 and 3 are organized according to the CNSC’s safety and control area (SCA) framework. The SCA framework includes 14 SCAs grouped into three functional areas, and one additional area, as shown in table 1.

Table 1: List of CNSC safety and control areas
Functional Area SCA #
Management Management system 1
Human performance management 2
Operating performance 3
Facilities and equipment Safety analysis 4
Physical design 5
Fitness for service 6
Core control processes Radiation protection 7
Conventional health and safety 8
Environmental protection 9
Emergency management and fire protection 10
Waste management 11
Security 12
Safeguards and non-proliferation 13
Packaging and transport 14
Other matters of regulatory interest 15

The safety assessments in this regulatory oversight report are done according to the licensing basis for each facility. The licensing basis is unique for each licensed facility. As such, statements related to compliance are in terms of the applicable regulatory requirements for the specific facility. The licensing basis is described in section 1.4.1.

The conclusions of this report are provided in section 4.

This report includes a list of references, a glossary and a list of the CNSC inspection reports that form the basis of many of the observations and conclusions in this report. In addition to the terms that are explained in the glossary, the reader should note the use of the terms “Indigenous peoples”, “public” and “general public”. Indigenous peoples include First Nation, Métis and Inuit communities. “General public” is meant to include all people and comprises two groups, Indigenous peoples and the public, each having distinct rights and interests.

### 1.2 Scope

The scope of the Regulatory Oversight Report for Canadian Nuclear Power Generating Sites: 2017 is significantly different than that of the Regulatory Oversight Report for Canadian Nuclear Power Plants: 2016 References 1 which only covered NPPs that were operating in Canada in 2016. Information about the Gentilly-2 facilities was not included as the facilities were permanently shut-down in 2012. Safety assessments of Gentilly-2 are included in this regulatory oversight report, since its status and regulatory oversight is similar to that of the WMFs covered in the report. General statements in the report that refer to “NPPs” apply to Gentilly-2, whereas the phrase “operating NPPs” is used in statements that do not apply to Gentilly-2.

Safety assessments of WMFs that are licensed separately from the NPPs but located at the same sites are also included in this regulatory oversight report. Although these WMFs have been covered in separate regulatory oversight reports in the past, there was no regulatory oversight report for them in 2016. However, the 2016 safety assessments of the PWMF and the WWMF were presented to the Commission at public hearings in April 2017.

Generally speaking, the information provided in this report is pertinent to 2017, and the status that is described is valid as of December 2017. Since Gentilly-2 and the WMFs were not covered by a regulatory oversight report for 2016, the descriptions of these facilities may contain more background information than those of the operating NPPs.

The term “UPDATE:” is used in the report to identify topics where more recent information (up to June 1, 2018) is included (e.g., descriptions of significant events or updates that were specifically requested by the Commission).

The detailed scope of the safety assessments in this report is covered by the set of specific areas that constitute each SCA. They are listed in section 2 at the beginning of each SCA section. Some specific areas do not apply to Gentilly-2 and the WMFs; where this is the case, those areas were not considered in the safety assessments for these facilities.

### 1.3 Nuclear facilities covered by this regulatory oversight report

NPPs and WMFs are considered Class I facilities and are subject to the Class I Nuclear Facilities Regulations. Figure 1 shows the geographic location of the NPPs and WMFs covered in this report. All sites are located on traditional territories of Indigenous peoples in Canada.

#### 1.3.1 Nuclear power generating sites in Canada

The Darlington site is located in Clarington, Ontario, and consists of the Darlington Nuclear Generating Station (DNGS) and the Darlington Waste Management Facility (DWMF). The DNGS and DWMF are licenced separately. See section 3.1 for details.

The Pickering site is located in Pickering, Ontario, and consists of the Pickering Nuclear Generating Station (PNGS) and the Pickering Waste Management Facility (PWMF). The PNGS and PWMF are licenced separately. See section 3.2 for details.

The Point Lepreau site is located at Point Lepreau, New Brunswick, and consists of the Point Lepreau Nuclear Generating Station (PLNGS) and the Solid Radioactive Waste Management Facility (SRWMF). The Point Lepreau NGS and SRWMF are licenced together. See section 3.3 for details.

The Bruce site is located in Tiverton, Ontario, and consists of the Bruce A and B NPPs, the Central Laundry and Maintenance Facility (CLMF), the Ontario Power Generation (OPG) Western Waste Management Facility (WWMF) and Radioactive Waste Operations Site-1 (RWOS-1), and the Canadian Nuclear Laboratory (CNL) Douglas Point Waste Facility (WF). The Bruce A and B NPPs and the CLMF are licenced together and operated by Bruce Power. The WWMF, RWOS-1 and Douglas Point WF are all licenced separately. See sections 3.4 and 3.5 for details. Note that the Douglas Point WF is not covered in this report; rather, it is covered in the Progress Update for CNL’s Prototype Waste Facilities, Whiteshell Laboratories and the Port Hope Area Initiative.

The Gentilly nuclear site is located in Bécancour, Quebec, and consists of CNL’s Gentilly-1 WF and Hydro-Québec’s Gentilly-2 facilities. The Gentilly-1 WF and Gentilly-2 facilities are licenced separately. See section 3.6 for details. Please note that the Gentilly-1 WF is not covered in this report; rather, it is covered in the Progress Update for CNL’s Prototype Waste Facilities, Whiteshell Laboratories and the Port Hope Area Initiative.

#### 1.3.2 NPPs

NPPs are considered Class IA nuclear facilities, as defined in the Class I Nuclear Facilities Regulations.

##### Operating NPPs

Nineteen reactors continued to be operated in Canada throughout 2017, a figure unchanged from 2016. They are located in four NPPs, each with a power reactor operating licence (PROL) issued by the CNSC. They are located in two provinces (Ontario and New Brunswick) and are operated by three separate licensees (OPG, Bruce Power and NB Power). These NPPs range in size from one to eight power reactors, all of which are CANDU (CANada Deuterium Uranium) reactors.

Table 2 provides data for each operating NPP, including the generating capacity of the reactor units, the initial start-up date, the name of the licensee and the PROL expiry date. Additional information about the NPPs and licences is provided in section 3.

Table 2: Basic information for operating NPPs
NPP Licensee Location State of reactor units Gross capacity per unit (MWe) Start-up1 Licence expiry
DNGS Ontario Power Generation Inc. Clarington, ON Four operating (including one undergoing refurbishment) 935 1990 November 30, 2025
PNGS Ontario Power Generation Inc. Pickering, ON Six operating, two defueled and in safe storage

Units 1, 4: 542

Units 5–8: 540

Units 1, 4: 1971

Units 5–8: 1982

August 31, 2018
PLNGS New Brunswick Power Corp. Point Lepreau, NB One operating 705 1982 June 30, 2022
Bruce A2 Bruce Power Inc. Tiverton, ON Four operating 831 1977 May 31, 2020
Bruce B2 Bruce Power Inc. Tiverton, ON Four operating 872 1984 May 31, 2020

1 For the multi-unit NPPs, this indicates the start-up of the first reactor unit.

2 Bruce A and Bruce B are licensed as one multi-unit NPP consisting of eight operating reactor units.

##### Non-operating reactors and NPP

PNGS includes Units 2 and 3 which remain defueled and in safe storage. They are governed by the same PROL as the six operating units at Pickering.

The NPP at Gentilly-2 is shut down and is proceeding to decommissioning. It is also a CANDU design, and it is governed by a power reactor decommissioning licence.

##### New build

In 2012, the Commission issued a nuclear power reactor site licence (PRSL) to OPG for the new nuclear project at the Darlington site for a period of 10 years. The PRSL requires OPG to continue follow-up work on the environmental assessments (EAs) conducted in conjunction with the licence application. OPG carried out work in 2017 in the following areas:

• bank swallow monitoring and mitigation activities
• support for CNSC activities to engage stakeholders in developing policy for land use around nuclear generating stations
• development of a methodology that will help with siting of intake and diffuser structures in Lake Ontario

See appendix B for a description of the progress made in these activities and a description of the work anticipated for 2018.

#### 1.3.3 WMFs

The WMFs that are assessed separately in this regulatory oversight report are licensed independently from the adjacent NPP. They include the Darlington, Pickering and Western WMFs (DWMF, PWMF and WWMF respectively). RWOS-1 is included in the assessment for WWMF. These facilities are defined as Class IB nuclear facilities in the Class I Nuclear Facilities Regulations. They are owned and operated by OPG.

Table 3 provides data for each WMF, including the initial start-up date, the name of the licensee, the licence expiry date and the type of waste managed at each facility – low-level waste (LLW), intermediate-level waste (ILW) or high-level waste (HLW). Additional information on the facilities and licences is provided in section 3.

As discussed in section 1.3.1, both the Point Lepreau and Gentilly-2 sites have WMFs that are further discussed in sections 3.3 and 3.6, respectively.

Table 3: Basic information for WMFs
Facility Licensee Location Operation start Licence expiry Waste management
DWMF OPG Clarington, ON 2008 April 30, 2023

HLW from DNGS

ILW from DNGS refurbishment

PWMF OPG Pickering, ON 1996 August 31, 2028

HLW from PNGS

ILW from PNGS Units 1–4 refurbishment

WWMF OPG Tiverton, ON 1974 May 31, 2027

HLW from Bruce A and B NPPs

ILW from Bruce Units 1 and 2 refurbishment

L&ILW from DNGS, PNGS, and Bruce A and B NPP operations

RWOS-1 OPG Tiverton, ON Mid-1960 Indefinite LLW and ILW from Douglas Point WMF and PNGS

### 1.4 Regulatory framework and oversight

The CNSC is the federal government body that regulates the use of nuclear energy and materials to protect health, safety, security and the environment. It implements Canada’s international commitments on the peaceful use of nuclear energy and disseminates objective scientific, technical and regulatory information to the public relating to the points above. Licensees are responsible for operating their facilities safely and are required to implement programs that make adequate provisions for meeting legislative and regulatory requirements.

The CNSC regulates the nuclear sector in Canada, including NPPs and WMFs, through licensing, reporting, compliance verification and enforcement activities. For each NPP and WMF, CNSC staff perform inspections, surveillance and monitoring, and desktop reviews. The CNSC employs a rating methodology to assess collectively the results of these individual activities. The CNSC also conducts regulatory research and development (R&D) to support regulatory efforts (see appendix D). The CNSC uses a risk-informed regulatory approach that applies resources and regulatory oversight in a manner commensurate with the risk associated with the regulated facility and activity.

The CNSC’s regulatory programs for NPPs and WMFs involve the direct efforts of approximately 400 CNSC staff, including support from other members of the organization. This accounts for approximately 44% of the CNSC workforce. CNSC inspectors and other subject matter experts travel to NPPs and WMFs to conduct inspections and other regulatory activities (described further in section 1.4.4). At operating NPPs, the regulatory program also includes approximately 37 CNSC inspectors permanently located at those sites. The inspectors lead and participate in inspections, monitor safety performance and provide regulatory oversight from site offices.

The CNSC consults with Indigenous peoples to ensure the licensing decisions uphold the honour of the Crown and considers potential and established Aboriginal and treaty rights.

#### 1.4.1 CNSC requirements

The licensing basis is defined in the CNSC information document titled Licensing Basis Objective and DefinitionReference 3. It comprises the following:

1. the regulatory requirements set out in the applicable laws and regulations
2. the conditions and safety and control measures described in the facility's or activity's licence and the documents directly referenced in that licence
3. the safety and control measures described in the licence application and the documents needed to support that licence application

The licences for NPPs and WMFs contain a requirement for the licensees to operate in accordance with their licensing basis. The requirements in parts (ii) and (iii) of the licensing basis are unique to each licensed facility. They depend on the content of each licence, the licence applications and the applicant’s supporting documentation. CNSC regulations, including the Class I Nuclear Facilities Regulations, provide the requirements for the content of licence applications for NPPs and WMFs. In 2017, the CNSC published REGDOC-1.1.3, Licence Application Guide: Licence to Operate a Nuclear Power Plant to elaborate on the application requirements for operating NPPs. CNSC staff provide additional, tailored guidance to licensees that intend to renew their licences for NPPs and WMFs.

Licence applications for NPPs and WMFs cite CNSC regulatory documents, CSA Group standards, and other publications such as the applicant’s own documentation. When a licence is issued, CNSC staff develop a licence conditions handbook (LCH) (described further in section 1.4.2) to identify the specific requirements that apply to that licence. Appendix E lists all CNSC regulatory documents and CSA Group standards that have been identified as containing compliance verification criteria in the LCHs for the NPPs and WMFs covered by this regulatory oversight report.

Appendix E illustrates the vast number of CNSC regulatory documents and CSA Group standards that provides requirements relevant to the SCAs. It indicates the similarities and differences in the CNSC regulatory documents and CSA Group standards that apply to NPPs and WMFs.  It indicates the differences in publications that apply to operating NPPs versus non-operating reactors such as Gentilly-2. It also indicates the significant number of newer CNSC regulatory documents and CSA Group standards that are being implemented by the licensees. Details about the implementation of these publications are provided under the relevant SCAs throughout this report.

Each licensee implements new CNSC regulatory documents and CSA Group standards in a staged, risk-informed manner that takes into consideration the timing of licence renewals, operational needs, and other concurrent changes. Although differences exist in applicable requirements between similar facilities at any given time, the requirements are nevertheless robust and comprehensive, and improved requirements are implemented in a measured and systematic way.

#### 1.4.2 Licensing

The CNSC licensing process for NPPs and WMFs is comprehensive and covers all 14 SCAs.

The CNSC assesses licence applications to ensure that the proposed safety and control measures are technically and scientifically sound, all application requirements are met and the appropriate safety systems are in place to protect people and the environment. The CNSC assesses the adequacy of the proposed measures against the requirements in the regulations and criteria that have been provided to the applicant which are expected to become part of the licensing basis, if the licence is granted.

The licensing process has participation opportunities for the public and Indigenous peoples in Commission meetings and hearings. Commission hearings are often held in the community close to the site in question. All Commission proceedings are open to the general public and webcast live.

Each of the operating NPPs and WMFs described in this report has been granted a licence by the Commission. Typically, a waste facility operating licence is issued for a period of 10 years, and a power reactor operating licence is issued for 5 years. The CNSC is transitioning to longer licence periods for power reactor operating licences. For operating NPPs, this longer licence is issued in conjunction with the implementation of a comprehensive periodic safety review (PSR) process in preparation for the licence renewal.

The PSR is a comprehensive evaluation of the design, condition and operation of an NPP. CNSC REGDOC-2.3.3, Periodic Safety Reviews sets out the regulatory requirements for PSR implementation. As outlined in REGDOC-2.3.3, a PSR involves an assessment of the current state of the plant and plant performance to determine the extent to which the plant conforms to modern codes, standards and practices, and to identify any factors that would limit safe long-term operation. It gives the licensee a framework in which it can systematically identify practicable safety enhancements which are documented in an integrated implementation plan (IIP). The status of the PSR for each operating NPP is described in section 3.

A PSR is not a requirement for Gentilly-2 or the WMFs, because the associated hazards and requirements change relatively slowly, such that the regular licensing process and implementation of CNSC regulatory documents and CSA Group standards are sufficient to ensure safe long-term operation.

The NPP and WMF licences are relatively similar and contain standardized licence conditions that are organized by SCA. For example, under the radiation protection SCA,  licences contain a condition that requires the licensee to implement and maintain a radiation protection program. The detailed compliance verification criteria for the radiation protection program are found in the LCH for the facility written by CNSC staff. LCHs are consistent with the licensing basis for the facility and establish the basis for the CNSC’s compliance verification program during the licence period.

When licensees implement new CNSC regulatory documents and CSA Group standards, the implementation plans are typically recorded in the LCH (i.e., the LCH will indicate the date on which CNSC staff will begin assessing compliance with the new or revised requirements).

In 2017, CNSC staff continued to standardize LCHs for NPPs and WMFs. This involved gradually adopting and adapting templates, generic text and common guidance for writing and revising LCHs that apply to all CNSC licences with LCHs. Revisions to the LCHs relevant to this report are summarized in appendix F.

Fisheries Act authorizations

In addition to CNSC licences, this regulatory oversight report also describes developments related to Fisheries Act authorizations, such as the preparation of applications and resulting decisions by Fisheries and Oceans Canada. The Fisheries Act requires the establishment of offsets to compensate for any residual harm caused to fish and fish habitats after mitigation measures have been put in place. The CNSC has a memorandum of understanding with Fisheries and Oceans Canada, whereby CNSC staff are responsible for monitoring activities and verifying compliance for Fisheries Act authorizations. The Minister of Fisheries and Oceans Canada is responsible for enforcing the authorizations in the event of non-compliance.

#### 1.4.3 Reporting

Licensees are required to provide various reports and notices to the CNSC under CNSC regulations. LCHs clarify the CNSC’s expectations for these requirements.

In addition to the reporting requirements in the regulations, a condition in the licences of NPP licensees requires that they report to the CNSC in accordance with REGDOC‑3.1.1, Reporting Requirements for Nuclear Power Plants. REGDOC-3.1.1 requires licensees to submit quarterly and annual reports on various subjects (e.g., quarterly reports on the safety performance indicators) and it provides detailed requirements concerning the submission of other important reports (e.g., updates to the final safety analysis report, proposed decommissioning plan, annual environmental protection report). REGDOC-3.1.1 also requires licensees to report to the CNSC on any unplanned situations and events. These reports are posted by the licensees on their respective websites. The requirements in REGDOC-3.1.1 have been adjusted for Gentilly-2 based on its current state and the associated risks.

During 2017, NPP licensees reported to CNSC staff on 256 events and submitted 90 scheduled reports. Three of these events were presented to the Commission as event initial reports (EIRs); they are described in the relevant parts of section 3. WMF licensees submitted 13 reports to CNSC staff for reportable events under the General Nuclear Safety and Control Regulations that occurred at DWMF, PWMF and WWMF. No EIRs related to WMFs were presented to the Commission in 2017. The NPP EIRs and WMF reportable events are discussed in section 3. None of the events were above level 0 on the International Nuclear and Radiological Event Scale.

Note that the CNSC published REGDOC-3.1.2, Reporting Requirements for Non-Power Reactor Class I Facilities and Uranium Mines and Mills in January 2018. Beginning in 2019, WMF licensees will report to the CNSC in accordance with REGDOC-3.1.2.

#### 1.4.4 Compliance program

The safety assessments presented in this report are based on the results of activities planned through the CNSC compliance verification program (CVP). In 2017, these activities included inspections supported by subject matter experts, desktop reviews by a wide range of technical specialists, and surveillance and monitoring conducted by CNSC inspectors. These activities were performed through a combination of document reviews, workplace observations and worker interviews. All compliance verification activities were fully documented.

Tables 4, 5 and 6 demonstrate the CVP effort by CNSC staff for each NPP and WMF. CNSC staff made approximately 16,000 person-days of effort conducting inspections, event reviews and other compliance activities in 2017, which is comparable to the effort made in 2016.

Table 4: Compliance activities for NPPs for 2017 in person days
Compliance activities effort DNGS PNGS PLNGS Bruce A and B Gentilly-2 Industry total
Inspections 1,422 1,764 981 1,716 98 5,981
Event reviews 120 130 70 184 8 512
Other activities* 2,160 2,602 1,466 2,970 139 9,339
Total effort 3,702 4,497 2517 4,871 245 15,832
DWMF PWMF WWMF Industry total 3 3 3 9
Table 6: Compliance activities for WMFs for 2017 in person days
Compliance activities effort DWMF PWMF WWMF Industry total
Event reviews 75 209 258 542
Other activities* 161 94 227 482
Total effort 236 303 485 1,024

*Includes verification activities, such as surveillance and monitoring, and desktop reviews of licensee-submitted documents and reports (other than event reports)

The five-year trend in compliance activities is given in appendix G.

The goal is to ensure that the CVP for NPPs and WMFs is always timely, risk-informed, performance-based and responsive to developments. At its foundation, the CVP consists of a collection of compliance verification activities that cover the 14 SCAs conducted with varying frequency over a rolling five-year period. This baseline is the minimum set of activities needed to systematically and comprehensively determine whether licensees are complying with the safety and control measures in their licensing bases. Individual inspections typically verify compliance with requirements across multiple specific areas and SCAs.

For each NPP, between 80 and 100 applicable compliance verification activities are selected from the baseline for the year’s compliance plan. Additional reactive compliance verification activities for NPPs and WMFs are added as needed. These focus on site-specific matters and known or potential licensee challenges. The annual plans are then validated by CNSC subject matter experts and licensing staff using a risk-informed approach that considers the status, performance history, conditions and challenges of each facility to ensure appropriate regulatory oversight and safety performance evaluations. Additional compliance verification activities for NPPs and WMFs may be added as necessary during the year, as new licensee challenges emerge.

The CVP for NPPs includes reviews of safety performance indicators submitted quarterly to the CNSC. Data for some of the safety performance indicators submitted are reproduced in this report. There are no regulatory limits or thresholds associated with this data. However, CNSC staff monitor them, watching for trends over time and deviations from the data typically provided by other licensees with similar operations or facilities. Trends develop relatively slowly over time. The differences between licensees are relatively small since NPP licensees tend to have mature programs for the SCAs that are based on similar or identical requirements.

Any unfavourable trend or comparison is followed by increased regulatory scrutiny. Depending on the safety significance of the trend or deviation, increased regulatory scrutiny can range from increased surveillance and monitoring, to increased focus during field inspections, to adjusted timing and/or scope of a baseline inspection, focused desktop review or reactive inspection.

During 2015–16, the Commissioner of the Environment and Sustainable Development completed a performance audit of the CNSC’s oversight of the nuclear sector, reviewing the period of April 2013 to March 2015. Details were provided in the Regulatory Oversight Report for Canadian Nuclear Power Plants: 2016 References 1. The CNSC had implemented four of the audit’s five recommendations by September 30, 2016. Work to address the final recommendation – to improve the documentation on the site inspection planning process – was completed by March 31, 2017.

#### 1.4.5 Enforcement

The CNSC uses a graduated enforcement approach to encourage and compel compliance and deter future non-compliance.

When a point of non-compliance is identified, CNSC staff determine the appropriate enforcement action based on the safety significance and other factors, such as whether the non-compliance is systemic or repeated. Each enforcement action is a discrete and independent response to a point of non-compliance.

Regulatory judgment is applied and multiple factors are taken into account to determine the most appropriate enforcement strategy for any given situation. If the initial enforcement action does not result in timely compliance, other enforcement actions are used.

Regulatory responses to non-compliance and enforcement measures include:

• issuing written notices
• increasing regulatory scrutiny
• making requests under subsection 12(2) the General Nuclear Safety and Control Regulations
• issuing orders
• taking licensing actions
• decertifying persons or equipment
• prosecuting

Enforcement actions may be applied independently or in combination with other actions.

#### 1.4.6 Safety assessment ratings

This report presents safety performance ratings for each SCA at each NPP and WMF. The ratings are based on findings generated during CVP activities. The findings are categorized by appropriate SCA and specific area and assessed against a set of CNSC-developed performance objectives and criteria for the SCAs (see appendix A).

Since the CVP consists of a (typically five-year) rolling cycle of regulatory activities, not all specific areas are directly evaluated through inspections or desktop reviews each year. In rating specific areas, CNSC staff rely on inspections conducted in previous years supplemented by conclusions from other regulatory oversight conducted during 2017. This can include reviews of actions stemming from previous inspections and other developments, monitoring and surveillance at a site, and other interactions with the licensees.

The assessment presented in this report includes an overall rating for each NPP and WMF. It is a judgment of the overall safety performance at each facility. See appendix C for a comprehensive description of the CNSC rating methodology for NPPs and WMFs.

In generating the performance ratings for 2017, CNSC staff considered 1,547 findings for NPPs and WMFs. The vast majority of the findings (99.9%) were assessed as being either compliant, negligible or of low safety significance. In other words, they had a positive, insignificant or small negative impact on safety within the specific area. The remainder (fewer than 0.1%) had a significant negative effect in the context of assessing a specific area. These findings of medium safety significance are discussed in detail in section 3 of this report.

At the Bruce site, Bruce A and B are rated separately from WWMF because they are operated by different licensees. For the Darlington and Pickering sites, the NPP and WMF are rated separately because they are regulated by separate licences and have facility-specific regulatory requirements. However, they are discussed together in the same site subsection, as they have commonalities (the same licensee). The WMFs at Point Lepreau and Gentilly-2 are assessed together with their respective NPPs, as they are governed by the NPP licences and are subject to the same regulatory requirements (as was done in previous regulatory oversight reports).

The 2017 SCA ratings for the NPPs and WMFs are provided in section 2 by SCA and in section 3 by facility. In addition, section 3 provides the overall ratings for each NPP and WMF. For trending purposes, section 3 also cites the SCA ratings and overall ratings for the facilities in 2016. Gentilly-2 is an exception, as it was last rated in 2015. The 2016 ratings are explained and tabulated for all facilities in appendix C.

## 2 General and supporting information

This section provides general information organized by SCA that serves as background information for the assessments in section 3. It includes notes about the requirements for the assessments. Detailed information about the requirements is provided in appendix E.

### 2.1 Management system

This SCA covers the framework that establishes the processes and programs required to ensure that an organization achieves its safety objectives, continuously monitors its performance against those objectives and fosters a healthy safety culture.

Management system ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
SA SA SA SA SA SA SA SA SA

The management system encompasses the following specific areas:

• management system
• organization
• change management
• safety culture
• configuration management
• records management
• management of contractors
• performance assessment, improvement and management review
• problem identification and operating experience

#### Management system

The following publications contain regulatory requirements that were relevant in 2017:

• CSA Group standard N286-05, Management system requirements for nuclear power plants
• CSA Group standard N286-12, Management system requirements for nuclear facilities

Details on their applicability and implementation are provided in appendix E and section 3.

Licensee management systems encompass nuclear policy statements, descriptions of interfaces and supporting documentation that control and maintain the programs and processes that the management system comprises. The CNSC’s compliance verification activities gather objective evidence of the effectiveness of licensee management systems in accordance with regulatory requirements.

#### Organization

The organization of each licensee is defined in its management system documentation. Organizational structure, authorities, accountability and the responsibilities of positions are defined, including internal and external interfaces, how decisions are made and by whom. The CNSC’s compliance verification activities check that the organizational structures, roles and responsibilities are documented and current in the context of the processes reviewed during inspections and other oversight.

#### Change management

Licensees have approved processes to control changes to their organization, documentation, processes, programs, designs, drawings, structures, systems, components, equipment, materials and software. The processes ensure that changes are documented, justified and reviewed by stakeholders to assess the potential impact on safety. The level of approval is commensurate with the impact and complexity of the change.

#### Safety culture

Licensees periodically conduct safety culture self-assessments. Data is gathered by various methods, including surveys, interviews and focus groups. Bruce Power, OPG and NB Power have implemented safety-culture monitoring panels, in keeping with the guidance provided by the Nuclear Energy Institute. CNSC staff review licensees’ safety culture self-assessments and their results to confirm the adequacy of the licensees’ follow-up actions.

#### Configuration management

The licensees’ configuration management integrates management processes that ensure that the physical and operational configuration and documentation conform with the design requirements and licensing basis. These processes include the review of completion assurance before turning over structures, systems and components (SSCs) to operations.

#### Records management

Records management systems ensure that only approved and current documents are issued and used. Obsolete documents are withdrawn. Records are produced and reviewed for acceptance. Documents and records are available when they are needed. Records are protected and retained in accordance with the applicable regulatory requirements. CNSC staff base their assessment of the licensees’ implementation of the document and record control processes on many regulatory activities involving a variety of SCAs.

#### Management of contractors

CNSC staff assess licensees’ implementation of the supply chain programs that qualify contractors and manage contractual requirements and contractors’ work. Licensees’ management defines, plans and controls the business by establishing safety objectives that meet regulatory and licensee requirements. How well those objectives are achieved is measured and monitored, as are aspects that are assigned to contractors.

Licensees have measures in place to continue achieving their safety and business objectives in the event of disabling circumstances; these measures include contingency plans for maintaining or restoring critical safety and business functions.

#### Performance assessment, improvement and management review

Licensees continually assess and improve their management systems. Their senior management confirm their management system’s effectiveness in controlling safe operation through annual performance monitoring reviews. The input in these reviews includes audit and self-assessment results, the status of corrective actions and the key performance indicators used to maintain control of their processes and operate safely. From these reviews, actions are taken to resolve weaknesses identified in the management system.

#### Problem identification and operating experience

Licensees have corrective action programs to identify and resolve problems and take into account operating experience (OPEX). When problems arise, licensees take immediate action to limit the impact on their facilities. Problems are documented and reported to the appropriate levels of management to initiate the process of correcting their causes and to prevent the reoccurrence of significant events. The timeframes for controlling deficiencies and completing corrective actions are established.

For systemic or serious problems, licensees conduct root cause analyses. For lower safety-significance problems, the direct and apparent causes are determined. Licensees perform analyses to identify trends. Licensees also have an information-gathering and review process to identify and evaluate relevant OPEX to improve and implement actions that prevent the occurrence of problems.

### 2.2 Human performance management

This SCA covers the activities that enable effective human performance through the development and implementation of processes that ensure licensees have sufficient personnel in all relevant job areas. Personnel have the necessary knowledge, skills, procedures and tools to safely carry out their duties.

Human performance management ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
SA SA SA SA SA SA SA SA SA

Human performance management encompasses the following specific areas:

• human performance program
• personnel training
• personnel certification
• initial certification examinations and requalification tests
• work organization and job design
• fitness for duty

#### Human performance program

The human performance program is applied as a corporate requirement across the licensee organizations and implemented locally within the various departments, so it is applicable to both the NPPs and WMFs. Licensees use a human performance program to minimize errors and to support workers in completing their tasks effectively and safely.

#### Personnel training

The licensees use training systems based on the principles of a systematic approach to training (SAT).

The following publication contains regulatory requirements for NPPs and WMFs that were relevant in 2017:

• CNSC REGDOC-2.2.2, Personnel Training

Details on its applicability and implementation are provided in appendix E and section 6.2.

#### Personnel certification

This specific area applies to the NPPs but does not apply to the DWMF, PWMF or WWMF, because they have no certified personnel.

The following publication contains regulatory requirements that were relevant in 2017:

• CNSC RD-204, Certification of Persons Working at Nuclear Power Plants

Details on its applicability are provided in appendix E and section 3.

To become a certified worker, a candidate must successfully complete the training program and certification examinations. The CNSC certifies a candidate who meets the requirements in RD‑204 and who has demonstrated competence to safely perform the duties of the certified position. After they are certified by the CNSC, workers undergo continuing training and requalification testing to ensure that they maintain the knowledge and skills to safely perform their duties.

CNSC requires NPP licensees to have certified shift supervisors, reactor operators and health physicists. Due to the design of Bruce A, Bruce B and DNGS, the CNSC requires these licensees to also have certified Unit 0 operators (U0Os). The only certified persons working at Gentilly-2 are health physicists.

Table 7 shows the number of certified personnel who are available in the certified positions at each NPP as of December 31, 2017. The table also shows the minimum required number of personnel for each position, which is the minimum number of certified personnel who must be present at all times, multiplied by the total number of crews.

Table 7: Number of available certifications per NPP and certified positions for 2017
Station Reactor operator Unit 0 operatorsa Shift supervisorb Health physicist Total
Bruce A
Actual51 21 19 5c 96
Minimum30 10 10 1 51
Bruce B
Actual58 26 17 5c 106
Minimum30 10 10 1 51
DNGS
Actual58 18 30 3 109
Minimum30 10 10 1 51
PNGS 1, 4
Actual36   16 4d 56
Minimum20   10 1 31
PNGS 5–8
Actual60   19 4d 83
Minimum30   10 1 41
Point Lepreau NGS
Actual12   7 2 21
Minimum6   6 1 13
Gentilly-2
Actual e      3 3
Minimum e      1 1

Notes:

1. There are no U0O positions at PNGS 1, 4, PNGS 5–8 or Point Lepreau NGS.
2. At multi-unit NPPs, the number of shift supervisors is the total of certified shift managers plus certified control room shift supervisors.
3. Five health physicists are certified for both Bruce A and Bruce B.
4. Four health physicists are certified for both PNGS 1, 4 and PNGS 5–8.
5. There are no reactor operators, U0Os or shift supervisors at Gentilly-2.

#### Initial certification examinations and requalification tests

This specific area applies to the operating NPPs, but does not apply to the DWMF, PWMF or WWMF. As part of the personnel certification program to become certified workers, candidates are required to complete initial certification examinations. Workers who are certified are required to complete requalification tests as part of the requirements to renew their certification. CNSC staff administer the initial certification examinations and requalification tests for health physicists. The licensees are responsible for administering the certification examinations and requalification tests for all other certified staff. As noted above, health physicists are the only certified staff working at Gentilly-2. Since CNSC administers the initial examinations and requalification tests for them, this specific area does not apply to Hydro-Québec.

The following publication contains regulatory requirements that were relevant in 2017.

• CNSC RD-204, Certification of Persons Working at Nuclear Power Plants

Details on its applicability are provided in appendix E.

#### Work organization and job design

This specific area applies to the NPPs but does not apply to the DWMF, PWMF or WWMF.

Under the General Nuclear Safety and Control Regulations, licensees are required to ensure the presence of a sufficient number of qualified workers to safely carry out all licensed activities. Furthermore, NPP licensees must maintain a minimum shift complement (MSC) at all times in accordance with their licences. The MSC is specific to each NPP and is influenced by the design of the facility, operating and emergency procedures, and organizational functions. NPP licensees determine their respective MSC by systematic analysis and demonstrate their adequacy in integrated validation exercises which CNSC staff review. The analyses and validation reports become part of the licensing basis for each NPP.

The CNSC requires NPP licensees to report MSC points of non-compliance to it, under CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants. A total of eight MSC points of non-compliance were reported by licensees in 2017. Of the eight events reported, four events were related to the availability and qualifications of full-time and voluntary fire fighters and emergency response personnel. Some of them are described in more detail in section 3. The NPP licensees took appropriate actions to ensure safety was maintained, including operating in “quiet mode”Footnote 1 and calling in additional personnel. CNSC staff did not identify any significant operation-related issues related to these points of non-compliance.

#### Fitness for duty

All NPP and WMF licensees have fitness for duty programs.

The following publications contain regulatory requirements that were relevant in 2017:

• CNSC RD-204, Certification of Persons Working at Nuclear Power Plants
• CNSC RD-363, Nuclear Security Officer Medical, Physical, and Psychological Fitness

Details on their applicability and implementation are provided in appendix E and section 3.

CNSC published REGDOC-2.2.4, Fitness for Duty Volume II: Managing Alcohol and Drug Use in November 2017. It sets out the requirements and guidance for managing the fitness for duty of workers who occupy safety-sensitive and safety-critical positions in relation to alcohol and drug use at all high-security sites. All licensees of high-security sites were asked to provide implementation plans early in 2018. CNSC staff were reviewing the implementation plans in the first half of 2018. Details on this implementation are provided in section 3.

UPDATE: CNSC staff were reviewing the implementation plans in the first half of 2018.

All NPP licensees have procedures that specify requirements concerning hours of work and processes for monitoring compliance with the limits to hours of work. REGDOC‑3.1.1, Reporting Requirements for Nuclear Power Plants requires NPP licensees to prepare a quarterly report on the points of non-compliance with hours of work limits for certified staff who perform safety-related tasks.

In the four quarterly reports submitted to the CNSC in 2017, NB Power reported no points of non-compliance with its hours of work procedure for certified staff, and OPG reported two for the DNGS and one for the PNGS. Bruce Power reported numerous instances of non-compliance with its hours of work procedure for certified staff. These points of non-compliance are discussed in section 3.4.2. There were no points of non-compliance with  provincial hours of work limits at the DWMF, PWMF and WWMF in 2017.

To ensure regulatory clarity and consistency in this area, the Commission approved REGDOC‑2.2.4, Fitness for Duty, Volume I: Managing Worker Fatigue for publication in March 2017. The NPP and WMF licensees submitted implementation plans and timelines to the CNSC. Details on its implementation are provided in section 3.

### 2.3 Operating performance

This SCA includes an overall review of the conduct of licensed activities and the activities that enable effective operating performance.

CNSC staff evaluate licensees’ operating performance by conducting various compliance verification activities which include reviewing quarterly operational reports, reviewing the reports and follow-up actions associated with reportable events, conducting baseline and focused inspections and follow-up on licensee’s responses to inspection findings.

Operating performance ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
FS FS FS FS SA FS FS FS SA

Operating performance encompasses the following specific areas:

• procedures
• reporting and trending
• outage management performance
• safe operating envelope
• severe accident management and recovery
• accident management and recovery

Operating policies and principles for NPPs and WMFs set out specific requirements to meet the design basis of the facility for safe operation. During onsite inspections, CNSC staff verify that safe work practices are being followed and they review licensee record systems to confirm that corrective actions are identified and tracked.

CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants requires operating NPP licensees to report serious process failures to the CNSC. CNSC staff have determined that there were no serious process failures at the NPPs in 2017. CNSC REGDOC-3.1.1 also requires operating NPP licensees to report on performance indicator “number of unplanned transients” to the CNSC. This performance indicator shows the unplanned reactor power transients due to all sources while the reactor was not in a guaranteed shutdown state (GSS).

Unexpected reactor power reductions (or transients) can indicate problems within a plant and place unnecessary strain on its systems. Table 8 summarizes the number of unplanned reactor power transients at NPPs caused by stepbacks, setbacks and reactor trips where the trip resulted in a reactor shutdown. Stepbacks and setbacks are gradual power changes intended to eliminate potential risks to plant operations.

In 2017, all unplanned transients were properly controlled and adequately managed by the reactor control systems. They are discussed further in sections 3.1.3, 3.2.3, 3.3.3, and 3.4.3.

Table 8: Number of unplanned transients
NPP Number of operating reactors Number of hours of operation Un-planned reactor trips1 Step backs Set backs Total unplanned transients2 Number of trips per 7,000 operating hours
DNGS 4 23,846 1 1 2 4 0.29
PNGS 1, 4 2 13,301 1 n/a 3 0 1 0.53
PNGS 5–8 4 29,825 0 0 4 4 0.00
Point Lepreau 1 7,928 0 0 5 5 4 0.00
Bruce A 4 32,965 2 0 0 2 0.42
Bruce B 4 30,871 0 1 6 7 0.00
Industry total 19 138,736 4 2 17 23 0.20

Notes:

1. This includes automatic reactor trips only; it does not include manual reactor trips or trips during commissioning testing.
2. Unplanned transients consist of unplanned reactor trips, stepbacks and setbacks.
3. Stepbacks are not implemented at PNGS 1, 4.
4. There were not five distinct events; see section 3.3.3.

Figure 2 shows the total number of unplanned transients from 2013 to 2017 for both individual operating NPPs and the operating NPPs as a whole (referred to as the industry total). The number of unplanned transients in 2017 was comparable to the numbers in previous years and was acceptable to CNSC staff.

Figure 3 compares the number of unplanned reactor trips for Canada’s operating NPPs per 7,000 hours of operation, a measure used by the World Association of Nuclear Operators (WANO). In 2016, WANO began reporting the overall percentage of reactors that met the WANO targets. WANO targets for overall industry performance for specific reactor types include the following:

• 1.0 unplanned total scram per 7,000 hours critical for pressurized heavy water reactors

Although the WANO target for pressurized heavy water reactors is a more appropriate benchmark for the CANDU reactors at Canadian NPPs, figure 3 indicates a more challenging target (0.5) for pressurized water reactors. The following approximations are derived from representative data in the 2016 WANO performance indicator publication (WANO data for 2017 is not yet available). They can be used to compare Canadian NPP performance with reactor performance worldwide:

• Only 64% of pressurized water reactors worldwide met the WANO industry target of 0.5 unplanned total scrams per 7,000 hours critical
• Only 58% of pressurized heavy water reactors worldwide met the WANO industry target of 1.0 unplanned total scram per 7,000 hours critical

Figure 3 indicates that collectively, Canadian NPPs came well within those targets in both 2016 and 2017.

#### Procedures

All NPPs and WMFs have processes in place to ensure that procedures are developed and changes to them are managed consistently to support the safe operation and maintenance of each facility.

#### Reporting and trending

Sections 29 and 30 of the General Nuclear Safety and Control Regulations outline specific scenarios in which a licensee must file a report to the CNSC. For every reportable event, the licensee must file a full report that provides details of the event, including the effects on the environment, the health and safety of persons, the maintenance of security that have resulted or may result from the situation and the actions the licensee has taken or proposes to take with respect to the reportable event.

The following publications elaborate the regulatory requirements for reporting for NPPs:

• CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants
• CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants, Version 2

Details on their applicability and implementation are provided in appendix E and section 3. Additional requirements and guidance are specified for event, quarterly and annual reports. REGDOC-3.1.1 is described further in section 1.4.3.

CNSC staff found that the licensees’ reporting and trending met regulatory requirements in 2017.

For the WMFs, reporting requirements are found in the applicable regulations, such as the General Nuclear Safety and Control Regulations, and the operating licences. For example, each waste facility operating licence (WFOL) contains a licence condition on reporting requirements that covers the content and submission deadline of quarterly and annual reports.

CNSC staff follow up on all reportable events of NPPs and WMFs in a graded approach, based on the risk significance of the event, including the corrective actions that are taken. CNSC staff inform the Commission of significant reportable events through either event initial reports (EIRs) or regular status updates. The most significant events reported in 2017 relating to the NPPs and WMFs are discussed in this report.

#### Outage management performance

This specific area applies to the operating NPPs but does not apply to the DWMF, PWMF, WWMF or Gentilly-2.

CNSC staff conduct inspections during NPP outages to confirm that regulatory requirements continue to be met and that work is executed safely. CNSC staff monitor the level of performance and achievement of objectives during planned maintenance outages. CNSC staff also confirm that forced outages and outage extensions are managed safely and in accordance with the applicable regulatory requirements. CNSC staff inform the Commission of unplanned outages resulting from reactor trips and their outcomes via EIRs and status reports on NPPs.

#### Safe operating envelope

This specific area applies to the operating NPPs, but does not apply to the DWMF, PWMF, WWMF or Gentilly-2.

The following publication contains regulatory requirements that were relevant to operating NPPs in 2017:

• CSA Group standard N290.15-10, Requirements for the safe operating envelope of nuclear power plants

Each operating NPP’s adherence to its safe operating envelopes (SOE) ensures that each reactor operates in an analyzed state, thereby ensuring adequate safety at all times.

#### Severe accident management and recovery

The licensees have established roles and responsibilities within their organizations to manage severe accidents at their sites, should they occur.  All NPP licensees have developed and implemented severe accident management guidelines (SAMGs). SAMGs include measures to prevent severe damage to the reactor core in the event of an accident, mitigate the consequences of an accident involving damage to the reactor core and achieve stable conditions in the long term.

Licensees have also developed emergency mitigating equipment guidelines (EMEG) to provide instructions for use and deployment of emergency mitigating equipment (EME). The purpose of EME is to provide additional water make-up and power-supply capabilities to cool the fuel, arrest accident progression and mitigate accident consequences for beyond-design-basis accidents, including severe accidents.

In 2017, licensees continued to update their existing SAMGs to incorporate lessons learned post-Fukushima, including the addition of guidelines and strategies to deal with multi-unit events for multi-unit NPPs, and events in irradiated fuel bays and shutdown states.

The following publication was relevant in 2017:

• CNSC REGDOC 2.3.2, Accident Management: Severe Accident Management Programs for Nuclear Reactors (2013)

The 2013 version of REGDOC-2.3.2 provides guidance (but not requirements) for severe accident management. Details on its applicability and implementation are provided in appendix  E and section 3. The CNSC published version 2 of REGDOC-2.3.2, Accident Management in 2015 which supersedes the 2013 version. It provides both regulatory requirements and guidance for managing all accidents, including severe accidents at reactor facilities. The CNSC asked the licensees of operating NPPs to submit their implementation plans. NB Power submitted its plan in 2017 (see section 3.3.3 for details).

#### Accident management and recovery

CNSC compliance verification activities ensure that up-to-date procedures are available to the operators and that those operators are trained in their use. NPP and WMF licensees have adequate procedures in place (e.g., abnormal incident manuals and emergency operating procedures for NPPs) to manage abnormal incidents as well as design-basis accidents. These procedures ensure that incidents are mitigated and the facility is returned to a safe and controlled state. They also prevent the abnormal incident from escalating further into a serious accident.

### 2.4 Safety analysis

This SCA pertains to maintaining the safety analysis that supports the overall safety case for each facility. Safety analysis is a systematic evaluation of the potential hazards associated with the conduct of a proposed activity or facility, and it considers the effectiveness of preventive measures and strategies in reducing the effects of such hazards.

For NPPs, safety analysis is primarily deterministic in demonstrating the effectiveness of the fundamental safety functions of “control, cool, and contain”. Risk contributors are considered by using probabilistic safety assessments (PSAs). Appropriate safety margins should be demonstrated to address uncertainties and limitations of safety analysis approaches.

Safety analysis ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
FS FS FS FS FS FS FS FS SA

Safety analysis encompasses the following specific areas:

• deterministic safety analysis
• probabilistic safety assessment
• criticality safety
• severe accident analysis
• management of safety issues (including R&D programs)

The following publication contains regulatory requirements that were relevant to this SCA in 2017:

• CSA Group standard N286.7, Quality assurance of analytical, scientific, and design computer programs for nuclear power plants

#### Deterministic safety analysis

NPP and WMF licensees submit a safety analysis report for their facilities every five years at a minimum that effectively identifies facility hazards and items that are relied on to safely control or mitigate these hazards. It demonstrates the adequacy of the design of the facility.

The following publications contain regulatory requirements that were relevant in 2017:

• CNSC REGDOC-2.4.1, Deterministic Safety Analysis
• CSA Group standard N293, Fire protection for nuclear power plants (2007)
• CSA Group standard N293, Fire protection for nuclear power plants (2012)
• CSA Group standard N393, Fire protection for facilities that process, handle, or store nuclear substances (2013)

Details on their applicability and implementation are provided in appendix E and section 3.

The NPP licensees are undertaking a safety analysis improvement program linked to the ongoing staged implementation of REGDOC-2.4.1. One area of focus in 2017 was the deterministic safety analysis for common mode events (CMEs) which contains some new features for analyzing multi-unit CANDU reactors.

CNSC staff provide feedback to the NPP licensees on their ongoing safety analysis improvements. The existing licensees’ deterministic safety analyses remained adequate during the continued implementation of REGDOC-2.4.1 throughout 2017.

##### Impact of aging on the safety analysis for NPPs

The aging of a reactor affects certain characteristics of the heat transport system which can result in a gradual reduction of safety margins. Therefore, compensatory measures are implemented to mitigate the impact of aging when needed. The structures, system and components (SSCs) of a reactor are affected by aging simultaneously and to different degrees. As such, the overall safety case of an NPP needs to be periodically assessed and the existing safety margins quantified.

Important parameters related to the safety analysis of reactor aging are systematically monitored through an aging management program put in place by the licensee. The aging management program is supported by the licensee’s assessments of the existing safety margins as reactor conditions change due to aging. The goal of the assessments and aging management programs is to monitor, assess and mitigate the impact of heat-transport system aging on safety analyses and to demonstrate safe plant operation.

CNSC staff were satisfied with the licensees’ consideration of aging in their safety analyses in 2017.

##### Large-break loss-of-coolant accident: safety margin for NPPs

OPG, NB Power and Bruce Power have proposed using the composite analytical approach (CAA) to demonstrate that safety margins for large-break loss-of-coolant accidents (LBLOCAs) are greater than those evaluated using the traditional safety-analysis method that is based on a limit of operating envelope approach. (See the description in the specific area of management of safety issues below for further details.)

At the conceptual level, the proposed CAA methodology is consistent with the requirements set out in REGDOC-2.4.1. However, CNSC staff have determined that the methodology requires further validation and refinement before it can be accepted for regulatory application. A number of key activities have been identified that would lead CNSC staff to accept the CAA methodology. Overall, the industry continues to progress well with all identified activities.

Bruce Power submitted a work plan for CAA development in late 2016 to use the CAA methodology to quantitatively demonstrate that the LBLOCA safety margins were greater than predicted in the analysis for the Bruce B reactors. The work plan was reviewed in 2017 by CNSC staff. CNSC staff concluded that overall, the proposed work is acceptable. However, further clarification is required in some areas. While addressing CNSC staff’s review comments, Bruce Power plans to submit the results in a regulatory application of the CAA for an LBLOCA safety analysis of Bruce B reactors in mid-2019.

OPG continues to support industry efforts in the resolution of LBLOCA safety margins using the CAA as part of its long-term plan. Meanwhile, OPG had proposed an improvement to its current approach, a more realistic implementation of the limit of operating envelope (LOE) methodology to address the LBLOCA safety margin issue in the short term. In 2017, CNSC staff reviewed the proposed work and made certain recommendations in some areas.

UPDATE: OPG addressed some of the CNSC staff’s comments, and it plans to submit its updated LBLOCA safety analysis using the proposed and more realistic implementation of LOE methodology for the DNGS in March 2018 and for the PNGS in a subsequent phase. As mentioned above, OPG also continues to work with Bruce Power to further develop CAA methodology for regulatory application.

NB Power continues to cooperate with Bruce Power on the generic aspects of the CAA project and may consider a CAA-based analysis in the future.

While the development of advanced analytical methods such as CAA continues, CNSC staff  have confirmed that all operating NPPs have sufficient LBLOCA safety margins for the most probable operating states. As a risk control measure, CNSC has put in place a set of interim criteria for the safety margins (in case of discoveries that could decrease margins further) until CAA is implemented in regulatory applications.

##### Fire Safety Analysis

The CNSC requires NPP and WMF licensees to complete and maintain comprehensive fire protection assessment reviews (e.g., CCR and Fire Hazard Analysis (FHA)). These reviews help ensure that each licensee is able to efficiently and effectively prevent, detect and mitigate the effects of a fire, and to protect the ability to safely shutdown in the event of a fire.

#### Probabilistic safety assessment

This specific area applies to the operating NPPs but does not apply to Gentilly-2, nor to the DWMF, PWMF or WWMF.

Table 9: Status of PSAs and reviews
PSA submission Bruce A Bruce B DNGS PNGS 1, 4 PNGS 5–8 Point Lepreau
Last PSA report received 2014 2014 2015 2013 2017 2016
Review status Completed Completed Completed Completed Ongoing Completed
Next PSA report expected 2019 2019 2020 2018 2022 2021
Expected compliance REGDOC-2.4.2 2019 2019 2020 2020 2020 2016

The following publication contains regulatory requirements that were relevant in 2017.

• CNSC REGDOC-2.4.2, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants

Details on its applicability and implementation are provided in appendix E and section 3.

REGDOC-2.4.2 introduces new requirements (e.g., consideration of other radioactive sources, including the irradiated fuel bay, as well as multi-unit impacts).

Bruce Power and the DNGS and PNGS are compliant with CNSC regulatory document S-294, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants, and are progressing in their plans for compliance with REGDOC-2.4.2 by 2019, 2020 and 2020 respectively.  Note that OPG and Bruce Power have already addressed the additional requirements outlined in REGDOC 2.4.2  through the PSA for the consideration of multi-unit impacts, the use of the deterministic safety analyses and/or alternative approaches for the consideration of combinations of external hazards, and the consideration of other radioactive sources, such as the irradiated fuel bays.

NB Power has been compliant with REGDOC-2.4.2, Probabilistic Safety Analysis (PSA) for Nuclear Power Plant since 2016.

In addition to addressing the new requirements in REGDOC-2.4.2, NPP licensees have also worked collaboratively to address direction from the Commission to OPG (associated with renewing the operating licence for the PNGS in 2013) to develop an approach for whole-site PSAs. Whole-site PSAs involve estimating aggregate risk for sites with multiple reactors and other radioactive sources. OPG submitted the whole-site PSA for PNGS in 2017 which included the risk associated with different operating states, shutdown states, the irradiated fuel bay and dry fuel storage. OPG and CNSC staff presented the preliminary results at the Commission meeting in December 2017. CNSC staff agreed with OPG’s overall results, and specifically, the methodology used to avoid double counting accident sequences (CMD 17-M64 References 4).

Bruce Power is expected to submit its whole-site PSA methodology in 2018. The DNGS will study the lessons learned from the pilot whole-site PSA project prior to starting whole-site PSA work.

As part of their action to update the Commission on the activities associated with establishing a proposed regulatory position on risk aggregation (CMD 17-M15.A References 5), CNSC staff updated the Commission in December 2017 on whole-site PSA (CMD 17-M64 References 4). The update included a presentation on staff members’ active role in international efforts, especially with the International Atomic Energy Agency (IAEA) and the Nuclear Energy Agency (NEA), and on site-level PSA (including multi-unit PSA) developments, including risk aggregation. The NEA’s work on the status of site-level PSA developments is targeted for completion in December 2018, while the IAEA’s project on a multi-unit PSA was targeted for completion by October 2019.

#### Criticality safety

NPP and WMF licensees handle and store fuel bundles containing irradiated natural or depleted uranium. Analyses of nuclear criticality safety of these types of bundles have been performed and included in the safety analysis reports. The OPG, Hydro-Québec and NB Power fuel bundles have sufficiently low fissile content that they cannot become critical in air or in light water. Therefore, their respective facilities are not required to maintain nuclear criticality safety programs. However, due to the storage of booster fuel assemblies at Bruce A and the demonstration irradiation of low-void reactivity fuel at Bruce B during the 2006–07 period, Bruce Power is required to have a criticality safety program. The following publication contains regulatory requirements that were relevant to Bruce Power in 2017:

• CNSC RD-327, Nuclear Criticality Safety

#### Severe accident analysis

This specific area applies to the NPPs but does not apply to the DWMF, PWMF or WWMF.

OPG and Bruce Power participated in the Severe-Accident Software Simulator Solution project to improve their methods of probabilistic analysis of multi-unit severe accidents. They submitted the results to the CNSC in 2015. CNSC staff completed their review in 2017 and made some recommendations for improvement.

Additional information on supporting research and development (R&D) related to certain aspects of severe-accident analysis is provided below, in  the specific area of management of safety issues.

Management of safety issues

This specific area applies to the operating NPPs but not to Gentilly-2, nor to the DWMF, PWMF or WWMF.

##### CANDU safety issues

In 2007, CNSC staff identified generic safety issues associated with CANDU reactors as a result of initiatives started by the IAEA to reassess the safety of operating NPPs. CANDU safety issues (CSIs) were classified into broad categories according to the adequacy and effectiveness of the control measures implemented by the NPP licensees, namely:

• Category 1: Not an issue in Canada
• Category 2: Issue is a safety concern in Canada, but appropriate measures are in place to maintain safety margin
• Category 3: Issue is a concern in Canada; however, measures are in place to maintain        safety margins, but the adequacy of these measures needs to be confirmed

A technical briefing on the generic safety issues was presented to the Commission in August 2016 (CMD 16-M34 References 24). The CNSC continued to monitor the management of CSIs by licensees of operating NPPs to ensure timely and effective implementation of plant-specific safety improvement initiatives and risk control measures.

At the end of 2017, there were four remaining Category-3 CSI issues, three of which were related to large-break loss-of-coolant accident (LBOCA).

• AA9 – analysis for void reactivity coefficient
• PF9 – fuel behaviour in high-temperature transients
• PF10 – fuel behaviour in power pulse transients

The industry continues to develop the CAA methodology described above in order to address the LBLOCA CSIs. Through an industry-wide agreement, Bruce Power is taking the lead in the regulatory application of the CAA methodology. Bruce Power requested the re-classification of the LBLOCA CSIs to a lower category.

UPDATE: In 2018, CNSC staff concluded that additional information was needed to justify the re-classification of CSIs AA9, PF9 and PF10 for Bruce Power (CMD 18-H4 References 6).

The fourth category-3 issue, IH6, is related to systematic assessment of the effects of high energy pipeline breaks inside containment. It is only applicable to the PNGS and Point Lepreau.

For PNGS Units 5 to 8, OPG had requested re-categorization of this CSI to Category 2 based on pipe-whip and jet-impingement assessments for various systems. CNSC expected to complete its review of the request by fall of 2018.

UPDATE: CNSC re-categorized CSI IH6 from Category 3 to Category 2 for PNGS Units 5 to 8 in June 2018.

OPG was also completing a leak-before-break analysis for various systems at PNGS Units 1 and 4. Following its anticipated completion in summer of 2018, OPG planned to request the re‑categorization of CSI IH6 for Units 1 and 4 to Category 2. CNSC staff was satisfied with this timeline.

NB Power requested the re-categorization of this CSI to Category 2 based on pipe-whip and jet-impingement assessments for various systems. CNSC expects to complete its review of the request by fall of 2018.

##### Supporting R&D

In 2017, CNSC staff continued to undertake systematic evaluations to confirm that the industry maintains or has access to a robust R&D capability to address emerging issues and enhance knowledge and confidence in the safety provisions in key areas.

CNSC staff reviewed the 2017 CANDU Owners Group (COG) R&D Annual Reports submitted by OPG, Bruce Power, and NB Power. These reports include:

• the annual COG R&D program overview reports and operational plans
• the multi-year strategic plans and capability maintenance reviews at such intervals as they are produced

CNSC staff determined that the licensees complied with the reporting requirements of REGDOC‑3.1.1, Reporting Requirements for Nuclear Power Plants. However, areas in which reporting could be enhanced were identified.

Information on specific R&D projects executed by the licensees and the CNSC is provided in appendix D.

NPP licensees have started a COG joint project to address questions raised by intervenors relating to postulated severe accidents at operating NPPs during licence renewal hearings in 2015. Background information was provided in the Regulatory Oversight Report for Canadian Nuclear Power Plants: 2016 References 1. CNSC staff reviewed the results and presented their findings to the Commission in 2017 (CMD 17-M14 References 7). CNSC staff agreed with the project's dispositions and concluded that issues raised were of low safety significance. This conclusion was shared by external expert reviewers engaged by the CNSC and COG. The Commission was satisfied with the methodical approach, although CNSC staff identified a limited number of topics, deemed of low safety significance, where a more complete experimental or a documented technical basis for the arguments was needed. The main topics were:

• hydrogen/deuterium production and effectiveness of PARs
• modelling by MAAP-CANDU software
• in-vessel retention strategy
• hydrogen/deuterium source term estimation
• long-term monitoring capability

CNSC staff requested that the licensees of operating NPPs document COG R&D work performed to date, work in progress and work planned to specifically address the topics described above. This overview document was provided by all licensees in December 2017. At the end of 2017, CNSC staff were preparing a detailed review for the formal response to the licensees.

### 2.5 Physical design

This SCA relates to activities that affect the ability of SSCs to meet and maintain their design basis as new information arises over time and changes take place in the external environment.

Physical design ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
SA SA SA SA SA SA SA SA SA

Physical design encompasses the following specific areas:

• design governance
• site characterization
• facility design
• structure design
• system design
• component design

In addition to the extensive design requirements applicable to operating NPPs and WMFs listed in this report, general guidance for the design of NPPs is provided in CNSC REGDOC-2.5.2, Design of Reactor Facilities: Nuclear Power Plants which would apply to new-build as requirements and as guidance for existing NPPs.

In 2017, each licensee executed various modifications with no impact on its ability to operate within its safety case, while improving the overall performance of its facilities and improving safety in design and operations.

#### Design governance

Licensees have policies, processes and procedures that provide direction and support for physical design. Licensees’ design management is supported by programs that govern the conduct of engineering, pressure boundaries, seismic qualification, environmental qualification, human factors in design, robustness and fire protection, as well as change control mechanisms within their management systems.

##### Seismic qualification

Seismic qualification is the verification of an SSC’s ability to perform its intended function during and/or following the designated earthquake through testing, analysis or other methods. The following publication contains regulatory requirements that were relevant in 2017:

• CSA Group standard N289.1, General requirements for seismic design and qualification

Details on its applicability and implementation are provided in appendix E.

CNSC staff determined that all licensees have established seismic qualifications that meet the applicable regulatory requirements or guidance.

##### Environmental qualification

An environmental qualification program ensures that all required SSCs are capable of performing their designated safety functions in a postulated harsh environment resulting from design-basis accidents. The following publication contains regulatory requirements that were relevant in 2017:

• CSA Group standard N290.13-05, Environmental qualification of equipment for CANDU nuclear power plants

Details on its applicability are provided in appendix E.

Although these programs are mature, CNSC staff monitor this area closely to confirm that the NPP licensees continue to maintain environmental qualification in the context of aging reactors and limited resources.

##### Pressure boundary design

The following publication contains regulatory requirements that were relevant in 2017:

• CSA Group standard N285.0, General requirements for pressure-retaining systems and components in CANDU nuclear power plants

Details on its applicability and implementation are provided in appendix E.

NPP and WMF licensees implement comprehensive pressure boundary programs and maintain formal service agreements with an authorized inspection agency for pressure boundaries.

##### Human factors in design

The following publication contains regulatory requirements that were relevant in 2017:

• CSA Group standard N290.12-14, Human factors in design for nuclear power plants

Details on its applicability and implementation are provided in section 3 and appendix E.

##### Robustness design

Robustness design and assessment covers the physical design of nuclear facilities for sufficient robustness against anticipated threats. The CNSC’s assessment of this specific area is based on the licensee’s performance in meeting the regulatory commitments for mitigating the potential consequences of these accidents.

##### Fire Protection – Governance

NPP and WMF licensees have fire protection programs to minimize the risk to health, safety and the environment due to fire, ensuring that each licensee is able to efficiently and effectively respond to emergency fire situations. The CNSC requires that fire protection provisions be applicable to all work related to the design, construction, operation and maintenance of nuclear facilities, including the SSCs that directly support the facility and the protected area.

The following publications contain regulatory requirements for operating NPPs or WMFs that were relevant in 2017:

• CSA Group standard N293, Fire protection for nuclear power plants (2007)
• CSA Group standard N293, Fire protection for nuclear power plants (2012)
• CSA Group standard N393, Fire protection for facilities that process, handle, or store nuclear substances (2013)

Details on their applicability and implementation are provided in appendix E.

The CSA Group standards require licensees to submit to CNSC staff third party reviews (TPRs) of proposed modifications that may potentially impact fire protection. TPRs confirm that the compliance criteria for modifications are being met. In 2017, CNSC staff reviewed the TPRs and confirmed that the licensees fulfilled the applicable fire protection requirements for modifications.

#### Site characterization

There is no background information needed for this specific area.

#### Facility design

Facility design and structure design, which are discussed next, pertain to the overall adequacy of the design of the facility and structures, which are governed by licensee design programs and a number of codes and standards.

#### Structure design

The following publication contains regulatory requirements for NPPs that were relevant in 2017:

• CSA Group standard N291, Requirements for safety-related structures for CANDU nuclear power plants (2015).

Details on its applicability are provided in appendix E.

#### System design

CNSC staff activities in 2017 included the confirmation that licensees’ service water, electrical power and fire protection systems functioned as expected.

##### Service water, including emergency service water systems

Service water systems in NPPs provide water to a large number of components and systems. From a nuclear safety perspective, however, the most important service water loads are associated with:

• removing heat from the reactor core (such as moderator heat-exchanger cooling and end-shield cooling)
• performing cooling functions to ensure proper functioning of SSCs important to safety (such as instrument air compressors and boiler room air cooling units)
##### Electrical power systems

Electrical power systems provide necessary support for the safety of an NPP and are important in the defence-in-depth concept. It is essential that NPPs have reliable electrical power supplies to control anticipated deviations from normal operations and to power, control and monitor the plants during all types of events. These electrical power systems include onsite and offsite power systems that work together to provide the power necessary in all conditions so that the NPP can be maintained in a safe state.

Components design

##### Fuel design

Licensees of operating NPPs have mature fuel design and inspection programs.

Over the past several years, operating NPPs have experienced challenges related to fuel performance (e.g., fuel defects, end plate cracking and deposits). However, these challenges have been adequately managed by licensee fuel programs and personnel. Regulatory limits for fuel bundle and fuel channel power were met throughout this period. Fuel performance has, for the most part, now returned to historic norms, and the few remaining challenges have well-developed corrective action plans and mitigation strategies in place. CNSC staff continued to monitor the success of the corrective action plans and were satisfied with the industry’s management of these issues. Details regarding individual licensee challenges and performance are provided in section 3.

##### Cables

Cables are critical to the safe and reliable operation of NPPs due to their widespread use as a connection medium for many systems important to safety. Canada’s operating reactors are aging, and cables are affected by the aging process. The CNSC requires operating NPP licensees to implement cable condition monitoring and surveillance programs, as well as cable aging management programs to assess the degradation of cable insulation over time.

### 2.6 Fitness for service

This SCA covers activities that affect the physical condition of SSCs to ensure that they remain effective over time. This includes programs to ensure that all equipment is available to perform its intended design function when needed.

Fitness for service ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
SA SA SA SA SA SA SA SA SA

Fitness for service encompasses the following specific areas:

• equipment fitness for service/equipment performance
• maintenance
• structural integrity
• aging management
• chemistry control periodic inspection and testing

Equipment fitness for service/equipment performance

This specific area applies to the NPPs but does not apply to the DWMF, PWMF or WWMF. An important consideration for NPPs under the specific area is the reliability of systems important to safety.

The following publication contains regulatory requirements for operating NPPs that were relevant in 2017:

• CNSC RD/GD-98, Reliability Programs for Nuclear Power Plants

Details on its applicability are provided in appendix E.

Multiple special safety systems in CANDU reactors provide protection against process system failures. The special safety systems are required to be available and effective for continued operation. These special safety systems include two shutdown systems that are independent of each other. The first system uses shutoff rods that drop into the reactor core by gravity with initial assistance from a spring. The second system uses the injection of a neutron-absorbing solution into the moderator. At least one shutdown system will operate, if required, following any process system failure.

In addition to the special safety systems, the CANDU design provides other safety-related systems and features that perform solely safety functions. If unavailability is detected, immediate actions are taken to ensure that safety is maintained at all times.

Operating NPP licensees’ reliability programs trend system performance, for example by monitoring process parameters, station condition records, and test and inspection results, and initiating investigations or maintenance activities as needed.

CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants requires each operating NPP licensee to report annually to the CNSC on the results of its reliability program. CNSC staff review these reports to confirm compliance with the regulatory requirements.

The annual reliability reports include information on the reliability of the special safety systems. Availability is the fraction of time for which the system can be demonstrated to meet all of the minimum allowable performance standards. Overall, the special safety systems performed well in 2017 to meet their unavailability targets (apart from those exceptions noted in section 3 of this report). Notwithstanding the backup systems in place, licensees took appropriate actions to address the incidents that led to unavailability and corrected the situations.

In addition, the licensees’ reliability programs require that the availability of systems important to safety be confirmed through surveillance activities, such as tests and inspections. Missed tests are tracked by licensees and reported to the CNSC in accordance with REGDOC-3.1.1. The numbers are a measure of a licensee’s ability to successfully complete routine tests on safety-related systems and calculate the predicted availability of systems. Data for the NPPs and the industry as a whole are shown in table 10 and figure 4.

The total number of missed safety-system tests remained very low in 2017. In all, 47,657 tests were performed, and the percentage of missed tests was 0.01%. The impact of missing a single test is negligible, because the safety systems involved in the tests have sufficiently high redundancy to ensure their continuous availability.

Table 10: Safety system test performance for 2017
Nuclear power plant Number of annual planned tests Safety system tests not completed Percent not completed
Special safety systems Standby safety systems Safety-related process systems Total
DNGS 10,093 0 1 0 1 0.01
PNGS 13,608 0 0 0 0 0.00
Point Lepreau 4,202 0 1 0 1 0.02
Bruce A 10,454 0 3 0 3 0.03
Bruce B 9,300 0 0 0 0 0.00
Industry total 47, 657 0 5 0 5 0.01

#### Maintenance

The following publication contains regulatory requirements that were relevant in 2017:

• CNSC RD/GD-210, Maintenance Programs for Nuclear Power Plants

Details on its applicability are provided in appendix E. REGDOC-2.6.2, Maintenance Programs for Nuclear Power Plants superseded RD/GD-210 in August 2017; the requirements and guidance are unchanged. REGDOC-2.6.2 will replace RD/GD-210 as the applicant requirement in the upcoming licence renewal for each NPP or through the regular LCH revision process.

CNSC staff routinely monitor several maintenance safety performance indicators, including ones that must be reported under REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants, including the preventive maintenance completion ratio (PMCR), maintenance backlogs and number of preventive maintenance deferrals.

There are no pre-determined limits for these indicators; CNSC staff track trends and compare the values of these indicators at individual NPPs with the industry average to help determine whether closer regulatory scrutiny is warranted. Based on the values and trending, the CNSC might, for example, increase the focus on maintenance during regular field inspections, adjust the frequency of the baseline compliance program inspection on maintenance planning and scheduling, or conduct a reactive inspection to verify the causes for and determine the actual safety significance of the values observed.

The PMCR quantifies the preventive maintenance program’s effectiveness at minimizing the need for corrective maintenance activities. The average PMCR value for NPPs was 88% in 2017. CNSC staff were satisfied with this value.

The corrective maintenance backlog, deficient maintenance backlog and deferrals of preventive maintenance are performance indicators that monitor the effectiveness of the maintenance program at NPPs. A certain amount of backlog is always expected due to normal work management processes and equipment aging. Although usually not safety-significant, maintenance backlogs can be a useful indicator of overall maintenance effectiveness and plant operation. Corrective maintenance work is required when an SSC has failed and can no longer perform its design function. As defined in REGDOC-3.1.1, corrective maintenance backlogs consist of all corrective work generated through work order requests and that appear in the work management system as uncompleted work.

Deficient maintenance is planned when SSCs of NPPs have been found to be degrading, but remain capable of performing their design functions. The deficient maintenance backlog consists of all deficient work generated through work requests and that appear in the work management system as uncompleted work.

The corrective and deficient maintenance backlogs reported in this regulatory oversight report are for critical components, in other words  safety-significant components.

Deferred preventive maintenance is preventive maintenance at NPPs for which a technical justification for extension has been approved prior to its late date.

The maintenance backlogs and deferrals for the industry are provided in table 11.

Table 11: Trend of industry maintenance backlogs and deferrals for critical components of NPPs
Performance indicator Average quarterly work orders per unit in 2015 Average quarterly work orders per unit in 2016 Average quarterly work orders per unit in 2017 Three year trending
Corrective maintenance backlog 11 8 4 Down
Deficient maintenance backlog 117 111 94 Down
Deferrals of preventive maintenance 49 38 30 Down

The industry average for these three performance indicators continued to drop in 2017. Overall, CNSC staff were satisfied with the progress in 2017. The current levels of maintenance backlogs for the NPPs represent a negligible risk to the safe operation of the NPPs.

#### Structural integrity

The following publications contain regulatory requirements that were relevant in 2017:

• CSA Group standard N285.4, Periodic inspection of CANDU nuclear power plant components (2005)
• CSA Group standard N285.4, Periodic inspection of CANDU nuclear power plant components (2009)
• CSA Group standard N287.7, In-service examination and testing requirements for concrete containment structures for CANDU nuclear power plants
• CSA Group standard N285.5, Periodic inspection of CANDU nuclear power plant containment components
• CSA Group standard N285.8, Technical requirements for in-service evaluation of zirconium alloy pressure tubes in CANDU reactors (2005)
• CSA Group standard N285.8, Technical requirements for in-service evaluation of zirconium alloy pressure tubes in CANDU reactors (2010)

Details on their applicability and implementation are provided in appendix E.

Licensees have processes to monitor and assess structural integrity, such as the inspection of pressure boundary components and containment for NPPs, and the inspection and testing of dry storage containers (DSCs) and storage facility structures for WMFs. After DSCs are loaded with used fuel, they are required to undergo several inspections and tests to confirm their integrity before placing them into storage. These processes draw on results from aging management activities, which are described in the next section.

NPP licensees also monitor and assess safety-significant balance-of-plant systems. Balance-of-plant pressure boundary systems consist of the systems and components that comprise a complete NPP, excluding the systems that are subject to inspection in accordance with CSA Group standard N285.4, Periodic inspection of CANDU nuclear power plant components, which are typically considered non-nuclear systems.

In 2017, CNSC compliance verification reviews related to the specific area of structural integrity include desktop reviews of reports provided by the licensee (e.g., quarterly operations reports, pressure boundary reports and event reports as required in REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants, and inspection reports and annual aging management reports for DSCs).

CNSC staff determined that all licensees continued to inspect and demonstrate the structural integrity of passive NPP components and structures, including those for pressure boundary systems, containment systems and safety-significant balance-of-plant systems, in accordance with the stations’ periodic inspection programs and applicable standards. No significant issues were reported to the CNSC.

#### Aging management

NPP and WMF licensees have implemented processes and programs to address aging-related factors that could affect the condition of SSCs important to safety. The licensees manage known and plausible aging-related degradation of SSCs to prevent the erosion of design and safety margins.

The following publications contain regulatory requirements that were relevant in 2017:

• CNSC RD-334, Aging Management for Nuclear Power Plants
• CNSC REGDOC-2.6.3, Aging Management

Details on their applicability and implementation are provided in appendix E and section 3.

The CNSC requires NPP licensees to have component-specific aging management programs – licensees typically refer to them as lifecycle management plans (LCMPs) – for the major primary heat transport components of their reactors (i.e., feeders, pressure tubes and steam generators) as well as for reactor internals, concrete containment structures and balance-of-plant safety-related civil structures.

The LCMPs include structured, forward-looking inspection and maintenance schedule requirements to monitor and trend aging effects and any preventive actions necessary to minimize and control aging degradation.

The CNSC also requires the WMFs to have aging management plans for DSCs to address plausible aging mechanisms. OPG also has inspection programs in place at the WMFs to  support the aging management of civil structures.

Compliance monitoring activities conducted by CNSC staff included desktop reviews of licensee submissions relating to integrated aging management programs and components and structure-specific LCMPs; the activities also included onsite inspections to assess licensees’ implementation of these programs.

The licensees update their LCMPs to incorporate operating experience and research findings, then submit them to the CNSC for a review of compliance with the requirements of REGDOC­‑2.6.3.

Aging management programs for pressure tubes are important to the ongoing safe operation of the NPPs, as the operating conditions in CANDU fuel channels have significant effects on the material properties. Pressure tube aging management activities include inspections to verify the condition of the tubes and to monitor material property changes (see the section on structural integrity, above).

The licensees demonstrate the ability to safely operate pressure tubes through assessments of the current and expected conditions of the pressure tubes that are based on an understanding of relevant degradation mechanisms. Research activities and inspection and maintenance programs provide data to periodically validate the input parameters for these assessments. One important parameter is fracture toughness, which is modelled and used for leak-before-break assessments for pressure tubes (a key assessment to demonstrate the continued safe operation of aging fuel channels). For temperatures below 250°C, one critical input in the fracture toughness model is the hydrogen equivalent content (Heq) in the pressure tube. The analytical fracture-toughness model that the CNSC currently accepts for use in this temperature range is valid only up to a Heq concentration of 120 ppm. Details about the current and anticipated future fuel channel conditions and validity of the fracture toughness model for the NPPs in OntarioFootnote 2 are provided in appendix H.

In 2017, CNSC staff actively monitored the industry’s progress in research activities to ensure licensees have a sufficient understanding of degradation issues to safely operate pressure tubes, especially those planned for extended operation. Specifically, CNSC staff monitored the fuel channel life management project, which included the following activities in 2017:

• Research focusing on the fracture toughness of near-inlet areas of pressure tubes
• Initiation of the development of a revised version of the fracture toughness model, including collection of supporting burst-test data
• Continued development of assessment methodologies:
• a probabilistic approach for demonstrating fracture protection (i.e., the ability to satisfy the design intent of a pressure tube when an undetected crack is postulated)
• a deterministic approach for assessing risks posed by hydride region overload (i.e., when a hydride area is exposed to greater stress than existed when it was initially created, which could lead to crack initiation)

Overall, CNSC staff were satisfied that the LCMPs for pressure tubes provided a sound basis for licensee aging management activities. CNSC staff also continued to review the results from fuel channel inspections that occurred routinely during planned inspection outages in 2017. CNSC staff confirmed that no new flaw-degradation mechanisms were identified and that licensees appropriately evaluated any findings that required disposition, in accordance with CSA Group standards. CNSC staff concluded that the fitness for service of inspected pressure tubes was effectively demonstrated.

In addition to pressure tube aging, LCMPs address the aging and behaviour of fuel channel spacers, which maintain the gaps between pressure tubes and their corresponding calandria tubes. If contact were to occur between a pressure tube and the cooler calandria tube, pressure tube degradation could result. Licensees assess the possibility of spacer movement along the fuel channel (which could increase the likelihood of pressure-tube to calandria-tube contact) over time and correct the positioning if necessary. In 2017, the fuel channel life management project also continued research and development on fuel channel spacer degradation and supported the development of a set of fitness-for-service guidelines. CNSC staff are satisfied with the licensees’ work to ensure fuel channel spacers continue to perform their design function. A review of available information confirms that the spacers are behaving in a predictable manner.

#### Chemistry control

Licensees’ programs establish processes, address overall requirements and identify staff accountabilities to ensure effective control of chemistry. For NPPs, chemistry control covers operational and lay-up conditions, control of laboratory methods, sampling and analyses, process chemicals, chemistry-control performance monitoring and reporting. These programs maintain system chemistry at the conditions necessary to minimize corrosion and performance degradation during all plant states, and they contribute to safe and reliable plant operation. Proper chemistry control maximizes equipment life, reliability and long-term performance. Chemistry specifications identify parameters that must be controlled within specific limits.

The CNSC requires licensees of operating NPPs to report on the safety performance of their chemistry programs through the Chemistry Index and Chemistry Compliance Index in accordance with CNSC REGDOC 3.1.1, Reporting Requirements for Nuclear Power Plants. The chemistry index is the percentage of time that the selected chemical parameters are within specification. It quantifies the long-term control of important chemical parameters in accordance with licensee requirements. The chemistry compliance index is the average percentage of time that selected important chemical parameters are within the licensees’ specifications for guaranteed shutdown state and non-guaranteed shutdown state conditions. Index values that are close to 100 indicate that measured parameters are maintained within specifications most of the time.

Figures 5 and 6 show the values of the chemistry index and the chemistry compliance index for operating NPPs from 2013 to 2017. Based on these values, CNSC staff determined that chemistry control was acceptable for all licensees. The downward trend and comparatively low results for the chemistry compliance index for Bruce A and B (figure 6) were due to a downward trend in moderator (D2O) isotopic purity for all units. However, there was no impact on the safe operation of Bruce A and B, and safety system functions were not impaired. Bruce Power has since applied corrective action to its use of D2O upgraders and its de-tritiation program.

#### Periodic inspection and testing

This specific area applies to the operating NPPs but does not apply to the DWMF, PWMF, WWMF or Gentilly-2.

The following publications contain regulatory requirements that were relevant in 2017:

• CSA Group standard N285.4, Periodic inspection of CANDU nuclear power plant components (2005)
• CSA Group standard N285.4, Periodic inspection of CANDU nuclear power plant components (2009)
• CSA Group standard N285.5, Periodic inspection of CANDU nuclear power plant containment components
• CSA Group standard N287.7, In-service examination and testing requirements for concrete containment structures for CANDU nuclear power plants

Details on their applicability and implementation are provided in appendix E and section 3.

Licensees of operating NPPs have inspection and testing programs to provide ongoing monitoring of the fitness for service and structural integrity of safety-significant SSCs. After every inspection campaign, the results of the inspections and tests are submitted to CNSC staff, who verify the licensees’ effective implementation of the inspection and testing programs.

This SCA covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations. This program must ensure that contamination levels and radiation doses received by individuals are monitored, controlled and maintained as low as reasonably achievable (ALARA).

The dose data presented in this report is based on the radiation exposure records for every individual monitored at a Canadian NPP or WMF. This report presents and analyzes these dose records in terms of annual collective doseFootnote 3, average effective doseFootnote 4, maximum individual effective dose and distribution of doses among the monitored individuals.

Figures 7, 8 and 9 present the effective doses (average and maximum) and dose distributions to monitored persons, based on the dose records provided to the CNSC by the NPPs and WMFs. The estimated dose to the public from Canadian NPPs and WMFs, for 2013 to 2017 is provided in figure 10.

DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
SA SA SA SA SA FS FS SA SA

Radiation protection encompasses the following specific areas:

• application of ALARA
• worker dose control
• estimated dose to the public

#### Application of ALARA

NPP and WMF licensees implement radiation protection measures to keep the doses to persons ALARA, taking into account social and economic factors, as required by the Radiation Protection Regulations.

In 2017, the total collective dose for monitored individuals at all Canadian NPPs and WMFs was 23.33 person-sieverts (person-Sv), approximately 23% higher than the industry-wide collective dose reported for the previous year (18.94 person-Sv). The number of persons that received a dose in 2017 (9,273) was also significantly higher than 2016 values (7,697). The increase in total collective dose was mainly due to refurbishment activities at the DNGS.

The vast majority of collective dose for the NPPs and WMFs occurs at the operating NPPs. The collective doses for the individual operating NPPs are shown in table 12. It illustrates how outages account for a much greater fraction of the collective dose than routine operations, and how external dose is, collectively, much greater than internal dose.

Table 12: Breakdown of collective dose for operating NPPs in 2017 (person-mSv)
NPP Routine Operations Outages Internal External Total
Pickering 719 3,309 782 3,246 4,028
Darlington 429 12,068 542 11,955 12,497
Point Lepreau 204 361 89 475 564
Bruce A 389 884 132 1,141 1,273
Bruce B 504 4,509 220 4,792 5,012

The annual average effective dose in 2017 for all operating Canadian NPPs and WMFs was 2.52 millisieverts (mSv), an approximate increase of three% from the 2016 value of 2.46 mSv.

Figure 7 shows the average effective doses to monitored persons at each NPP and WMF for the period 2013 to 2017. This figure shows that, for 2017, the average effective dose at each facility ranged from 0.30 to 3.24 mSv per year. In general, the fluctuations in average dose observed from year to year are reflective of the type and scope of work being performed at each facility. No negative trends were identified in 2017.

#### Worker dose control

In addition to maintaining doses to persons below regulatory limits, NPP and WMF licensees have established action levelsFootnote 5 for worker exposures. During 2017, no worker at any NPP or WMF received a radiation dose that exceeded the licensees’ action levels or regulatory dose limits.

CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants requires NPP licensees to report safety performance indicators related to worker dose control. They include tracking of occurrences involving doses received from unplanned exposures or uptakes. CNSC staff monitor licensee actions for the affected workers.

The maximum annual individual effective doses reported by each NPP and WMF from 2013 to 2017 are presented in figure 8. In 2017, the maximum individual effective dose received at a single site was 18.94 mSv by a worker at the DNGS. In 2017, there were no radiation exposures of persons at any NPP or WMF that exceeded the regulatory dose limit of 50 mSv/year for nuclear energy workers, as established in the Radiation Protection Regulations.

Figure 9 shows the distribution of annual effective doses to all monitored persons at all Canadian NPPs from 2013 to 2017. All doses reported were below the annual regulatory dose limit of 50 mSv. In fact, approximately 70% of the doses reported were at or below the much smaller annual regulatory dose limit of 1 mSv for members of the general public.

Overall, CNSC staff were satisfied with the licensees’ control of worker doses in 2017.

The NPP and WMF licensees effectively implement their radiation protection programs and seek to improve program performance through assessment and benchmarking. The licensees maintain program documents and supporting procedures, taking into consideration operating experience and industry best practices. Licensee programs include safety performance indicators to monitor program performance.

The NPP and WMF licensees implement measures in their radiation protection programs to monitor, minimize and control radiological hazards and the spread of radioactive contamination in their facilities. These measures include, but are not limited to, using radiological zoning systems and ventilation systems to control the direction of air flow, and ambient air monitoring and radiation monitoring equipment at zone boundaries. The licensees also set action levels for contamination control.

Workplace monitoring programs protect workers and ensure that radioactive contamination is controlled within the site boundary. In 2017, no contamination control action levels were exceeded and no safety-significant performance issues were identified at any NPP or WMF.

#### Estimated dose to the public

The estimated dose to the public for airborne emissions and liquid releases from 2013 to 2017 are illustrated in figure 10. Note that the data for the Bruce, Darlington and Pickering sites include that of the WWMF, DWMF and PWMF, respectively. Figure 10 shows that the doses to the public were well below the annual regulatory dose limit of 1 mSv for members of the general public.

A comparison of the 2017 data to previous years indicates that the values remained within the same general range as the values for 2013 to 2016.

The value for 2017 for Gentilly-2 was higher than that of previous years, and the values for other NPPs, but was still very small and well within regulatory limits. See section 3.6.7 for further details.

### 2.8 Conventional health and safety

This SCA covers the implementation of a program to manage workplace safety hazards and protect personnel and equipment.

Regulatory requirements for conventional health and safety are found in the relevant provisions of provincial and/or federal laws (the Occupational Health and Safety Act (Ontario), the Ontario Labour Relations Act, the Occupational Health and Safety Act (New Brunswick),  the Act respecting occupational health and safety (Quebec) and the Canada Labour Code, Part II: Occupational Health and Safety). The CNSC has memoranda of understanding with the provinces of Ontario and New Brunswick to facilitate cooperation in regulating conventional health and safety at the nuclear sites. A similar MOU with Quebec is not considered necessary. CSA Group standard N286-12, Management system requirements for nuclear facilities also contains regulatory requirements that are directly applicable to conventional health and safety.

Conventional health and safety ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
FS FS FS FS FS FS SA FS SA

Conventional health and safety encompasses the following specific areas:

• equipment fitness for service/equipment performance
• practices
• awareness

#### Performance

A key performance measure is the number of lost-time injuries (LTIs) that occur per year. An LTI is an injury that takes place at work and as a result, a worker is unable to return to work and carry out his or her duties for a period of time. The number of recordable LTIs reported by the WMFs was zero in 2017 (as it was in 2016).

The NPP licensees are required to report additional safety performance indicators for conventional health and safety, in accordance with CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants. These safety performance indicators are based on averages for 200,000 person-hours worked (approximately 100 person-years). They are not appropriate indicators for Gentilly-2 which has far fewer person-hours than the operating NPPs. Data for Gentilly-2 has been excluded from the following graphs. Hydro-Québec reported one LTI in 2017 which is discussed in section 3.6.7.; it reported zero in 2016.

For operating NPPs, accident severity rate (ASR), accident frequency (AF) and industrial safety accident rate (ISAR) are performance indicators that provide additional measures of the effectiveness of conventional health and safety programs with respect to worker safety. The ASR measures the total number of days lost due to work-related injury for every 200,000 person-hours worked at an NPP. This indicator reflects licensees’ performance in meeting nuclear industry standards in the area of worker health and safety. The AF is a measure of the number of fatalities and injuries (lost-time and medically treated) due to accidents for every 200,000 person-hours worked at NPPs. The ISAR is a measure of the number of lost-time injuries for every 200,000 person-hours worked at NPPs.

The ASR, AF and ISAR values for the operating NPPs and industry average are presented in figures 11, 12 and 13, respectively. CNSC staff observed that the data in figures 11, 12, and 13 indicate continuing low figures in terms of accidents and lost time due to accidents.

CNSC staff observed that there were no work-related fatalities at Canadian NPPs and WMFs in 2017.

Figure 14 indicates that accident frequency at the Canadian NPPs continued to be very low compared to similar industries.

#### Practices

The NPP and WMF licensees establish practices through their conventional health and safety policies and programs to protect workers from physical, chemical and other hazards that may arise in their facilities. Licensees provide the CNSC with any reports made to other regulatory bodies, such as the provincial regulatory body for occupational health and safety.

In addition to being exposed to radiological hazards, workers at NPPs and WMFs could be exposed to other hazardous materials and industrial work hazards. Hazardous materials can include compressed gases, such as gases used for welding activities or fire suppression and for emission monitors. Other materials include lubricants, adhesives, abrasives, solvents, paints, fuel for incinerators and other maintenance and cleaning supplies. In addition to the risks from hazardous materials, the risks from conventional hazards include, for example,  those associated with the control and safe handling of large and heavy items, heavy equipment and conventional x-ray equipment for security-related purposes.

#### Awareness

Licensees deliver safety-related training courses to their employees and contractors. These courses encompass the safety areas of general health and safety knowledge, radiation protection, fire protection, regulatory requirements and job/task-specific safety training, and the use of a Workplace Hazardous Materials Information System (WHMIS)that provides information on the safe use of hazardous materials. The training is supported by management oversight.

### 2.9 Environmental protection

This SCA covers programs that identify, control and monitor all releases of radioactive and hazardous substances, and the effects on the environment from facilities or as a result of licensed activities.

Environmental protection ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
SA SA SA SA SA SA SA SA SA

Environmental protection encompasses the following specific areas:

• effluent and emissions control (releases)
• environmental management system
• assessment and monitoring
• protection of the public
• environmental risk assessment

#### Effluent and emissions control (releases)

The following publications contain regulatory requirements that were relevant in 2017:

• CSA Group standard N288.1, Guidelines for calculating derived release limits for radioactive material in airborne and liquid effluents for normal operation of nuclear facilities (2008)
• CSA Group standard N288.1, Guidelines for calculating derived release limits for radioactive material in airborne and liquid effluents for normal operation of nuclear facilities (2014)
• CSA Group standard N288.3.4, Performance testing of nuclear air cleaning systems at nuclear facilities
• CSA Group standard N288.5, Effluent monitoring programs at Class I nuclear facilities and uranium mines and mills

Details on their applicability and implementation are provided in appendix E and section 3.

As part of normal operations, NPPs release radioactive substances into both the atmosphere (as gaseous emissions) and bodies of water (as liquid effluents), and WMFs release radioactive substances into the atmosphere. Licensees are required to control radioactive releases into the environment to ensure compliance with the regulatory release limits. These limits are based on derived release limits (DRLs) which are quantities of radionuclides (released as an airborne emission or waterborne effluent) calculated based on the regulatory dose limit of 1 mSv per year (1 mSv/y) to members of the general public. The DWMF and PWMF fall under the DRLs for the DNGS and the PNGS, respectively. The WWMF has its own facility-specific DRLs for airborne and liquid releases. The DRLs are given in appendix I. No radiological releases to the environment from the facilities covered in this report exceeded the regulatory limits in 2017.

Licensees also establish and use environmental action levels that, in 2017, were set at approximately 10% of the DRLs, with the exception of Point Lepreau (set at 1% of the DRLs). An action level is a specific quantity of radionuclide (released as an airborne emission or waterborne effluent) that, if reached, could indicate the loss of control of part of a licensee’s environmental protection program and point to the need to take specific actions and report them to the CNSC. In 2017, Hydro-Québec revised the calculation of its DRLs, which CNSC staff accepted in April 2011. In December 2017, OPG submitted new DRLs and ALs for the WWMF for CNSC staff review.

Data on releases of radionuclides to the environment in 2017 are provided in appendix I. The releases were well below the DRLs for each facility; comparisons of the releases with the respective DRLs are also provided in the site-specific discussions of effluent and emissions control in section 3. Further, no environmental action levels were exceeded in 2017 at any facility covered by this report.

#### Environmental management system

The following publications contain regulatory requirements that were relevant in 2017:

• CNSC regulatory document S-296, Environmental Protection Policies, Programs and Procedures at Class I Nuclear Facilities and Uranium Mines and Mills
• CNSC REGDOC-2.9.1, Environmental Protection Policies, Programs, and Procedures (2013)
• CNSC REGDOC-2.9.1, Environmental Principles, Assessments and Protection Measures, Version 1.1 (2017)

Details on their applicability and implementation are provided in appendix E and section 3.

Each licensee has an environmental management system (EMS) to assess the environmental risks associated with its nuclear activities and to ensure that these activities are conducted in a way that prevents or mitigates adverse environmental effects. The EMS includes activities like establishing annual objectives and targets, and it is verified through internal and external compliance audits.

All EMSs for operating NPPs are also registered to ISO 14001: 2015 standard, Environmental Management Systems – Requirements with Guidance for Use References 8. As a result of registration,  EMSs are subject to periodic, independent third-party audits and reviews to verify their sufficiency and to identify potential improvements. By reviewing the documentation of licensee management teams, CNSC staff confirmed that annual management reviews of the EMSs were conducted and that corrective actions were documented.

#### Assessment and monitoring

Under the Nuclear Safety and Control Act (NSCA), the licensee of each nuclear facility is required to develop, implement and maintain an environmental monitoring program to demonstrate that the general public and the environment are protected from emissions related to the facility’s nuclear activities. The results of these monitoring programs are submitted to the CNSC to ensure compliance with applicable guidelines and limits, as set out in the CNSC’s regulations. CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants requires NPP licensees to submit annual environmental reports to the CNSC. Similar requirements apply to WMFs.

The following publications contain regulatory requirements that were relevant in 2017:

• CSA Group standard N288.4-10, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills
• CSA Group standard N288.7, Groundwater protection programs at Class I nuclear facilities and uranium mines and mills

Details on their applicability and implementation are provided in appendix E and section 3.

Licensees monitor groundwater regularly around all sites and submit the results annually to the CNSC. CNSC staff reviewed the 2017 monitoring results and concluded that the licensed operations had no adverse impact on the groundwater environment.

##### Independent Environmental Monitoring Program

To complement ongoing compliance activities, the CNSC has implemented its own Independent Environmental Monitoring Program (IEMP). The IEMP involves taking samples from publicly accessible areas around the facilities, then measuring and analyzing the amounts of radiological and hazardous substances in those samples. Samples may be taken for air, water, soil, sediment, vegetation and some foods, such as meat and produce.

CNSC staff conducted independent environmental monitoring around the Bruce site (which includes Bruce A, Bruce B and the WWMF), as well as at the Point Lepreau site and the Gentilly-2 facilities in 2016. Areas around the Pickering, Darlington and Point Lepreau sites were sampled in 2017. The results are available on the CNSC website.

The IEMP results indicate that the general public and the environment in the vicinity of all sites were protected. The values in the IEMP results were in the same numerical range for the same media as the results submitted by licensees, independently confirming that the licensees’ environmental protection programs did protect the general public and the environment in 2017.

Additionally, regional monitoring is also carried out by other government organizations in the area around the NPPs, which the CNSC takes into account when assessing how the health of the general public and the environment is protected. These include the Drinking Water Surveillance Program by the Ontario Ministry of the Environment and Climate Change, the Ontario Ministry of Labour’s Ontario Reactor Surveillance Program and the Canadian Radiological Monitoring Network by Health Canada, along with its Fixed Point Surveillance Network. These programs provide further confirmation that the environment around the sites is protected and that there are no expected health impacts.

#### Protection of the public

This specific area is related to ensuring that members of the general public are not exposed to unreasonable risk with respect to hazardous substances discharged from the facilities. The dose to the general public is discussed separately in section 2.7.

#### Environmental risk assessment

An environmental risk assessment (ERA) is a systematic process used by licensees to identify, quantify and characterize the risk posed by contaminants and physical stressors in the environment to biological receptors, including humans. It is a practice or methodology that provides science-based information to support decision making and to prioritize the implementation of mitigation measures. The applicant or licensee's ERA informs an environmental assessment (EA) under the Canadian Environmental Assessment Act (CEAA 2012) and forms the basis of an EA under the NSCA. The CNSC requires that the environmental effects of all nuclear facilities or activities be considered and evaluated when licensing decisions are made. All licence applications that demonstrate potential interactions with the environment are subject to an EA, commensurate with the scale and complexity of the environmental risks associated with the facility or activity.

The following publication contains regulatory requirements that were relevant to ERAs in 2017:

• CSA Group standard N288.6-12, Environmental risk assessments at Class I nuclear facilities and uranium mines and mills

Details on its applicability and implementation are provided in appendix E and section 3.

The CNSC reviews the ERAs of the operating NPPs on a five-year cycle, more frequently if major facility changes are proposed or if the science upon which the conclusions are based changes. CNSC staff were satisfied with the status of the ERAs in 2017.

The NPP licensees have developed and implemented programs to ensure that fish are being protected from the effects of the thermal discharge of water and intake water withdrawal (i.e., impingement and entrainment), and to verify that measures are in place to make sure that the risks to fish and fish populations remain acceptable. This work is conducted at the request of CNSC staff with advice from agencies that include Fisheries and Oceans Canada and Environment and Climate Change Canada through memoranda of understanding.

### 2.10 Emergency management and fire protection

This SCA covers emergency response plans and emergency preparedness programs for managing radiological, nuclear and conventional emergencies. It also includes the results of participation in emergency response exercises during the year. For the specific area of fire response, only the performance of the industrial fire brigade organization is addressed in this SCA; design issues are described in section 2.5.

Emergency management and fire protection ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
SA SA SA SA SA SA SA SA SA

Emergency management and fire protection encompasses the following specific areas:

• conventional emergency preparedness and response
• nuclear emergency preparedness and response
• fire emergency preparedness and response

#### Conventional emergency preparedness and response

The NPP and WMF licensees maintain conventional emergency preparedness and response capabilities to manage potential emergency situations, such as physical injuries, chemical releases, uncontrolled energy releases (such as steam, electricity, compressed gas), equipment malfunctions or extreme weather conditions. Licensees have safety and emergency response programs to minimize both the probability of occurrence and the consequences from emergencies involving conventional hazards. These programs identify training, barriers, procedures, processes and the emergency response to demonstrate a planned, coordinated and controlled approach to conventional safety and response.

#### Nuclear emergency preparedness and response

The following publications contain regulatory requirements that were relevant in 2017:

• CNSC RD-353, Testing and Implementation of Emergency Measures (2016)
• CNSC REGDOC-2.10.1, Nuclear Emergency Preparedness and Response (2014)

Details on their applicability and implementation are provided in appendix E and section 3.

The NPP and WMF licensees have emergency preparedness programs that identify the concepts, structures, roles and resources to implement and maintain an effective nuclear emergency response capability. The programs establish how nuclear facilities and other concerned organizations prepare for and plan to respond to emergencies (including nuclear or radiological emergencies, both onsite and offsite), in order to protect workers, the general public and the environment. An effective emergency preparedness program ensures that arrangements are in place to ensure a timely, coordinated and effective response to any emergency.

Each licensee’s response capability is captured in its nuclear emergency plan, which encompasses both emergency preparedness and emergency response measures. It ensures that appropriate emergency response capabilities have been developed and are maintained for an effective response in the event of a nuclear emergency. The plan is centred on the licensee’s planning basis for both design-basis and beyond-design-basis events. Note that OPG has a single, consolidated nuclear emergency plan that governs both the Darlington and Pickering sites.

The licensees nuclear emergency plans include measures to address onsite emergencies and to support planning, preparedness and response for offsite emergencies. The response to offsite emergencies takes a hierarchical approach that involves the licensee, the local municipal government, the provincial/territorial government and the federal government. Background information about the measures provided by each of these stakeholders is provided in appendix K. The following describes developments in 2017 related to the provincial nuclear emergency plans.

##### Province of Ontario

In 2017, the province of Ontario revised its Province of Ontario Nuclear Emergency Response Plan (PNERP). The PNERP underwent a public review involving a formal public consultation, outreach to Indigenous communities and review by an advisory group. CNSC staff submitted proposed changes to the draft PNERP  to the Advisory Group in August 2017. The updated PNERP Master Plan 2017 was approved by the Executive Council of Ontario in December 2017, triggering the development of site-specific implementing plans and the subsequent incorporation of those plans in the Ontario licensees’ emergency plans.

UPDATE: The draft PNERP site-specific implementing plans became available for stakeholder comment in February 2018 and were approved at the end of March 2018. The next step is to formalize the agreements in these plans with the United States, the federal and provincial governments and the affected municipalities. These affected stakeholders will update their site-specific nuclear emergency plans for their nuclear emergency response.

UPDATE: In 2018, the NPP licensees in Ontario began updating their plans and procedures to align with the new PNERP and site-specific implementing plans. The update is administrative and is expected to be operationally complete by March 2019. The licensees plan to complete the revision of training programs for new emergency response staff in 2019.

The Office of the Auditor General (OAG) of Ontario, in its 2017 Annual Report, reported on the status of emergency preparedness in Ontario. There were 14 recommendations regarding the province’s emergency management program and nine that dealt with the nuclear emergency management program. CNSC staff reviewed the OAG report and the responses provided by the Ministry of Community Safety and Correctional Services), which made a commitment to correct the deficiencies identified by the OAG.

UPDATE: The Office of the Fire Marshall and Emergency Management (OFMEM) of Ontario developed a detailed management action plan to address the OAG recommendations. OFMEM staff presented this action plan and a PNERP update at the April 4, 2018, Commission meeting.

In December 2017, the Commission also asked the CNSC to review the OAG Annual Report and determine whether any of the recommendations identified potential improvements to the CNSC’s emergency management program.

In general, the OAG recommendations were intended to enhance compliance with Ontario’s Emergency Management and Civil Protection Act. They were aimed specifically at the OFMEM, along with its offsite key-partner ministries and some of the affected communities in Ontario. The recommendations did not have a direct impact on the CNSC and its nuclear emergency response plan, which generally addresses onsite matters with licensees and ensures that the CNSC understands and validates the technical processes and procedures in place. CNSC staff noted that the recommendations in the OAG Annual Report were consistent with the findings from several major exercises conducted at NPPs in Ontario in recent years.

The CNSC is a member of the Nuclear Emergency Management Coordinating Committee which involves all levels of government and the licensees; the Committee openly discusses some of the more complex issues and determines how they will be addressed.

The OFMEM revised the PNERP and the site-specific implementing plans to take the OAG Annual Report into consideration. The amendments took into account CSA Group standard N1600, General requirements for nuclear emergency management programs, CNSC REGDOC-2.10.1, Nuclear Emergency Preparedness and Response and IAEA standards.

CNSC staff were satisfied with the progress and will continue to support the OFMEM in order to improve the overall nuclear emergency response network in Ontario.

##### Province of New Brunswick

The New Brunswick Emergency Measures Organization (NBEMO) issued the new Point Lepreau Nuclear Off-Site Emergency Plan in August 2017 and made it available online. The NBEMO aligned it with the applicable domestic and international requirements and made its interface more user-friendly. Point Lepreau is compliant with the new plan.

##### Province of Quebec

The offsite nuclear emergency response plan for Quebec (“Plan des mesures d’urgence nucléaire externe à la centrale nucléaire pour Gentilly-2”(PMUNE-G2)) was abolished in 2016. However, Quebec’s broader emergency plan (the “Plan national de sécurité civile” (PNSC)) remains in place to address emergencies in general. The PNSC relies on the cooperation of various ministers and government organizations that have a defined role to play in responding to an emergency. The public health directorate of the Quebec ministry of health and social services will intervene in infectious, chemical, biological or radiological emergencies.

##### Emergency exercises

As part of their emergency preparedness programs, the licensees conduct emergency preparedness training, drills and exercises annually to ensure their sites have adequate and robust emergency notification and response capability from their own staff and/or nearby emergency services with which they have memoranda of understanding or agreements.

On December 6 and 7, 2017, OPG conducted a full-scale exercise (Exercise Unified Control) at the PNGS to test the preparedness and response capabilities and capacities of more than 30 organizations, including the CNSC and some non-government agencies. Additional details about the exercise itself are provided in section 3.2.10.

The CNSC participated in this exercise at its Emergency Operations Centre (EOC) at headquarters,  OPG’s Site Management Centre (SMC) and the OFMEM’s Provincial Operations Centre in Toronto. Health Canada and other Federal Nuclear Emergency Plan partners participated in the exercise at operations centres in Ottawa and Dorval, and at the OFMEM’s Provincial Operations Centre.

The CNSC contracted the services of an expert consultant to conduct an independent evaluation during the exercise. OPG also contracted an expert organization to plan all aspects of the exercise and to write a joint evaluation report of all participating organizations in the context of tier one objectives.

The lessons learned for the CNSC include the following:

• The CNSC EOC needs to refine its briefing methodology, consultation and process with the Emergency Executive Team.
• The EOC Director should focus on tactical and strategic responses when briefing the CNSC President and the Emergency Executive Team.
• The CNSC’s senior management should explore and promote a mutual understanding with OPG and the OFMEM to better resolve the serious issues that could potentially arise.
• For clarity, the CNSC should confirm whether the International Nuclear Event Scale (INES) ratings are helpful when responding to a nuclear emergency in Canada.
• The CNSC should develop a long-term strategy to fully integrate and improve its WebEOC tool for sharing information.
• For future exercises, the CNSC should ensure the operator understands, early in the planning process, that the technical scenario must be sent to the CNSC for review and approval at least six weeks prior to the exercise start date.

The lessons learned for other organizations include the following:

• A clear understanding of the role and responsibilities of the PEOC’s liaison officers is necessary, especially within the PEOC science group, to ensure effective communication and coordination of response activities.
• The OFMEM should review its data validation process, especially when dealing with conflicting information.
• OPG and Region of Durham staff should develop standard radiation guidelines for protective actions for its emergency workers (based on Health Canada’s guidance).
• The province should update its decision-making process for protective actions to take real-time radiation data into consideration.
• Key organizations, such as OPG, the CNSC, the OFMEM and Health Canada, should agree on a common platform for sharing technical data electronically.

The CNSC developed a management action plan to ensure all findings are captured and considered as part of the overall emergency management program.

#### Fire emergency preparedness and response

The following publications contain regulatory requirements that were relevant in 2017:

• CSA Group standard N293, Fire protection for nuclear power plants (2007)
• CSA Group standard N293, Fire protection for nuclear power plants (2012)
• CSA Group standard N393, Fire protection for facilities that process, handle, or store nuclear substances (2013)

Details on their applicability and implementation are provided in appendix E and section 3.

The licensees have fire protection programs to minimize both the probability of occurrence and the consequences of fire at their facilities. The programs identify the procedures and processes to demonstrate a planned, coordinated and controlled approach to fire protection. Fire response capability is maintained through a variety of arrangements.

### 2.11 Waste management

This SCA covers internal waste-related programs that form part of the facility’s operations up to the point where the waste is removed from the facility. This SCA also covers any planning for eventual facility decommissioning.

Waste management ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
FS SA FS SA SA FS FS SA SA

Waste management encompasses the following specific areas:

• waste characterization
• waste minimization
• waste management practices
• decommissioning plans

The licensees’ waste management programs describe how waste is managed throughout its lifecycle up to the point of disposal. This includes waste generation, storage, processing, recycling and removal/transfer.

The licensees continued to provide safe interim storage for LLW, ILW and HLW in 2017, noting that Bruce Power transfers its LLW, ILW and HLW to OPG’s WWMF for management. OPG is moving forward with long-term solutions for the management of LLW and ILW, while Hydro-Québec and NB Power engaged in discussions for possible long-term solutions for their LLW and ILW. Together, OPG, Hydro-Québec and NB Power are also stakeholders in the Nuclear Waste Management Organization (NWMO) which is leading the development of a long-term solution for HLW (described below).

Minimal radioactive waste is generated from the waste management activities conducted at the WMFs. Nonetheless, OPG has set a goal to minimize the amount of radioactive waste generated by the WMFs’ operational activities.

The following publications contain regulatory requirements that were relevant to the waste management SCA in 2017:

• CSA Group standard N292.0, General principles for the management of radioactive waste and irradiated fuel (2014)
• CSA Group standard N292.2, Interim dry storage of irradiated fuel (2007 and revised in 2013)
• CSA Group standard N292.3, Management of low- and intermediate-level radioactive waste (2008 and revised in 2014)

Details on their applicability and implementation are provided in appendix E and section 3.

OPG intends to dispose of low- and intermediate-level waste generated by operations and decommissioning activities in the deep geologic repository (DGR) proposed for the Bruce site. The DGR will be owned and operated by OPG.

The Canadian Environmental Assessment Agency (CEA Agency) and the CNSC established a joint review panel (JRP) in January 2012 to review OPG’s environmental impact statement in support of its application for a licence to prepare the site and construct the DGR. The JRP held public hearings in 2013 and 2014. On May 6, 2015, the JRP issued its environmental assessment report containing 97 recommendations to the Minister of Environment and Climate Change for review and decision under the Canadian Environmental Assessment Act (CEAA  2012). The JRP concluded that OPG’s DGR project is not likely to cause significant adverse environmental effects, provided the mitigation measures proposed, the commitments made by OPG during the review and the mitigation measures recommended by the JRP are implemented.

The Minister of Environment and Climate Change requested additional information from OPG in 2016 and 2017. The CEA Agency will review the additional information, which includes input from the federal review team, Indigenous peoples and the public. Subject to the Minister’s decision, the JRP under the Nuclear Safety and Control Act (NSCA) decides whether to issue a licence to OPG to prepare a site and construct the DGR.

#### Waste characterization, waste minimization and waste management practices

All NPP and WMF licensees continued to employ effective programs for the characterization, minimization, segregation, handling, storage, monitoring and processing (where applicable) of radioactive and hazardous wastes during 2017.

LLW generated at the DWMF and PWMF is typically restricted to floor sweepings that can potentially be contaminated from preparing and welding DSCs. Annual volumes amounting to less than one drum are sent to the DNGS or PNGS, respectively, for segregation as necessary and eventually transported to the WWMF for storage. LLW at the WWMF is processed and/or stored on site. “Likely clean” programs are in place at the DWMF, PWMF and WWMF that allow for at-source separation  of waste that is likely not radioactive, in order to minimize the generation of LLW at these facilities. OPG does not generate ILW at the DWMF, PWMF or WWMF.

In 2014, OPG began a pilot project to sort waste at the WWMF in order to further reduce the volume of waste stored at the facility through incineration, compaction, decontamination or free release. This program continued throughout 2017.

According to assessments of the hazard levels, all radioactive waste was disposed of appropriately using effective waste management practices that complied with the applicable regulatory requirements.

#### Decommissioning plans

The objective of decommissioning is to permanently retire a nuclear facility from service in a manner that ensures that the health, safety and security of workers, the general public and the environment are protected. Decommissioning involves removing radioactive and other hazardous materials from the site, and restoring the site to an agreed on end-state.

Planning for decommissioning is an ongoing process that takes place throughout each stage of the licensed facility lifecycle. Under paragraph 3(k) of the Class I Nuclear Facilities Regulations, licensees develop a preliminary decommissioning plan (PDP) for each facility lifecycle stage before decommissioning. The PDP provides the basis for a cost estimate and financial guarantee, which gives the assurance that funds will be available when the facility is ready to be decommissioned. The licensees are required to revise the PDPs and associated financial guarantees every five years or when requested by the Commission. A detailed decommissioning plan (DDP) is developed prior to decommissioning in support of an application for a licence to decommission.

The following publication contains regulatory requirements that were relevant in 2017:

• CSA Group Standard N294-09, Decommissioning of facilities containing nuclear substances

Regulatory guidance is also found in CNSC document G-219, Decommissioning Planning for Licensed Activities.

Details on their applicability and implementation are provided in appendix E and section 3.

For NPPs, the proposed decommissioning strategy allows for an extended period of storage with surveillance after the end of normal operations. This period would take place under a CNSC licence and would last for three or four decades prior to the onset of active dismantling, allowing for radioactive decay and safe storage of dismantling equipment. The decommissioning strategy for the WMFs, on the other hand, is immediate decommissioning with dismantling activities beginning once the waste is moved to a permanent repository.

OPG updated its PDPs for all of its nuclear facilities including the Bruce A and B NPPs and the  WWMF, DNGS, DWMF, PNGS and PWMF in January 2017 and submitted it to the CNSC for acceptance. These plans covered 2018 to 2022 (the next regular revision is due in 2022). CNSC staff concluded that the plans met the applicable regulatory requirements and guidance.

The PDPs for Point Lepreau and Gentilly-2 are separate and are discussed in sections 3.3.11 and 3.6.11, respectively.

The financial guarantees for decommissioning are discussed in section 2.15.

### 2.12 Security

This SCA covers the programs licensees are required to implement in support of the requirements stipulated in the regulatory documents associated Nuclear Security Regulations , and orders, as well as the expectations for their facilities or activities.

Security ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
SA SA SA SA SA SA SA SA SA

Security encompasses the following specific areas:

• facilities and equipment
• response arrangements
• security practices
• drills and exercises

While not represented as a specific area, cyber security has become an important topic; it is discussed as part of the facilities and equipment specific area, under the heading cyber security.

#### Facilities and equipment

The following publications contain regulatory requirements that were relevant in 2017:

• CSA Group standard N290.7-14, Cyber security for nuclear power plants and small reactor facilities
• CNSC RD-321, Criteria for Physical Protection Systems and Devices at High-Security Sites
• CNSC RD-361, Criteria for Explosive Substance Detection, X-ray Imaging and Metal Detection at High-Security Sites

Details on their applicability and implementation are provided in appendix E and section 3.

OPG partnered with Durham Region’s NextGen public safety radio system. In 2017, it installed radio-system infrastructure at the sites to support improved and interoperable communication links to offsite response services in Durham Region. The project established the P25 safety-grade communications system for the general public as the primary communications system for OPG fire and security organizations.

UPDATE: The system became operational for the security exercise under the CNSC Performance Testing Program at the Pickering site in March 2018 and was evaluated as a performance objective, with positive results.

##### Cyber Security

NPP licensees maintain cyber security programs to protect cyber-essential assets from cyber-attacks. The licensees are working through the CANDU Owners Group cyber-security peer group program to share lessons learned and develop best industry practices for implementing cyber-security controls.

#### Response arrangements

The following publication contains regulatory requirements for operating NPPs that were relevant in 2017:

• CNSC REGDOC-2.12.1, High-Security Sites: Nuclear Response Force

Details on its applicability and implementation are provided in appendix E.

All licensees provide well-trained and suitably equipped nuclear security officers for their facilities.

High-security nuclear facilities have formal arrangements with offsite armed response services; they contributed significant resources to the CNSC performance testing program by providing expert staff and participants to the Canadian Adversary Testing Team.

#### Security practices

NPP and WMF licensees have programs and procedures in place to control access to facilities, nuclear materials, and prescribed information.

The following publications contain regulatory requirements that were relevant in 2017:

• CNSC REGDOC-2.12.2, Site Access Security Clearance
• CNSC REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources

Details on their applicability and implementation are provided in appendix E and section 3.

UPDATE: All licensees were compliant with the regulatory requirements in REGDOC-2.12.3 for categories 1, 2, 3, 4 and 5 sealed sources by May 31, 2018.

The WMFs updated their security operating procedures and ensured that their contingency plans met the design-basis threat in 2017.

After the Treasury Board Secretariat updated its Standard on Security Screening, CNSC staff asked the licensees to implement new screening practices as part of their site access security clearance programs. These best practices will be identified as requirements in the revision of REGDOC-2.12.2 and will apply to the NPPs and WMFs. Each licensee has taken a different approach to adjusting its screening practices in order to meet the updated standard.

#### Drills and exercises

Licensees have exercise and drill programs to validate security practices, ensure regulatory compliance and identify areas for improvement in security operations, including drills with the participation of offsite response.

### 2.13 Safeguards and non-proliferation

This SCA covers the programs and activities required for the successful implementation of Canada’s obligations arising from the Canada/IAEA safeguards agreements, as well as other measures arising from the Treaty on the Non-Proliferation of Nuclear Weapons.

Safeguards and non-proliferation ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
SA SA SA SA SA SA SA SA SA

The safeguards program encompasses the following specific areas:

• nuclear material accountancy and control
• access and assistance to the IAEA
• safeguards equipment, containment and surveillance

This section also includes a statement of the IAEA’s overall conclusion on safeguards for Canada.

The scope of the non-proliferation program for Canada’s NPPs and WMFs is limited to tracking and reporting foreign obligations and origins of nuclear material, as specified in CNSC RD-336, Accounting and Reporting of Nuclear Material. This tracking and reporting assists the CNSC in the implementation of Canada’s bilateral nuclear cooperation agreements with other countries.

#### Nuclear material accountancy and control

The following publication contains regulatory requirements that were relevant in 2017:

• CNSC RD-336, Accounting and Reporting of Nuclear Material

Details on its applicability are provided in appendix E.

#### Access and assistance to the IAEA

NPP and WMF licensees are required to grant adequate access and assistance to the IAEA in order to perform safeguards activities at their respective facilities, including inspections and the maintenance of equipment. The inspections may include an annual physical inventory verification and a number of short-notice and unannounced inspections that target certain groups of material or their transfer.

NPP and WMF licensees are required to submit on-time operational and design information to the CNSC, as well as the information necessary pursuant to the IAEA Additional Protocol.

#### Safeguards equipment, containment and surveillance

NPP and WMF licensees support IAEA equipment operation and maintenance activities at the NPPs and WMFs, including the maintenance and installation of surveillance equipment to ensure the effective implementation of safeguard measures at each facility.

#### IAEA safeguards conclusion for Canada

Based on the IAEA’s comprehensive evaluation of all information relevant to safeguards that is available to it and based on an evaluation of how consistent Canada’s declared nuclear program is with the results of the Agency’s verification activities, the IAEA was able to conclude that all nuclear material in Canada has continued to be used in peaceful activities, including the nuclear material at the NPPs and WMFs.

### 2.14 Packaging and transport

This SCA pertains to programs that cover the safe packaging and transport of nuclear substances to and from the licensed facility.

Packaging and transport ratings
DNGS DWMF PNGS PWMF PLNGS Bruce A Bruce B WWMF Gentilly-2
SA SA SA SA SA SA SA SA SA

Packaging and transport encompasses the following specific areas:

• package design and maintenance
• packaging and transport
• registration for use

While the Packaging and Transport of Nuclear Substance Regulations, 2015 do not apply to onsite transfers of packages, the licensees have programs in place to provide an equivalent level of safety to workers, the general public and the environment, as is required for offsite transportation.

Package design and maintenance

Nuclear substances originating from NPPs and WMFs are required to be transported using packages that meet regulatory requirements. Common shipments include tritiated heavy water, contaminated tooling, laundry, resin and filters, and material samples for analysis.

Packaging and transport

NPP and WMF licensees have programs in place to ensure compliance with the requirements of both the Packaging and Transport of Nuclear Substances Regulations, 2015 and the Transportation of Dangerous Goods Regulations for all shipments of nuclear substances to and from their facilities. All licensees are required to have appropriately trained personnel involved in handling and transporting dangerous goods and to issue a training certificate to those workers in accordance with the Transportation of Dangerous Goods Regulations.

Registration for use

As required by the Packaging and Transport of Nuclear Substances Regulations, 2015, all licensees who use certified packages have registered their use with the CNSC.

### 2.15 Other matters of regulatory interest

Other matters of regulatory interest include public information and disclosure, Indigenous consultation, nuclear liability insurance, financial guarantees and environmental assessment. Environmental assessment is discussed under the Environmental protection SCA.

#### Public information programs

The following publication contains regulatory requirements that were relevant in 2017:

• CNSC RD/GD-99.3, Public Information and Disclosure Program

NPP and WMF licensees have public information and disclosure programs that are supported by disclosure protocols. The protocols outline the type of information that will be shared with the general public (e.g., incidents, major changes to operations, periodic environmental performance reports) and how that information will be shared. The objective is to ensure that timely information about the health, safety and security of persons and the environment and other issues associated with the lifecycle of nuclear facilities is effectively communicated.

The licensees provide information on the status of their facilities through a variety of communication activities, such as information sessions for the general public, facility tours, participation in community events, newsletters, ongoing website updates and social media.

#### Indigenous relations

In addition to the licensees’ work (described in section 3) to build and sustain relationships with Indigenous peoples, the CNSC also works toward strengthening relationships with Indigenous peoples. The efforts of CNSC staff in 2017 supported its commitment to reconciliation and building strong relationships with Indigenous peoples who have interests in Canada’s NPPs and WMFs. CNSC staff continued to work with Indigenous communities and organizations to identify opportunities for formalized and regular engagement throughout the lifecycle of those facilities.

Through this engagement, CNSC staff welcomed the opportunity to discuss all issues of interest and concern, including the licensees’ scheduled reports to the CNSC. CNSC staff continued to work with the licensees to ensure that their scheduled reports were provided to the interested Indigenous communities and organizations.

CNSC staff continued to have regular communications and meetings, including facilitated workshops with Indigenous communities and organizations to discuss their respective interests, issues and concerns. The concerns raised or issues addressed during these meetings included: the CNSC’s IEMP and possible opportunities for participation in the program; the operation of the NPPs and WMFs in Canada; environmental impacts from NPPs; Fisheries Act authorizations; environmental impacts (including on fish); oversight of major component replacements; the CNSC’s role as an agent of the Crown; and the CNSC’s approach to engagement and consultation.

Copies of the Regulatory Oversight Report for Canadian Nuclear Power Generating Sites are sent to all Indigenous communities and organizations who have asked to be kept informed of activities at the NPPs and WMFs. These communities are informed about the availability of funding through the CNSC’s Participant Funding Program to support their participation in the review of this report.

#### Nuclear liability insurance

On January 1, 2017, the Nuclear Liability and Compensation Act (NLCA) came into force, replacing the Nuclear Liability Act (NLA). The NLCA requires nuclear installations (nuclear facilities that have the potential to undergo a nuclear criticality event) to carry nuclear liability insurance.

Whereas the administration of the NLA was shared between the CNSC and Natural Resources Canada (NRCan), the role of administering the NLCA resides solely with NRCan.

Therefore, the CNSC will not require licensees to provide proof of compliance with the NLCA on an ongoing basis. Licensees will be expected to meet their obligations for nuclear liability coverage under the NLCA, in keeping with the CNSC’s general licence conditions that require licensees to comply with all applicable laws. CNSC staff confirm with NRCan that the licensees comply with the financial security obligations of the NLCA.

#### Financial guarantees

NPP and WMF licensees are required to revise their financial guarantees associated with the PDPs every five years or when requested by the Commission.

In January 2017, as part of its submission of its consolidated PDP to the CNSC, OPG submitted information related to its revised financial guarantee for the future decommissioning of its nuclear facilities in Ontario. Following a public hearing in October 2017, the Commission accepted OPG’s revised financial guarantee, which was in the amount of $16.47 billion in 2018 dollars – OPG’s financial guarantee was valued at$ 21.17 billion as of December 31, 2017.

The financial guarantees for Point Lepreau and Gentilly-2 are discussed in sections 3.3.15 and 3.6.15, respectively.

## 3 Nuclear power plant and waste management facility safety performance and regulatory developments

### 3.1 Darlington site

The safety assessment presented below for each SCA is facility-specific. General information relevant to the SCAs is provided in section 2. The CNSC regulatory documents and CSA Group standards that were identified as regulatory requirements for the Darlington site, as of December 2017, are listed in appendix E.

Overall safety assessment

The Darlington site consists of the Darlington Nuclear Generating Station (DNGS), the Tritium Removal Facility (TRF) and the Darlington Waste Management Facility (DWMF). The CNSC staff safety assessment of the Darlington site for 2017 resulted in the performance ratings shown in table 13. Based on the observations and assessments of the SCAs, CNSC staff concluded that the DNGS, TRF and DWMF were operating safely. The overall rating for the DNGS (and TRF) was “fully satisfactory”, unchanged from the integrated plant rating for 2016. The overall rating for the DWMF was “satisfactory”, unchanged from 2016.

Table 13: Performance ratings for the Darlington site, 2017
Safety and control area DNGS rating * DWMF rating
Management system SA SA
Human performance management SA SA
Operating performance FS FS
Safety analysis FS FS
Physical design SA SA
Fitness for service SA SA
Conventional health and safety FS FS
Environmental protection SA SA
Emergency management and fire protection SA SA
Waste management FS SA
Security SA SA
Safeguards and non-proliferation SA SA
Packaging and transport SA SA
Overall rating FS SA

Legend:

• FS – Fully Satisfactory
• SA – Satisfactory
• BE – Below Expectations
• UA – Unacceptable

* Also applies to TRF

#### 3.1.0 Introduction

The Darlington site is located    on the north shore of Lake Ontario in Clarington, Ontario, five kilometres outside the town of Bowmanville and 10 kilometres southeast of Oshawa. The CNSC regulates the DNGS and the TRF through a power reactor operating licence (PROL) and DWMF under a separate, independent waste facility operating licence (WFOL). General statements in this regulatory oversight report about DNGS should be considered as applicable to the TRF, unless stated otherwise. The facilities are owned and operated by Ontario Power Generation Inc. (OPG).

##### Darlington Nuclear Generating Station

The DNGS consists of four CANDU reactors, each one rated at 881 MWe (megawatts electrical). Construction of the facility started in 1981 and the first criticality date of one reactor unit was in 1989.

OPG intends to refurbish the four reactors. The refurbishment of Unit 2 began in October 2016 and continued in 2017. In November 2017, OPG began operating the Retube Waste Processing Building in time for processing the reactor components removed from Unit 2 (end fittings, pressure tubes and calandria tubes).

The TRF, which is housed in the heavy water management building, is used to remove tritium that builds up gradually in some plant systems as a result of day-to-day operations. Removing the tritium minimizes the amount released into the environment and reduces the potential radiation exposure of workers. The tritium is extracted from the reactor’s heavy water and stored safely as titanium tritide in stainless steel containers within a concrete vault.

##### Darlington Waste Management Facility

At the DWMF, OPG processes and stores dry storage containers (DSCs) that hold used nuclear fuel (high-level radioactive waste) generated solely at the DNGS. OPG also manages the intermediate-level radioactive waste generated from the DNGS refurbishment in dry storage overpacks (DSOs) at the DWMF’s Retube Waste Storage Building (RWSB), which was completed and placed in operation in 2017.

The DWMF consists of an amenities building, one DSC processing building, two DSC storage buildings (Storage Buildings #1 and #2) and the RWSB. The DWMF has the capacity to store 983 DSCs and 490 DSOs. The transfer of loaded DSCs from the DNGS to the DWMF is conducted on OPG property with a security escort. The transfer of loaded DSOs from the DNGS to the RWSB is also conducted on OPG property.

The DWMF is contained in its own protected area, separate from the DNGS protected area but within the boundary of the Darlington site. The RWSB is not within a protected area, but it is also located within the boundary of the Darlington site.

OPG is authorized under the current licence for the DWMF to construct two additional DSC storage buildings (Storage Buildings #3 and #4), which would create an additional storage capacity of 1,000 DSCs.

##### Licensing
###### Darlington Nuclear Generating Station

The Commission renewed the PROL for the DNGS, which also governs the TRF, in December 2015 References 10 for a 10-year period with an expiry date of November 30, 2025. The PROL was issued with an accompanying licence conditions handbook (LCH).

In March and April 2017, OPG asked the Commission to amend the PROL for the DNGS to allow the import and export of nuclear substances occurring primarily as contaminants in laundry, packaging, shielding or equipment. These activities were already authorized under a nuclear substance and radiation device temporary possession licence. CNSC staff determined that there were no safety impacts associated with the proposed licence amendment and that it would not change the scope of the import and export activities already authorized under the existing temporary possession licence. On October 26, 2017, the Commission amended Part IV of the DNGS PROL to include the new licensed activity.

###### Darlington Waste Management Facility

The Commission renewed the WFOL for the DWMF in March 2013 References 11 until April 30, 2023. No licensing actions occurred in 2017.

##### Licence conditions handbook
###### Darlington Nuclear Generating Station

CNSC staff revised the DNGS licence conditions handbook (LCH) in 2017 to update the compliance verification criteria in various sections to include new or revised regulatory documents and standards, and licensee documents. See appendix F for details.

###### Darlington Waste Management Facility

The DWMF LCH was not revised in 2017.

##### Fisheries Act authorization

The Fisheries and Oceans Canada (DFO) issued a Fisheries Act authorization on June 24, 2015 for the DNGS. The authorization contains a condition to report on the offset plan (compensation for residual harm to fish and fish habitats) to both DFO and CNSC staff.

##### Refurbishment
###### Darlington Nuclear Generating Station

CNSC staff were actively monitoring and conducting compliance verification inspections of the refurbishment of Unit 2, which started its refurbishment outage on October 14, 2016.

CNSC staff focused their regulatory oversight on the regulatory deliverables specified in the Integrated Implementation Plan (IIP), put in place pursuant to licence condition 15.3 in the PROL. The IIP was approved by the Commission during the licence renewal process. The Commission delegated to CNSC staff the authority to accept scheduling changes, as per the change control and closeout process referenced in the LCH, including changes concerning the return to service of Unit 2.

The work to which OPG committed in the IIP was progressing according to schedule; OPG submitted its annual report on completed IIP items for 2017 in March 2018. OPG planned and completed 37 IIP tasks in 2017. Table 14 summarizes the IIP tasks that were planned and have already been completed for the duration of the project. CNSC staff were reviewing the report and closing IIP items after confirming that they met the applicable regulatory requirements.

CNSC staff were satisfied with the progress on the IIP in 2017.

Table 14: IIP progress
2015 102 102
2016 38 38
2017 37 37
2018 49 15
2019 111 23
2020 17 2
2021 3 -
2022 108 5
2023 28 -
2024 44 2
2025 61 5
2026 14 0
2027 3 -
2028 12 1
Total 627 230

As part of its 2012 environmental assessment for the refurbishment project, OPG had committed to addressing several station improvement opportunities. These commitments were later incorporated into the IIP to consolidate all of the implementation activities. The station improvement opportunities involved features to further improve plant safety in beyond-design-basis accidents:

• shield tank over-pressure (STOP) modifications in all four units
• containment filtered venting system (CFVS)
• emergency power generator 3 (EPG 3)
• powerhouse steam venting system
• emergency service water and diesel-driven, fire-water pumps

The improvements to the powerhouse steam venting system and the STOP modifications on Units 1, 3 and 4 have been completed. STOP will be modified for Unit 2 during the refurbishment outage prior to restart, in accordance with the original IIP schedule in 2019.

CNSC staff inspected the installation and commissioning of EPG3 and confirmed compliance with the relevant IIP commitments and the regulatory requirements for completion assurance, design, installation, commissioning and turnover.

The CFVS was commissioned and available for service in 2017. CNSC staff inspected the CFVS and confirmed compliance with the IIP commitments for installation and commissioning and the specific requirements for completion assurance, design, installation, commissioning and turnover.

CNSC and OPG established a protocol to clarify requirements for return to service of Unit 2 and the removal of regulatory hold points. There was one revision of this protocol in 2017. The protocol requires regular meetings to monitor refurbishment progress.

##### Event initial reports
###### Darlington Nuclear Generating Station

CNSC staff submitted two event initial reports to the Commission pertaining to the DNGS for the period from January 1, 2017, to June 1, 2018. They are described in table 15.

Table 15: Event initial reports for DNGS
Subject Brief description
Contaminated motors shipped to an unlicensed vendor  References 12 In February 2017, four electrical motors with undetected internal contamination were shipped from DNGS to an unlicensed facility for repair. All four motors had been surveyed for contamination at the DNGS and approved for unconditional transfer prior to shipment. Following the detection of contamination at the repair facility, all four motors and contaminated materials were packaged and shipped back to the DNGS by qualified shippers, in accordance with OPG procedures and the Packaging and Transport Nuclear Substances Regulations, 2015. There were no safety consequences as a result of the incident. The licensee took the necessary measures to prevent the reoccurrence of such an incident.
Internal contamination References 13

In February 2018, two workers were contaminated while working in the Retube Waste Processing Building. The investigation determined that a wrongly classified work site resulted in workers wearing ineffective protective gear for the radiological hazards they encountered. Dose assessments confirmed that the two workers received committed effective doses of 0.28 mSv and 0.31 mSv, well below the licensee’s action level and the regulatory dose limits. CNSC staff conducted a reactive inspection and identified several points of non-compliance with OPG’s radiation protection program requirements. OPG was expected to provide a corrective action plan to address the findings in 2018.

Any findings made in the CNSC’s review of this event will be considered in the assessments for the 2018 regulatory oversight report.

###### Darlington Waste Management Facility

No event initial reports pertaining to DWMF were submitted to the Commission for the period from January 1, 2017, to June 1, 2018.

##### Compliance program

The CNSC’s annual total effort for the compliance program is tabulated in appendix G, at points G.1 and G.7 for the DNGS and DWMF, respectively. The inspections at the Darlington site that were considered in the safety assessments in this regulatory oversight report are tabulated in appendix J.

#### 3.1.1 Management system

CNSC staff concluded that the management system SCA at the Darlington site met the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “satisfactory” ratings, unchanged from the previous year.

##### Management system

CNSC staff determined that OPG’s nuclear management system at the Darlington site met the applicable regulatory requirements in 2017. OPG had completed the transition to the 2012 version of CSA Group standard N286-12, Management system requirements for nuclear facilities.

###### Darlington Nuclear Generating Station

As a result of regulatory oversight, CNSC staff were satisfied with OPG’s performance for this specific area.

###### Darlington Waste Management Facility

CNSC staff conducted a desktop review of OPG’s Nuclear Waste Management Program documentation for the DWMF and determined that it met the applicable regulatory requirements. In 2017, CNSC staff conducted a general inspection at DWMF, with a focus on OPG’s management system. CNSC staff identified minor issues of low safety significance regarding clarity and consistent application of documentation. At the end of 2017, CNSC staff were monitoring the implementation of the corrective actions.

##### Organization

CNSC staff determined that OPG had adequately defined organizational structures and roles, and responsibilities at the Darlington site.

###### Darlington Nuclear Generating Station

In 2017, CNSC staff inspected the implementation of OPG’s organization, roles and responsibilities, and interfaces at the DNGS (and the PNGS) related to the documentation and corporate business units. CNSC staff identified points of non-compliance of low safety significance with respect to identifying all program interfaces and defining roles and accountabilities. At the end of 2017, CNSC staff were reviewing OPG’s corrective action plan and were monitoring OPG’s implementation.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

##### Change management

CNSC staff determined that OPG had an adequate change management program at the Darlington site that complies with the applicable regulatory requirements.

###### Darlington Nuclear Generating Station

As a result of regulatory oversight, CNSC staff were satisfied with OPG performance for this specific area.

###### Darlington Waste Management Facility

In 2017, CNSC staff inspected the change management process at the DWMF and found that its implementation was ineffective for the DSC inspection process and for other generic documentation that is used by all OPG WMFs, resulting in a finding of medium safety significance. As a result of the inspection, OPG created a change management committee to manage governance and process changes for nuclear waste at all the WMFs, and it committed to applying the corrective actions. At the end of 2017, CNSC staff were monitoring the implementation of the corrective actions and overseeing the implementation of OPG’s changes at the DWMF.

##### Safety culture

CNSC staff were satisfied that OPG continued to foster a healthy safety culture at the Darlington site in 2017. CNSC will monitor OPG’s next safety culture self-assessment at the Darlington site scheduled for 2018 and any improvement actions that will be initiated.

##### Configuration management

CNSC staff determined that OPG maintained the configuration of its structures, systems and components (SSCs) at the Darlington site in compliance with its configuration management program and other applicable regulatory requirements.

###### Darlington Nuclear Generating Station

In 2017, CNSC staff inspected configuration management at the DNGS and identified one deficiency of low safety significance with respect ensuring that the status of equipment and systems is known at all times during an outage. OPG addressed this deficiency by reinforcing the requirements of configuration control during outages. In addition, OPG reviewed the robustness of its instructions  and committed to performing a self-assessment during the Unit 3 and Unit 4 outages in 2018. CNSC staff were satisfied with OPG’s corrective action plan which is slated for completion by September 2018.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

##### Records management

CNSC staff determined that OPG continued to maintain and implement a document control and records management system at the Darlington site that complied with the applicable regulatory requirements.

###### Darlington Nuclear Generating Station

During inspections in 2017, CNSC staff identified deficiencies of low safety significance in the control of documents and records at the DNGS with respect to the traceability of documents. CNSC staff reviewed OPG’s corrective action plans and were satisfied with the progress to the end of 2017.

OPG was planning a new records repository for the end of 2020. In 2018, CNSC staff will review this upgrade to ensure it meets the applicable requirements.

###### Darlington Waste Management Facility

The CNSC inspection that focused on OPG’s management system identified deficiencies of low safety significance in the control of documents and records at the DWMF. At the end of 2017, CNSC staff reviewed OPG’s corrective action plans and were satisfied with the progress.

##### Management of contractors
###### Darlington Nuclear Generating Station

CNSC staff confirmed in 2017 that the interfaces between OPG and its contractors at the DNGS were planned, defined, controlled and understood in accordance with the applicable regulatory requirements. In 2016, CNSC staff identified deficiencies of low safety significance in the area of management of contractors at the DNGS during a reactive inspection on quality management and project oversight, concerning maintaining documentation and records of oversight activities.  OPG developed corrective action plans in 2017 and addressed the deficiencies to the satisfaction of CNSC staff.

###### Darlington Waste Management Facility

CNSC staff concluded that the interface between OPG and its contractors at the DWMF did not meet the applicable regulatory requirements in 2017. The CNSC inspection that focused on OPG’s management system revealed that OPG was no longer performing the DSC receiving inspection, including the verification of the DSC history docket received from the vendors, which effectively removed oversight of the vendors. OPG cancelled the source surveillance inspection for DSCs at all three waste management facilities (DWMF, PWMF and WWMF) in 2014, but failed to reflect this change in its internal documentation. CNSC staff assessed this as a finding of medium significance in the context of the management of contractors, but noted that the overall safety significance of the finding was low, because there were several subsequent verification steps in the loading and storage of DSCs.

As a result, CNSC staff directed OPG to conduct an extent-of-condition assessment of DSCs received after 2014, including the DSC history packages, and prohibited the transport of the affected DSCs until OPG completed the extent-of-condition assessment. CNSC staff reviewed OPG’s corrective action plan, which included an extent-of-condition assessment of the affected DSCs, and found it to be acceptable. OPG committed to updating the CNSC on its progress to implement the corrective actions, expected to be complete by 2019. At the end of 2017, CNSC staff were monitoring the implementation of the corrective actions.

CNSC staff concluded that OPG met the applicable regulatory requirements for business continuity at the DNGS and DWMF. CNSC staff verified that OPG had adequate contingency plans in place to maintain or restore critical safety and business functions in the event of disabling circumstances, such as a pandemic, severe weather or labour action.

##### Problem identification and operating experience

CNSC staff determined that OPG met the applicable regulatory requirements for problem identification and OPEX at the Darlington site.

###### Darlington Nuclear Generating Station

In 2017, CNSC staff inspected the event investigation process at the DNGS and found that it complied with the regulatory requirements. However, CNSC staff found that for some event categories, OPG did not consistently conduct a root cause analysis, as required in its corrective action program. For those events, CNSC staff found that OPG conducted a common cause evaluation instead of a root cause analysis.

CNSC staff were satisfied with OPG’s corrective action plans and will continue to monitor their implementation in 2018.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

##### Performance assessment, improvement and management review

CNSC staff confirmed that OPG continued to meet the applicable regulatory requirements for performance assessment, improvement and management at the DNGS and DWMF. CNSC staff had no significant observations to report for the DNGS or DWMF in this specific area for 2017.

#### 3.1.2 Human performance management

CNSC staff concluded that the human performance management SCA at the Darlington site met the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “satisfactory” ratings – unchanged from the previous year.

##### Human performance program

CNSC staff determined that OPG’s human performance program for the DNGS and DWMF met the applicable regulatory requirements. CNSC staff had no significant observations to report for the DNGS or the DWMF in this specific area for 2017.

##### Personnel training

CNSC staff determined that OPG had a well-documented and robust fleet-wide training system based on a systematic approach to training (SAT). The implementation of this system for the training programs at the DNGS and DWMF met the applicable regulatory requirements.

###### Darlington Nuclear Generating Station

In 2017, CNSC staff performed compliance verification inspections of the authorized nuclear operator and contract management personnel training programs at the DNGS. CNSC staff also performed a desktop review of the chemical laboratory staff training program at the DNGS. In all cases, CNSC staff concluded that the training programs were defined and documented in accordance with the OPG’s SAT-based training system and that OPG met the applicable regulatory requirements. Minor procedural points of non-compliance of low safety significance were identified with respect to the documentation of training objectives and how documents that describe training qualifications align with governance. CNSC staff were satisfied with OPG’s progress to address the points of non-compliance.

###### Darlington Waste Management Facility

In 2017, CNSC staff verified that OPG completed, to CNSC staff’s satisfaction, the corrective actions that resulted from the training-focused compliance verification inspection conducted in 2016.

##### Personnel certification
###### Darlington Nuclear Generating Station

CNSC staff determined that OPG’s personnel certification program at the DNGS met the applicable regulatory requirements. CNSC staff reviewed the staffing reports for certified personnel and the applications for initial certification and renewal of certification and confirmed that certified personnel at DNGS possessed the knowledge and skills required to perform their duties safely and competently.

###### Darlington Waste Management Facility

This specific area does not apply to the DWMF because there are no CNSC certified positions at the facility.

##### Initial certification examinations and requalification tests
###### Darlington Nuclear Generating Station

CNSC staff concluded that the initial certification examination and requalification testing programs for certified personnel at the DNGS met the applicable regulatory requirements.

In 2017, CNSC staff conducted a compliance verification inspection of how the simulator-based initial certification examinations are conducted. A point of non-compliance of low safety significance was observed by CNSC staff concerning examination support team members inconsistently performing their role-playing duties in accordance with the requirements during the conduct of the certification examinations. CNSC staff were satisfied with OPGs corrective actions to prevent a reoccurrence.

###### Darlington Waste Management Facility

This specific area does not apply to the DWMF because there are no CNSC-certified positions at the facility.

##### Work organization and job design
###### Darlington Nuclear Generating Station

The minimum shift complement (MSC) at the DNGS met the applicable regulatory requirements in 2017.

In 2017, there were only two MSC violations at the DNGS by duty crew staff, and they did not impact safety. In one instance, a violation occurred when one person left due to a family emergency, and in the other, a person was late calling in sick.

###### Darlington Waste Management Facility

This specific area does not apply to the DWMF.

##### Fitness for duty

CNSC staff determined that OPG met the applicable regulatory requirements for fitness for duty at the DNGS and DWMF.

CNSC staff asked OPG to provide an implementation plan for CNSC REGDOC-2.2.4, Fitness for Duty, Volume I: Managing Worker Fatigue by September 30, 2017. OPG pledged to fully implement this regulatory document at the Darlington site by January 1, 2019. CNSC staff were satisfied with OPG’s implementation plan and will monitor its progress.

OPG also made a commitment to implement CNSC REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use, with the exception of the random-testing requirements, by July 2019. The implementation date for random testing is planned for December 2019. CNSC staff will monitor OPG’s implementation progress.

UPDATE: CNSC staff found the plans to be acceptable, although it notes that the implementation could be impacted by legal challenges.

###### Darlington Nuclear Generating Station

In 2017, CNSC staff completed a desktop review to check how accurately instances of non-compliance with the limit on the number of hours worked for certified staff for DNGS (and PNGS) are reported. CNSC staff identified points of non-compliance related to processes used to track, monitor and report non-compliance with hours of work. By the end of 2017, OPG was developing a corrective action plan that covered both PNGS and DNGS.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

#### 3.1.3 Operating performance

CNSC staff concluded that the Operating performance SCA at the Darlington site met or exceeded the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “fully satisfactory” ratings, unchanged from the previous year.

CNSC staff concluded that OPG met or exceeded the applicable regulatory requirements for the conduct of licensed activities at the DNGS and DWMF. CNSC staff observed that OPG continued to operate the DNGS and DWMF in a safe and secure manner with adequate regard for health, safety, security, radiation and environmental protection, and international obligations.

In 2017, OPG operated the DNGS and DWMF within the bounds of its operating policies and principles and its operational safety requirements.

###### Darlington Nuclear Generating Station

DNGS experienced one unplanned reactor trip, one stepback and two setbacks in 2017. CNSC staff determined that the reactor trip, stepback and setbacks were controlled properly and that the reactor control systems adequately initiated the power reductions. CNSC staff verified that for all events, OPG personnel followed approved procedures and took appropriate corrective actions.

###### Tritium Removal Facility

In 2017, CNSC staff conducted an inspection at the TRF and concluded that the TRF met the regulatory requirements applicable to operating the facility.

CNSC staff observed that the TRF was operated safely and did not exceed any environmental release limits.

###### Darlington Waste Management Facility

In 2017, OPG processed 63 DSCs at the DWMF. From the start of facility production to the end of 2017, OPG had processed and placed 551 DSCs into storage at the DWMF.

In 2017, OPG completed the construction of the RWSB. Before it began operating, CNSC staff reviewed and accepted the RWSB commissioning reports and issued a record of acceptance to OPG in November 2017. As of December 31, 2017, a total of 29 loaded retube waste containers had been transferred from the DNGS to the DWMF.

##### Procedures

OPG has governance to ensure that procedures at the DNGS and DWMF are written in a consistent and usable manner. OPG had clearly documented expectations for procedural use and adherence, and a process to manage procedural changes at the Darlington site. CNSC staff were satisfied with the quality of the OPG procedures and found that they met the applicable regulatory requirements at the DNGS and DWMF.

##### Reporting and trending

CNSC staff determined that OPG’s reporting and trending met or exceeded the applicable regulatory requirements and expectations in 2017 for the DNGS and DWMF.

During the reporting year, all scheduled reports were submitted to the CNSC in a timely manner and were adequate. In accordance with the LCHs, OPG provided notification of document changes to CNSC staff throughout the reporting period that were reviewed by staff, and comments were provided to OPG as applicable.

###### Darlington Nuclear Generating Station

OPG submitted 60 event reports to CNSC regarding the DNGS. CNSC staff found that OPGs reporting and trending processes met or exceeded the applicable regulatory requirements and expectations in 2017 for DNGS and DWMF.  All reported events were followed up by OPG with corrective actions and root cause analysis, when appropriate.

###### Darlington Waste Management Facility

During 2017, CNSC staff received 2 event reports of low safety significance from OPG regarding the DWMF. The event reports are discussed in detail in their applicable SCA section(s) throughout this report.

##### Outage management performance
###### Darlington Nuclear Generating Station

CNSC staff observed that OPG continued to demonstrate high levels of performance and achievement of objectives during outages in 2017.

OPG carried out three planned outages and experienced five forced outages at DNGS. OPG followed up appropriately on all planned and forced outages. CNSC staff determined that all outage-related undertakings, including heat sink management at DNGS, were carried out safely by OPG staff.

CNSC staff found that OPG’s outage management at the DNGS met or exceeded the applicable regulatory requirements and expectations in 2017.

###### Darlington Waste Management Facility

This specific area does not apply to the DWMF.

##### Safe operating envelope
###### Darlington Nuclear Generating Station

CNSC staff determined that OPG operated within the safe operating envelope (SOE) and met the applicable regulatory requirements for the DNGS in 2017.

In 2017, CNSC staff inspected the defueling for Unit 2 refurbishment. CNSC staff observed one point of non-compliance of low safety significance with respect to the tools in place for monitoring the heat load of the irradiated fuel bay. The tools were using overly conservative methodology, leading to an over-estimation of the heat load. CNSC staff confirmed that the bay temperatures always remained within the design limits.

CNSC staff were satisfied with OPG’s corrective action plans and the target date for complete implementation by June 2018.

###### Darlington Waste Management Facility

This specific area does not apply to the DWMF.

##### Severe accident management and recovery

CNSC staff determined that severe accident management and recovery met the applicable regulatory requirements for the DNGS and met or exceeded them for the DMWF. The program has been implemented at the Darlington site with an organizational structure that clearly establishes the roles and responsibilities of all program participants.

###### Darlington Nuclear Generating Station

In 2017, the CNSC commenced a desktop review for DNGS SAMG documentation, including recent updates, expecting to be completed in 2018.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

##### Accident management and recovery

CNSC staff determined that OPG’s accident management and recovery programs for the DNGS and DWMF met or exceeded the applicable regulatory requirements in 2017.

###### Darlington Nuclear Generating Station

OPG has a series of Abnormal Incident Manuals (AIMs) and Emergency Operating Procedures (EOPs) at the DNGS to detect abnormal conditions, mitigate the causes of incidents and accidents, return the plant to a safe and controlled state, and prevent the seriousness of the accident from escalating further. CNSC staff were satisfied that OPG had adequate measures in place.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

#### 3.1.4 Safety analysis

CNSC staff concluded that the safety analysis SCA at the Darlington site met or exceeded the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “fully satisfactory” ratings, unchanged from the previous year.

##### Deterministic safety analysis

CNSC staff concluded that OPG’s deterministic safety analysis projected adequate safety margins and met or exceeded the applicable regulatory requirements at the DNGS and DWMF.

###### Darlington Nuclear Generating Station

CNSC staff determined that OPG has a well-managed program for deterministic safety analyses. OPG continued to implement CNSC REGDOC-2.4.1, Deterministic Safety Analysis, and CNSC staff were satisfied with the progress. CNSC staff were reviewing the revised implementation plan submitted by OPG in 2017.

In 2017, OPG submitted an updated fire hazard analysis (FHA) and fire safety shutdown analysis (FSSA) for the DNGS. CNSC staff reviewed the FHA and FSSA and determined that the approach and methodology were consistent with the applicable regulatory requirements.

###### Darlington Waste Management Facility

CNSC staff determined that OPG maintained a safety analysis program that was effectively implemented at the DWMF and that fully satisfied the applicable regulatory requirements. OPG submits a safety analysis report for the DWMF every five years that effectively identifies facility hazards and the measures in place to control or mitigate these hazards. In 2017, OPG submitted the most recent revision to the safety report for the DWMF and an annex to the safety report for refurbishment waste. CNSC staff reviewed the reports and were satisfied with the updated documents. CNSC staff expect the next safety report for the DWMF to be submitted in 2022.

In 2016, OPG submitted an updated code compliance review and FHA for the DWMF. In 2017, CNSC staff reviewed the updated documents and determined that the approach and methodology used was consistent with CSA Group standard N393-13, Fire protection for facilities that process, handle, or store nuclear substances.

##### Probabilistic safety assessment
###### Darlington Nuclear Generating Station

CNSC staff determined that the DNGS complied with CNSC Regulatory Document S‑294, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants and was transitioning to the implementation of CNSC REGDOC-2.4.2, Safety Analysis: Probabilistic Safety Assessment (PSA) for Nuclear Power Plants. OPG plans to update the PSA models and demonstrate that the DNGS continues to meet the safety goals throughout its life extension refurbishment project. The submission of the next update to the model is expected in 2020; by that time, the DNGS is expected to be fully compliant with REGDOC-2.4.2.

CNSC staff found that OPG’s PSA performance at the DNGS met or exceeded the applicable regulatory requirements in 2017.

###### Darlington Waste Management Facility

This specific area does not apply to the DWMF.

##### Criticality safety

This specific area does not apply to the DNGS and DWMF.

##### Severe accident analysis
###### Darlington Nuclear Generating Station

OPG continues to support the industry R&D program in the area of severe accident analysis.

OPG, with other licensees, has developed a severe accident software simulator solution to improve its methods of conducting deterministic analyses of multi-unit severe accidents. CNSC staff reviewed the analysis and proposed some recommendations, as discussed in section 2.4.

###### Darlington Waste Management Facility

This specific area does not apply to the DWMF.

##### Management of safety issues (including R&D programs)
###### Darlington Nuclear Generating Station

The work by NPP licensees to address the remaining Category 3 CANDU safety issues is described in section 2.4.

The R&D project to establish a methodology for moderator subcooling requirements continued in 2017. OPG submitted the findings made by a safety-analysis issue review panel following its review of the CNSC-sponsored project in which experiments with contact boiling are performed to test calandria tube strain. CNSC staff issued an interim report summarizing the results of the experiments and an evaluation of those results. OPG planned to address the outstanding issues over the next licence period. This issue was considered to be of low safety significance as it only affected safety margins during postulated accidents that have a low probability of occurrence.

###### Darlington Waste Management Facility

This specific area does not apply to the DWMF.

#### 3.1.5 Physical design

CNSC staff concluded that OPG activities that fall under the physical design SCA at the Darlington site met the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “satisfactory” ratings – unchanged from the previous year.

##### Design governance

CNSC staff concluded that OPG continued to meet the applicable regulatory requirements regarding design governance in 2017 for the DNGS and DWMF.

##### Environmental qualification

CNSC staff determined that the environmental qualification program has been implemented in all DNGS units. OPG maintained program sustainability in accordance with the applicable regulatory requirements.

##### Pressure boundary design

CNSC staff observed that OPG continued to implement a comprehensive pressure boundary program at the DNGS that complied with the applicable regulatory requirements.

Human factors in design

OPG completed a gap analysis and developed a plan to implement CSA Group standard N290.12‑14, Human factors in design for nuclear power plants by September 1, 2018.

###### Darlington Waste Management Facility

CNSC staff determined that OPG continued to implement a comprehensive pressure boundary program at the DWMF that complied with the applicable regulatory requirements.

##### Site characterization

CNSC staff had no significant observations at the DNGS or the DWMF to report in this specific area for 2017.

##### Facility design

CNSC staff had no significant observations at the DNGS or the DWMF to report in this specific area for 2017.

##### Structure design

CNSC staff concluded that OPG continued to meet the applicable regulatory requirements regarding structure design for the DNGS and DWMF.

###### Darlington Nuclear Generating Station

In 2017, CNSC staff continued to monitor and review documentation related to a follow-up action from a 2016 inspection on the preservation of the seismic design basis at DNGS. CNSC staff were satisfied with the submission on OPG’s corrective action plan and the actions taken.

###### Darlington Waste Management Facility

In 2017, CNSC staff reviewed the commissioning reports for the RWSB. CNSC staff concluded that the findings were consistent with the RWSB modification design requirements, design objectives, applicable CSA Group standards, commissioning test results and compliance verification criteria, where available. The CNSC confirmed that the commissioning reports were acceptable and authorized OPG to begin operations at the RWSB, as per licence condition 15.2.

##### System design

CNSC staff concluded that OPG continued to meet the applicable regulatory requirements regarding system design in 2017 at the DNGS and DWMF.

###### Darlington Nuclear Generating Station

Electrical power systems

CNSC staff concluded that the electrical power systems at the DNGS met the applicable regulatory requirements.

In 2017, CNSC staff conducted desktop reviews and followed up on the integrated safety reviews (ISRs) and the 2014 compliance verification inspection. No areas of non-compliance were found and CNSC staff concluded that the electrical power systems at the DNGS met the applicable regulatory requirements.

Fire protection design

CNSC staff concluded that the fire protection program at DNGS met the applicable regulatory requirements based on the results of the CNSC’s ongoing compliance activities.

Independent third party reviews for design modifications and for the inspection of the facility site condition were acceptable and yielded no major findings. CNSC staff were satisfied with the level of compliance and concluded that the licensee continues to implement a comprehensive fire protection program at the DNGS.

Instrumentation and control

OPG plans to replace trip computers and monitoring and test computers for Shutdown System 1 and Shutdown System 2 in 2019. OPG demonstrated that the new trip computer hardware and software met the design modification requirements. The CNSC was reviewing the submissions in 2017.

Given the regulatory oversight, CNSC staff were satisfied with OPG’s performance for this specific area.

##### Fire protection system

CNSC staff determined that OPG continued to implement a comprehensive fire protection program at the DWMF in accordance with CSA Group standard N393-13, Fire protection for facilities that process, handle, or store nuclear substances.

##### Component design

CNSC staff concluded that OPG continued to meet the applicable regulatory requirements regarding component design for the DNGS and DWMF.

###### Darlington Nuclear Generating Station

CNSC staff concluded that OPG met the applicable regulatory requirements for component design at the DNGS.

Fuel design

CNSC staff determined that OPG had a mature reactor fuel inspection program. Fuel performance at the DNGS was acceptable in 2017. OPG’s defect rate and inspection findings were consistent with those of previous years. OPG was able to adequately manage fuel performance issues while maintaining safe operations.

Cables

In 2017, there were no issues found during compliance activities (i.e., desktop reviews). As a result, CNSC staff concluded that the cable management program at the DNGS met the applicable regulatory requirements.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

#### 3.1.6 Fitness for service

CNSC staff concluded that the fitness for service SCA at the Darlington site met the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received satisfactory ratings – unchanged from the previous year.

CNSC staff determined that OPG had established and maintained fitness-for-service programs to ensure the safe physical condition of the SSCs. The programs satisfied the applicable regulatory requirements and were effectively implemented at the DNGS and DWMF.

##### Equipment fitness for service and equipment performance
###### Darlington Nuclear Generating Station

CNSC staff determined that the overall equipment fitness for service and performance at the DNGS were satisfactory and met the applicable regulatory requirements.

Reliability of systems important to safety

CNSC staff determined that the reliability program at the DNGS met the applicable regulatory requirements in 2017. All special safety systems for DNGS Units 1 to 4 met their unavailability targets in 2017.

###### Darlington Waste Management Facility

This specific area does not apply to the DWMF.

##### Maintenance

CNSC staff determined that OPG’s maintenance program met the applicable regulatory requirements for the DNGS and DWMF in 2017. OPG’s maintenance program for NPPs also governs preventive and corrective maintenance activities for the WMFs.

###### Darlington Nuclear Generating Station

The average preventive maintenance completion rate for the four units at the DNGS was 94%, which compared favourably with the industry average (88%). The maintenance backlogs were acceptable and are shown in table 16 below.

Table 16: Trend of maintenance backlogs and deferrals for critical components for DNGS, 2015 to 2017
Parameter Average quarterly work orders per unit Three-year trend Industry average
2015 2016 2017
Corrective maintenance backlog 5 6 1 Down 4
Deficient maintenance backlog 75 48 37 Down 94
Deferrals of preventive maintenance 9 22 7 Stable 30

The corrective maintenance backlog, deficient maintenance backlog and number of deferrals of critical component preventive maintenance were all below the industry average and were being continuously reduced. CNSC staff determined that the overall safety significance of maintenance backlogs and deferrals for critical components was negligible for the DNGS.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

##### Structural integrity

CNSC staff concluded that the SSCs important for safe operation continued to meet the applicable structural integrity requirements established in the design basis or in CNSC‑accepted standards and guidelines for the DNGS and DWMF in 2017.

###### Darlington Nuclear Generating Station

As part of its periodic inspection program, OPG inspected the pressure boundary of Unit 1 and the containment components of Units 0, 3 and 4 in 2017. The pressure boundary inspections covered elements of the primary heat transport and auxiliary systems, feeders and pressure tubes. CNSC staff reviewed OPG’s inspection reports and were satisfied with the results, which indicated that all inspected elements met the CSA Group’s acceptance criteria.

###### Darlington Waste Management Facility

In October 2016, OPG had reported to CNSC staff that a DSC had failed its initial leak test and it was subsequently repaired. CNSC staff reviewed OPG’s follow-up actions and concluded in 2017 that these results did not have any impact on nuclear safety and that the licensee responded appropriately.

##### Aging management

CNSC staff concluded that OPG’s integrated aging management program met the applicable regulatory requirements at the DNGS and DWMF in 2017. OPG completed its transition to compliance with CNSC REGDOC-2.6.3, Aging Management at the DNGS and DWMF in 2017.

###### Darlington Nuclear Generating Station

CNSC staff confirmed that the major component lifecycle management plans (LCMPs) exceeded the basic requirements and provided a comprehensive in-service inspection plan. For example, OPG’s fuel channel LCMP included specific mitigating strategies for cases where fitness-for-service assessments identify degradation mechanisms for which the acceptance criteria cannot be met to the end of the evaluation period.

CNSC staff determined that OPG had adequate programs in place to confirm that fuel channels were fit for service for near-term operation. OPG submitted engineering assessments of degradation mechanisms that spanned the near term and met all applicable CSA Group acceptance criteria. CNSC staff continued to monitor the implementation of the fuel channel life management project which is developing the analytical tools necessary to demonstrate the fitness for service of pressure tubes for continued operation. CNSC staff were satisfied with the progress(see section 2.6 for further details). Also, see appendix H for details on the current and predicted future fuel channel conditions and the corresponding validity of analytical models of pressure tube fracture toughness for fuel channels at the DNGS (and the other NPPs in Ontario).

###### Darlington Waste Management Facility

There were no significant observations to report for this specific area at the DWMF in 2017.

##### Chemistry control

CNSC staff determined that OPG’s chemistry control program met or exceeded the applicable regulatory requirements for the DNGS and DWMF in 2017.

###### Darlington Nuclear Generating Station

CNSC staff determined that the DNGS remained compliant with its chemistry specifications in 2017 (see section 2.6). Moreover, the DNGS did not experience any chemistry-related reportable events in 2017.

###### Darlington Waste Management Facility

In 2017, CNSC staff reviewed the DWMF quarterly reports and concluded that the facility had maintained acceptable performance relating to chemistry. There were no chemistry-related incidents at the DWMF in 2017.

##### Periodic inspections and testing
###### Darlington Nuclear Generating Station

CNSC staff determined that OPG had adequate and well-maintained periodic inspection programs at the DNGS for the pressure boundary and containment components important to safety.

CNSC staff monitored compliance with the applicable regulatory requirements for periodic inspection programs during 2017 and concluded that their implementation met the applicable regulatory requirements.

OPG was updating its periodic inspection plans to comply with the 2014 edition of CSA Group standard N285.4, Periodic inspection of CANDU nuclear power plant components. Full implementation of the updated program requirements was expected by July 2019. CNSC staff were satisfied with the progress in 2017.

###### Darlington Waste Management Facility

This specific area does not apply to the DWMF, because periodic inspection and testing requirements are addressed under the scope of aging management at this facility.

CNSC staff concluded that the radiation protection SCA at the Darlington site met the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “satisfactory” ratings – a change from “fully satisfactory” for the DNGS and unchanged for the DWMF from the previous year.

##### Application of ALARA

CNSC staff determined that OPG continued to implement an effective and well-documented program based on industry best practices to keep doses to persons as low as reasonably achievable (ALARA) at the DNGS and DWMF. In 2017, CNSC staff verified that OPG used ALARA initiatives, work planning, and dose monitoring and control to work toward the challenging ALARA targets established by OPG at the DNGS and DWMF.

###### Darlington Nuclear Generating Station

In 2017, OPG approved a five-year ALARA plan for the DNGS that incorporated lessons learned and OPEX to develop challenging dose targets for the future with the goal of reducing worker doses. CNSC staff concluded that the application of the ALARA principle at the DNGS met or exceeded regulatory requirements and that safety was not compromised.

###### Darlington Waste Management Facility

CNSC staff verified, in 2017, that radiation exposures and doses to workers at the DWMF were below the regulatory dose limits and remained ALARA.

##### Worker dose control

CNSC staff determined that OPG continued to comply with the applicable regulatory requirements to measure and record doses received by workers at the DNGS and DWMF.

CNSC staff continued to pay close attention and exercise additional vigilance with respect to worker dose control during Darlington’s refurbishment activities. The CNSC put additional oversight in place, including enhanced surveillance and inspections.

Routine compliance verification activities conducted in 2017 confirmed that performance in the area of worker dose control at the DNGS and DWMF was effective. Radiation doses to workers at the DNGS and DWMF were below the regulatory dose limits  and the action levels established in OPG’s radiation protection program. CNSC staff observed that no adverse trends or safety-significant unplanned exposures resulted from the licensed activities at the DNGS and DWMF in 2017.

The data for doses to workers at the Darlington site are provided in section 2.7.

###### Darlington Nuclear Generating Station

The maximum individual dose received at the Darlington site was 18.94 mSv, which was received by a contractor performing bulkhead isolation, feeder cabinet removal and feeder coupling disconnection as part of the Unit 2 refurbishment. CNSC staff were satisfied that the dose to this worker was managed according to OPG processes and was well below the annual dose limit of 50 mSv.

In 2017, CNSC staff identified two low significance points of non-compliance. One of them was with respect to OPG’s adequate demonstration that the exposure control level increases for Unit 2 refurbishment workers were being maintained ALARA. The other point of non-compliance was observed in worker compliance with program requirements for non-routine bioassay submissions. CNSC staff were satisfied with OPG’s corrective action plans for the points of non-compliance and will continue to monitor the implementation in 2018.

###### Darlington Waste Management Facility

The maximum dose received by a worker in 2017 at the DWMF was 0.80 mSv, which was approximately 1.6% of the regulatory dose limit.

OPG regularly measures the performance of its corporate radiation protection program against industry-established objectives, goals, and targets. CNSC staff determined that the program, which covers the DNGS and DWMF, met the requirements of the Radiation Protection Regulations. OPG’s oversight in implementing and improving this program was effective in protecting workers at the DNGS and DWMF.

###### Darlington Nuclear Generating Station

In 2017, the DNGS implemented changes to the radiation protection program that dealt with improvements to the selection and use of personal protective equipment, the use of portable instruments to measure radiation and the unconditional transfer of materials from radiological zones. CNSC staff noted that the change to the material transfer procedures stemmed from a loss-of-contamination-control event at the DNGS (see description under the radiological hazard control specific area and table 15). The DNGS implemented enhancements to the radiation protection program to prevent the recurrence of similar events.

###### Darlington Waste Management Facility

OPG’s action levels for the WMFs were revised in 2017 to ensure they were appropriate indicators of the possible loss of control of an element of OPG’s radiation protection program at the DWMF. CNSC staff reviewed the revised action levels and found them to be appropriate.

CNSC staff determined that OPG implemented radiological hazard controls that met the applicable regulatory requirements. These measures protected workers and ensured that radioactive contamination was controlled within site boundaries for the DNGS and DWMF.

Contamination control action levels for surface contamination were not exceeded as a result of licensed activities at the DNGS and DWMF in 2017.

CNSC staff confirmed that no safety-significant incidents were identified through OPG’s reporting of safety performance indicators on personnel and loose contamination events.

In 2017, OPG revised its contamination control action levels for the Darlington site to ensure they were appropriate indicators of a failure of the radiation protection program. CNSC staff reviewed the revised action levels and found them to be appropriate.

###### Darlington Nuclear Generating Station

In 2017, CNSC staff identified non-compliances with radiation hazard labelling requirements, with contamination control during the execution of outage work and with review and verification of radiological survey results. CNSC staff determined that the adverse conditions identified did not pose unreasonable risks to workers or the environment and that OPG implemented suitable corrective action plans. CNSC staff were monitoring OPG’s progress in implementing suitable corrective actions to effectively address non-compliance related to supervisory review and verification of radiological survey results.

In February 2017, an event occurred where four electrical motors with undetected internal contamination were shipped from the DNGS to an unlicensed facility for repair. All four motors had been surveyed for contamination at the DNGS and approved for unconditional transfer prior to shipping. Following the detection of contamination at the repair facility, all four motors and contaminated materials were packaged and shipped back to the DNGS by qualified shippers, in accordance with OPG procedures and with the Packaging and Transport of Nuclear Substances Regulations, 2015. This incident was reported to the Commission in March 2017 as an EIR References 12. There were no safety consequences as a result of the incident. OPG took the necessary measures to prevent a reoccurrence of a similar incident.

###### Darlington Waste Management Facility

CNSC staff inspected the DWMF in November 2017 and issued two non-compliance actions in the area of radiation protection whereby OPG was to review the routine survey locations and perform an extent-of-condition review of the results of worker radiation monitoring.

UPDATE: CNSC staff were reviewing the corrective actions, and they were satisfied with OPG’s progress to date.

##### Estimated dose to the public

CNSC staff determined that OPG continued to ensure the protection of the general public in accordance with the Radiation Protection Regulations. The reported estimated dose to a member of the general public from the Darlington site was 0.0007 mSv, well below the annual dose limit of 1 mSv. See section 2.7 for details.

#### 3.1.8 Conventional health and safety

CNSC staff concluded that the conventional health and safety SCA at the Darlington site met or exceeded the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “fully satisfactory” ratings – an improvement over the previous year.

##### Performance

CNSC staff determined that OPG met or exceeded requirements at the DNGS and DWMF for conventional health and safety performance.

OPG continued to demonstrate its ability to keep workers safe from occupational injuries while conducting its licensed activities at the DNGS and DWMF.

CNSC staff conducted inspections at the DNGS and DWMF and recorded their findings on safety practices and the controls employed by OPG to address conventional hazards. CNSC staff did not identify any areas of concern regarding conventional health and safety in 2017.

###### Darlington Nuclear Generating Station

CNSC staff observed that the accident severity rate (ASR) for the DNGS increased from 0.7 in 2016 to 2.23 in 2017, while the accident frequency (AF) rate increased slightly from 0.22 in 2016 to 0.28 in 2017 (see figures 11 and 12 in section 2.8). Both indicators were similar to the industry average. In 2017, OPG reported one lost-time injury (LTI). CNSC staff found that the ASR and AF safety performance indicators at the DNGS were acceptable.

OPG reported health and safety related incidents on an ongoing basis. CNSC staff reviewed OPG’s actions and concluded that the actions were appropriate.

###### Darlington Waste Management Facility

No health and safety related incidents or LTIs were reported by OPG to CNSC staff for the DWMF in 2017.

CNSC staff participated in pre-inspection health and safety briefings with OPG staff and management while onsite for inspections. CNSC staff found that the health and safety briefings were satisfactory.

##### Practices

CNSC staff determined that the conventional health and safety practices met or exceeded the applicable regulatory requirements at the DNGS and DWMF in 2017.

The conventional health and safety work practices and conditions at the DNGS and DWMF continued to achieve a high degree of personnel safety. OPG personnel at all levels exhibited proactive attitudes toward anticipating work-related hazards and preventing unsafe conditions. There continued to be a working environment where safe work practices were encouraged. CNSC staff verified that OPG had appropriate procedures at the DNGS and DWMF to ensure that the environment and the health of persons are protected against hazardous materials.

###### Darlington Nuclear Generating Station

As a result of regulatory oversight in 2017, CNSC staff were satisfied with OPG’s performance for this specific area.

###### Darlington Waste Management Facility

CNSC staff observed safe work practices during inspections at the DWMF. A positive indicator in this regard was the use of the job hazard analysis program which specifies OPG’s commitment to conducting pre-inspection tours of jobs and job sites, listing emergency procedures for such jobs, identifying the minimum level of personal protective equipment required and listing the required permits or work authorizations before starting work.

##### Awareness

CNSC staff concluded that OPG met or exceeded the applicable regulatory requirements for awareness in 2017 at the DNGS and DWMF. CNSC staff determined that OPG continued to maintain a safe working environment at the DNGS and DWMF.

###### Darlington Nuclear Generating Station

Throughout 2017, CNSC staff observed the cleanliness and tidiness of the DNGS, although in some instances, equipment and transient material were improperly stored, which OPG addressed.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

#### 3.1.9 Environmental protection

CNSC staff concluded the Environmental protection SCA at the Darlington site met the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “satisfactory” ratings, unchanged from the previous year.

##### Effluent and emissions control (releases)

CNSC staff reviewed all reported airborne and waterborne radiological releases from the Darlington site and confirmed that they remained below the regulatory limits and action levels. The releases for the DNGS and DWMF are shown in figure 15 as fractions of the applicable derived release limits (DRLs). The actual values for the releases and DRLs for the Darlington site are shown in appendix I.

In 2017, OPG fully implemented CSA Group standard N288.3.4-13, Performance testing of nuclear air-cleaning systems at nuclear facilities for the DNGS and DWMF.

##### Environmental management system

CNSC staff concluded that OPG had established and implemented a corporate-wide environmental management system (EMS) in accordance with CNSC REGDOC- 2.9.1, Environmental Protection: Environmental Protection Policies, Programs and Procedures (2013) to assess the environmental risks associated with its nuclear activities at the DNGS and DWMF, and to ensure that these activities are conducted in a way that prevents or mitigates adverse environmental effects. The EMS was also registered to ISO standard 14001:2015, Environmental management systems – Requirements with guidance for use References 8. Because it is registered, the EMS is subject to periodic, independent, third-party audits and reviews to verify its sufficiency and to identify potential improvements.

##### Assessment and monitoring

CNSC staff reviewed and assessed the environmental monitoring data provided by OPG for the Darlington site and concluded that the general public and the environment in the vicinity of the site were protected. OPG met the applicable regulatory requirements for the DNGS and DWMF.

CNSC staff conducted independent environmental monitoring around the Darlington site in 2017; see section 2.9 for a description of the Independent Environmental Monitoring Program (IEMP). The results are available on the CNSC’s IEMP web page. The IEMP results indicate that the general public and the environment in the vicinity of Darlington site were protected and that there were no expected health impacts.

OPG has a transition plan in place to implement the requirements of CSA Group standard N288.7-15, Groundwater protection programs at Class I nuclear facilities and uranium mines and mills at the DNGS and DWMF by December 31, 2020. CNSC staff found the implementation date to be acceptable.

##### Protection of the public

CNSC staff confirmed that the general public in the vicinity of the Darlington site was protected and that there were no expected health impacts. No reported releases of hazardous substances from the Darlington site exceeded regulatory limits in 2017.

The dose to the public is discussed in section 3.1.7.

##### Environmental risk assessment

CNSC staff determined that OPG continued to implement and maintain an effective environmental risk assessment and management program at the Darlington site in accordance with the applicable regulatory requirements.

In 2017, CNSC staff reviewed the 2016 Darlington nuclear environmental risk assessment (ERA) which covered the DNGS and DWMF. CNSC staff determined that OPG had taken adequate measures to protect human health and the environment, and that the ERA complied with CSA Group standard N288.6, Environmental risk assessments at Class I nuclear facilities and uranium mines and mills.

#### 3.1.10 Emergency management and fire protection

CNSC staff concluded that the emergency management and fire protection SCA at the Darlington site met the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “satisfactory” ratings – unchanged from the previous year.

CNSC staff determined that OPG continued to maintain comprehensive conventional, nuclear and fire emergency response capabilities that met the applicable regulatory requirements at all times for the Darlington site. This included personnel and equipment for medical situations and events involving hazardous material (HAZMAT), search and rescue, and fire response.

The DNGS emergency response team (ERT) responds to events within the DNGS protected area at all times. The DNGS ERT provides off-hours investigation services and responds to fire alarms within the DWMF protected area.

OPG has a written agreement with the Municipality of Clarington to provide emergency response services with support from site personnel, within the Darlington site boundary but outside the DNGS protected area for fire, medical, rescue and HAZMAT events. Site support can include operations, security staff and ERT personnel.

##### Conventional emergency preparedness and response

CNSC staff had no significant observations at the DNGS or the DWMF to report in this specific area for 2017.

##### Nuclear emergency preparedness and response

OPG continued to support offsite emergency management organizations and commitments throughout 2017.

OPG’s nuclear emergency preparedness program is documented in the Consolidated Nuclear Emergency Plan (CNEP) which governs the Darlington site.

Training and exercises are conducted annually at the Darlington site to ensure all areas of the site have adequate emergency notification or response capability from either the ERT or the Municipality of Clarington emergency services.

###### Darlington Nuclear Generating Station

OPG implemented version 1 of CNSC REGDOC-2.10.1, Nuclear Emergency Preparedness and Response (2014) at the DNGS by September 2017.

In 2017, OPG completed the implementation of a real-time automatic data transfer system for the DNGS which promptly provides staff in the CNSC’s Emergency Operations Centre with plant information during nuclear emergencies.

In September 2017, CNSC staff inspected an emergency response exercise at the DNGS. The inspection identified one point of non-compliance of low safety significance related to ensuring that survey results were transmitted to external stakeholders required. CNSC staff were satisfied with OPG’s corrective action plan. OPG planned to provide updates on the implementation to CNSC staff in November 2018.

###### Darlington Waste Management Facility

The DWMF has a facility emergency program that includes radiation response emergency procedures. OPG also incorporates the CNEP as part of its onsite requirements for nuclear response.

OPG currently has a transition plan for implementing the requirements of CNSC REGDOC‑2.10.1, Nuclear Emergency Preparedness and Response, version 2 (2016) at the DWMF by December 31, 2018. CNSC staff found this implementation date to be acceptable.

##### Fire emergency preparedness and response

The DNGS has an extensive fire drill and training program that includes the Wesleyville Fire Training Academy located near Wesleyville, Ontario, where live fire training is conducted for Darlington ERT and with the Clarington Municipal Fire Department.

###### Darlington Nuclear Generating Station

In 2017, CNSC staff conducted several inspections at the DNGS to verify compliance with the fire protection program. CNSC staff observed a number of points of non-compliance of low safety significance in the areas of radioactive material storage, ignition source permits and space allocation for transient combustible material. CNSC staff were satisfied with OPG’s corrective action plan and will monitor its implementation, targeted for April 2018.

In addition to CNSC compliance activities, the DNGS is required to conduct expert third-party reviews (TPRs) which include an annual plant condition inspection, bi-annual fire drill audit and tri-annual fire program audit.

By incorporating the results of the CNSC compliance findings and TPR observations and recommendations into the drill and training program, the ERT’s performance continued to improve.

###### Darlington Waste Management Facility

OPG has a facility emergency program at the DWMF that includes basic fire response so that facility staff can respond to small fires with fire extinguishers.

On February 23, 2017, OPG reported to CNSC staff an event that occurred at the DWMF involving a programmatic failure to inspect the exit signs at the facility. OPG stated that no immediate effects or impacts on the environment, health and safety of persons or maintenance of security resulted, or may have resulted, from the situation. CNSC staff were satisfied with the measures taken by OPG and subsequently closed the event.

On April 4, 2017, OPG reported to CNSC staff an event that occurred at the DWMF involving a loss of fire water during routine maintenance of the fire suppression system. OPG stated that no immediate effects or impacts on the environment, health and safety of persons or the maintenance of security resulted, or may have resulted, from the situation. CNSC staff were satisfied with the corrective measures taken by OPG, and subsequently closed the event.

#### 3.1.11 Waste management

CNSC staff concluded that the waste management SCA at the Darlington site met or exceeded the performance objectives and applicable regulatory requirements. As a result, the DNGS received a “fully satisfactory” rating and DWMF received a “satisfactory” rating – unchanged from the previous year.

##### Waste characterization

CNSC staff determined that OPG’s waste characterization met or exceeded the applicable regulatory requirements at the DNGS and DWMF. OPG continued to employ effective programs for the characterization of radioactive and hazardous wastes at the DNGS and DWMF in 2017. CNSC staff had no significant observations at the DNGS or the DWMF to report in this specific area in 2017.

##### Waste minimization

CNSC staff determined that OPG’s waste management programs for minimizing radioactive waste met or exceeded the applicable regulatory requirements at the DNGS and DWMF.

###### Darlington Nuclear Generating Station

As a result of regulatory oversight, CNSC staff were satisfied with OPG’s performance for this specific area.

###### Darlington Waste Management Facility

Minimal radioactive waste is generated from the waste management activities conducted at the DWMF. Nonetheless, OPG has a goal to minimize the generation of radioactive waste due to operational activities. Annual volumes amount to less than one drum that is sent to the DNGS for segregation, as necessary, and eventually transported to the WWMF for processing and storage.

##### Waste management practices

CNSC staff determined that OPG’s waste management practices met or exceeded the applicable regulatory requirements at the DNGS and DWMF. OPG continued to employ effective radioactive and hazardous waste management practices at the Darlington site in 2017. OPG used waste management procedures to ensure that waste generated at the facility was separated properly.

###### Darlington Waste Management Facility

As of October 31, 2017, OPG was fully compliant with the requirements of CSA Group standards N292.0-14, General principles for the management of radioactive waste and irradiated fuel, N292.2-13, Interim dry storage of irradiated fuel and N292.3-14, Management of low- and intermediate-level radioactive waste for the DWMF.

##### Decommissioning plans

The preliminary decommissioning plans (PDPs) for the DNGS and DWMF met or exceeded the applicable regulatory requirements in 2017.

In 2017, OPG revised the PDPs for all of its facilities for the period ending in 2022. OPG selected a deferred decommissioning strategy for the DNGS and an immediate decommissioning strategy for the DWMF, following the completion of the DNGS decommissioning. The associated financial guarantee is discussed in section 2.15.

#### 3.1.12 Security

CNSC staff concluded that the security SCA at the Darlington site met the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “satisfactory” ratings – unchanged from the previous year.

##### Facilities and equipment

CNSC staff determined that OPG met the applicable regulatory requirements for facilities and equipment at the DNGS and DWMF. OPG continued to sustain its security equipment through lifecycle management at the Darlington site. No significant equipment failures were reported in 2017. OPG had processes in place to adequately prevent security events at the DNGS and DWMF.

###### Darlington Nuclear Generating Station

OPG made improvements to the DNGS preventive maintenance program in 2017 to ensure that adequately trained personnel were available in order to effectively maintain security equipment.

Cyber security

OPG maintains a cyber security program at the DNGS. CNSC staff concluded that the program complied with the applicable regulatory requirements. No cyber security events were reported in 2017.

OPG was updating its cyber security program for the DNGS to achieve compliance with CSA Group standard N290.7-14, Cyber security for nuclear power plants and small reactor facilities by November 30, 2019. CNSC staff were satisfied with the progress.

###### Darlington Waste Management Facility

OPG had physical protection systems and a security program in place at the DWMF that were appropriate for a high-security nuclear facility.

CNSC staff inspected security at the DWMF in 2017 and issued one low-risk compliance action to OPG. CNSC staff were satisfied with the resulting corrective actions and considered the inspection to be closed.

CNSC staff confirmed that the DWMF updated its security operating procedures and ensured that its contingency plans continued to meet the design basis threat, as approved by CNSC.

##### Response arrangements

CNSC staff determined that OPG met the applicable regulatory requirements for response arrangements at the DNGS and DWMF.

###### Darlington Nuclear Generating Station

OPG has nuclear security officers to respond to security incidents and perform routine patrols at the DNGS.

A CNSC staff inspection concluded that elements of the response force did not meet all the performance objectives outlined in OPG’s exercise manual. Several findings of low significance were made where some individuals faced challenges using their training, and subsequently, decision-making. OPG was working toward implementing suitable corrective measures to effectively address the outstanding items.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

##### Security practices

CNSC staff determined that OPG implemented security practices at the DNGS and DWMF that met the applicable regulatory requirements.

OPG has procedures in place at the DNGS and DWMF to guide plant and security personnel in security practices.

###### Darlington Nuclear Generating Station

In 2017, this area was affected by reportable events related to non-adherence to security procedures. There were some challenges in the area of security awareness. However, CNSC staff concluded that there were no safety-significant issues for this specific area and that OPG was implementing appropriate corrective actions.

OPG submitted a detailed implementation plan to meet the new requirements for security screening which CNSC staff assessed as acceptable.

###### Darlington Waste Management Facility

CNSC staff had no significant observations at the DWMF to report in this specific area for 2017.

##### Drills and exercises

CNSC staff determined that OPG’s exercise and drill program met the applicable regulatory requirements for the DNGS and DWMF. CNSC staff had no significant observations at the DNGS or the DWMF to report in this specific area for 2017.

#### 3.1.13 Safeguards and non-proliferation

CNSC staff concluded that the safeguards and non-proliferation SCA at the Darlington site met the performance objectives and all applicable regulatory requirements. As a result, the DNGS and DWMF received “satisfactory” ratings – unchanged from the previous year.

##### Nuclear material accountancy and control

CNSC staff confirmed that OPG’s accountancy and control of nuclear material at the DNGS and DWMF complied with the applicable regulatory requirements in 2017.

##### Access and assistance to the IAEA

CNSC staff verified that OPG met the applicable regulatory requirements for access and assistance at the DNGS and DWMF. OPG granted adequate access and assistance to the International Atomic Energy Agency (IAEA) for safeguards activities, including inspections and equipment maintenance at the DNGS and DWMF, pursuant to the Canada/IAEA safeguards agreements and the conditions of the facilities’ licences.

###### Darlington Nuclear Generating Station

The IAEA did not perform physical inventory verification at the DNGS in 2017. CNSC staff performed an evaluation of preparedness at the DNGS for an IAEA physical inventory verification. CNSC staff concluded that the DNGS was adequately prepared for an IAEA physical inventory verification, had one been selected.

In 2017, the IAEA performed one short-notice, random inspection and three unannounced inspections at the DNGS to verify the nuclear material inventory and ensure there were no undeclared nuclear material or activities.

OPG granted access and provided assistance to the IAEA in October 2017 for a site survey to identify potential locations for additional IAEA surveillance equipment in the spent fuel bay area, with the goal of optimizing the current safeguards approach at that facility.

###### Darlington Waste Management Facility

In 2017, the IAEA performed four unannounced inspections at the DWMF to verify the nuclear material inventory and ensure there were no undeclared nuclear material or activities. OPG provided access and support for these inspections, and the IAEA informed the CNSC that the inspection results were satisfactory.

The IAEA did not perform a physical inventory verification at the DWMF in 2017. CNSC staff performed an evaluation of OPG’s preparedness for a physical inventory verification at the DWMF. CNSC staff concluded that OPG was adequately prepared for an IAEA physical inventory verification at the DWMF in 2017, had one been selected.

CNSC staff confirmed that OPG met the applicable regulatory requirements for operational and design information for the DNGS and DWMF.

OPG submitted its annual operational program with quarterly updates for the DNGS and DWMF to the CNSC on time. OPG also submitted the annual updates to the information pursuant to the IAEA Additional Protocol to the CNSC on time. CNSC staff were satisfied with the information provided and concluded that it met the CNSC’s submission requirements.

##### Safeguards equipment, containment and surveillance

CNSC staff confirmed that OPG met the applicable regulatory requirements for safeguards equipment, containment and surveillance for the DNGS and DWMF. OPG supported IAEA equipment operation and maintenance activities at the Darlington site, including routine maintenance of surveillance equipment, to ensure the effective implementation of safeguards measures at the DNGS and DWMF.

#### 3.1.14 Packaging and transport

CNSC staff concluded that the packaging and transport SCA at the Darlington site met the performance objectives and applicable regulatory requirements. As a result, the DNGS and DWMF received “satisfactory” ratings, unchanged from the previous year.

##### Package design and maintenance, packaging and transport, and registration for use

CNSC staff determined that OPG has a packaging and transport program for the DNGS and DWMF that ensures compliance with the Packaging and Transport of Nuclear Substances Regulations, 2015 and the Transportation of Dangerous Goods Regulations.

There were no packaging and transport events reported in 2017.

OPG ensured an equivalent level of safety for the onsite movement of nuclear substances as for offsite transportation to protect the health and safety of workers, the public and the environment.

CNSC staff had no significant observations at the DNGS or the DWMF to report in this specific area for 2017.

#### 3.1.15 Other matters of regulatory Interest

##### Public information program

OPG continued regular communications about the Darlington site to engage and inform residents and stakeholders about the facility, and in particular, about the progress of the refurbishment project.

CNSC staff determined that OPG met the applicable regulatory requirements related to public information and disclosure and provided sufficient information on the status of the Darlington site through a variety of communication activities, including participation in community events, facility tours, ongoing website updates and the use of social media.

##### Indigenous relations

CNSC staff observed that OPG had a dedicated Indigenous engagement program. Throughout 2017, it met and shared information with interested Indigenous communities and organizations, particularly the Williams Treaties First Nations, the Mohawks of the Bay of Quinte and the Métis Nation of Ontario.

Information and discussion topics included OPG’s current operations at the DNGS and the progress of refurbishment activities, the DWMF, environmental protection and performance, monitoring program results and participation, and fish impingement and entrainment.

### 3.2 Pickering site

The safety assessment presented below for each SCA is facility-specific. General information relevant to the SCAs is provided in section 2. The CNSC regulatory documents and CSA Group standards that were identified as regulatory requirements for the Pickering site, as of December 2017, are listed in appendix E.

Overall safety assessment

The Pickering site consists of the Pickering Nuclear Generating Station (PNGS) and the Pickering Waste Management Facility (PWMF). The CNSC staff safety assessment of the Pickering site for 2017 led to the performance ratings shown in table 17. Based on the observations and assessments of the SCAs, CNSC staff concluded that both the PNGS and PWMF operated safely. The overall rating for the PNGS was “fully satisfactory” – unchanged from the integrated plant rating for 2016. The overall rating for the PWMF was “satisfactory” – unchanged from 2016.

Table 17: Performance ratings for the Pickering site, 2017
Safety and control area PNGS rating PWMF rating
Management system SA SA
Human performance management SA SA
Operating performance FS FS
Safety analysis FS FS
Physical design SA SA
Fitness for service SA SA
Conventional health and safety FS FS
Environmental protection SA SA
Emergency management and fire protection SA SA
Waste management FS SA
Security SA SA
Safeguards and non-proliferation SA SA
Packaging and transport SA SA
Overall rating FS SA

Legend:

• FS – Fully Satisfactory
• SA – Satisfactory
• BE – Below Expectations
• UA – Unacceptable

#### 3.2.0 Introduction

The Pickering site is located on the north shore of Lake Ontario in Pickering, Ontario, 32 kilometres northeast of Toronto and 21 kilometres southwest of Oshawa. The CNSC regulates the PNGS and  PWMF under two separate, independent licences – a power reactor operating licence (PROL) for the PNGS and a waste facility operating licence (WFOL) for the PWMF. The facilities are owned and operated by OPG.

##### Pickering Nuclear Generating Station

The PNGS consists of eight CANDU reactors. Units 1, 2, 3 and 4 went into service in 1971. Units 2 and 3 were defueled in 2008 and remain in a safe shutdown state; there are no plans to put them back into operation. Units 5, 6, 7 and 8 at the PNGS continue to operate safely ever since they were brought into service in 1983.

Each operating reactor for Units 1 and 4 has a gross electrical output of 542 MWe (megawatts electrical). Each operating reactor in Units 5–8 has a gross electrical output of 540 MWe.

In 2010, OPG announced that the PNGS would continue operations until its shutdown in 2020. In January 2016, the province of Ontario asked OPG to plan for continued operations beyond 2020. In 2017, OPG applied for a CNSC licence to continue commercial operations until December 2024.

##### Pickering Waste Management Facility

At the PWMF, OPG processes and stores DSCs containing used nuclear fuel (high-level radioactive waste) generated solely at the PNGS. OPG also manages the intermediate-level radioactive waste generated from the refurbishment of PNGS Units 1–4 (formerly known as PNGS A) in 34 above-ground dry storage modules (DSMs) located in the Retube Component Storage Area (RCSA) of the PWMF. The RCSA is closed to receiving any new intermediate-level radioactive waste.

The PWMF covers two separate areas, Phase I and Phase II, within the overall boundary of the Pickering site. Phase I is located within the protected area of the PNGS and consists of one DSC processing building, two DSC storage buildings (Storage Buildings 1 and 2) and the RCSA. Phase II of the PWMF is located northeast of Phase I and is contained within its own protected area, separate from the protected area of the PNGS but within the boundary of the Pickering site. Phase II contains Storage Building 3. The PWMF has the capacity to store 1,156 DSCs. The transfer of loaded DSCs from PWMF Phase I to PWMF Phase II is conducted on OPG property with a security escort.

OPG is authorized under the WFOL for the PWMF to construct three additional DSC storage buildings in Phase II – Storage Buildings 4, 5 and 6 – and one DSC processing building to replace the current one. The additional storage buildings would allow OPG to store all of the used fuel generated at the PNGS until the proposed end of its commercial operational life (2024), and the new DSC processing building would nearly double OPG’s processing capabilities at the PWMF, from 50 DSCs per year to approximately 100 DSCs per year.

##### Licensing
###### Pickering Nuclear Generating Station

The PROL was set to expire on August 31, 2018. In August 2017, OPG submitted a licence application to the CNSC requesting the renewal of its PROL References 14 for a period of 10 years, which would include the end of commercial operation on December 31, 2024. That licence period would cover three phases of operational activities: continued commercial operation until December 31, 2024, a stabilization phase (post-shutdown defueling and dewatering) lasting approximately three to four years, and the beginning of safe storage for Units 1, 4 and 5 to 8.

UPDATE: Part I of the public hearing was held on April 4, 2018. Part II of the public hearing was held from June 25 to 29, 2018. In August, the Commission announced its decision to renew OPG’s licence for the PNGS, effective September 1, 2018, until August 31, 2028.

In a separate request in April 2017, OPG requested that the Commission amend the PROL to allow the import and export of nuclear substances occurring primarily as contaminants in laundry, packaging, shielding or equipment. These activities had been authorized under a temporary possession licence (TPL). CNSC staff determined that there were no safety impacts associated with the proposed licence amendment and that it would not change the scope of the import and export activities already authorized under the TPL References 15. On October 26, 2017, the Commission amended Part IV of the PROL to include the import and export of nuclear substances licensed activity.

###### Pickering Waste Management Facility

In October 2016, OPG submitted a request to the CNSC to have the PWMF’s licence renewed References 16 for a period of approximately 11 years, until August 31, 2028. A public hearing for the licence renewal was held in Ottawa on April 13, 2017.

UPDATE: On April 1, 2018, the Commission issued the renewed WFOL for the period from April 1, 2018 to August 31, 2028.

##### Licence conditions handbook
###### Pickering Nuclear Generating Station

In 2017, one revision was made to the licence conditions handbook (LCH) to incorporate details about the PROL amendment authorizing the import and export of contaminated laundry. This revision also included other administrative and technical changes (see appendix F).

CNSC staff drafted a new LCH in conjunction with the PROL renewal.

###### Pickering Waste Management Facility

The WFOL for the PWMF did not have an accompanying LCH in 2017.

UPDATE: CNSC staff issued an LCH associated with the PWMF licence in June 2018 in conjunction with its WFOL renewal.

##### Fisheries Act authorization
###### Pickering Nuclear Generating Station

In May 2015, OPG had an episodic fish impingement event at the PNGS that impinged on an estimated biomass of between 5,410 and 6,428 kg. Fisheries and Oceans Canada conducted an investigation and issued a letter to OPG which included a requirement that OPG submit an application for authorization under paragraph 35(2)(b) of the Fisheries Act.

In July 2017, OPG submitted its application to Fisheries and Oceans Canada. Following Fisheries and Oceans Canada’s review of the application, OPG submitted a revised application in December 2017.

UPDATE: On January 11, 2018, Fisheries and Oceans issued the authorization, valid until December 2028.

The authorization also required OPG to annually install a fish diversion system (FDS) barrier net by May 1, and keep it in place and functioning until November 1 in order to prevent and mitigate serious harm to fish. However, because Fisheries and Oceans Canada determined that serious harm to fish was likely, even after installing the FDS, the authorization also required OPG to offset the residual impacts with the following compensatory measures:

• Big Island wetland habitat creation project (approximately 7.6 ha drawn from the existing Big Island Wetland complex habitat bank)
• Simcoe Point wetland habitat creation project (rehabilitation of Simcoe Point to create a 4.6 ha coastal wetland)
• Stocking contribution for Lake Ontario Atlantic Salmon Program (stocking of approximately 1,500 kg of age-one equivalent Atlantic salmon in Duffins Creek)
##### Periodic safety review

CNSC asked OPG to conduct a periodic safety review (PSR) to ensure that the PNGS’s operation, condition and programs conform, to the extent practicable, to modern codes and standards, and that arrangements exist to enhance the continued safe operation of the NPP.

OPG performed the PSR in accordance with CNSC REGDOC-2.3.3, Periodic Safety Reviews. In conducting the PSR, OPG built on the results of several earlier safety reviews, such as the work performed in support of the return to service of Units 1 and 4, the 2009 integrated safety review (ISR) conducted for PNGS B, and the ISR for Darlington which was completed in 2015. The PSR findings were being addressed with safety enhancement actions in an integrated implementation plan (IIP). CNSC staff included a licence condition in the proposed PROL requiring OPG to implement the IIP. The PSR covered operational and stabilization phases as well as the beginning of the safe storage phase. Adequate provisions were deemed to be in place to ensure the fitness for service of the safety significant systems required for each phase (including at the point of hand-over from permanent shutdown to the stabilization phase, and from the stabilization phase to the safe storage with surveillance phase).

##### Operational Safety Review Team Mission at PNGS

In 2016, an IAEA Operational Safety Assessment Review Team (OSART) mission was conducted to evaluate the PNGS’s operational safety performance against IAEA safety standards. OSART missions give IAEA member states an opportunity to share best practices and to support continuous improvements in their operations. The international, multi-disciplinary review team evaluated the following areas:

• leadership and management for safety
• training and qualifications
• operations
• maintenance
• technical support
• OPEX feedback
• chemistry
• emergency preparedness and response
• accident management
• human–technology and organization interactions
• long term operations
• transition to decommissioning

The OSART team concluded that management at the PNGS was committed to improving the operational safety and reliability of the NPP. The team identified eight good practices, 11 suggestions and 10 recommendations. The final OSART report is available on the CNSC website.

OPG developed improvement strategies and established action plans for all the suggestions and recommendations. All corrective actions to address safety-related findings were completed by the end of 2017, with the exception of the recommendations on managing alcohol and drug testing of key staff in safety-important roles. The recommendation to include alcohol and drug tests without cause as part of its existing fitness for duty program was being addressed through OPG’s implementation of CNSC REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use, which has requirements for random alcohol and drug testing. See section 3.2.2 for information on the implementation of REGDOC-2.2.4.

CNSC staff reviewed the OSART report and confirmed that in the areas linked to the suggestions and recommendations, the PNGS remained compliant with the applicable regulatory requirements. A follow-up mission by the IAEA was planned for 2018 to assess the progress of OPG’s actions to address the suggestions and recommendations.

##### Event initial reports

No event initial reports pertaining to the Pickering site were submitted to the Commission for the period from January 1, 2017 to June 1, 2018.

##### Compliance program

The CNSC’s annual compliance program effort is tabulated in appendices G.2 and G.8, respectively, for the PNGS and PWMF. The inspections at the Pickering site that were considered in the safety assessments in this regulatory oversight report are tabulated in appendix J.

#### 3.2.1 Management system

CNSC staff concluded that the management system SCA at the Pickering site fulfilled the performance objectives and met the applicable regulatory requirements. As a result, the PNGS and PWMF received “satisfactory” ratings – unchanged from the previous year.

##### Management system

CNSC staff determined that OPG’s nuclear management system at the Pickering site met the applicable regulatory requirements in 2017. OPG had completed the transition to the 2012 version of CSA Group standard N286-12, Management system requirements for nuclear facilities.

###### Pickering Nuclear Generating Station

As a result of regulatory oversight, CNSC staff were satisfied with OPG’s performance for this specific area.

###### Pickering Waste Management Facility

CNSC staff conducted a desktop review of OPG’s nuclear waste management documentation for the PWMF and determined that it met the applicable regulatory requirements. However, during a 2017 inspection at the DWMF, CNSC staff identified minor issues of low safety significance regarding the clarity and consistent application of documentation that were also applicable to the PWMF. OPG committed to applying its corrective action plan at the PWMF as well as at the DWMF. At the end of 2017, CNSC staff were monitoring the implementation of the corrective actions and confirming OPG’s implementation of the changes at the PWMF.

##### Organization

CNSC staff determined that OPG had adequately defined organizational structures, roles and responsibilities at the Pickering site.

###### Pickering Nuclear Generating Station

In 2017, CNSC staff inspected the implementation of OPG’s organization, roles and responsibilities and the interfaces for the PNGS and DNGS. CNSC staff identified points of non-compliance of low safety significance with respect to identifying all program interfaces and defining roles and accountabilities. At the end of 2017, CNSC staff were reviewing OPG’s corrective action plan and will continue to monitor OPG’s implementation activities.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

##### Change management

CNSC staff determined that OPG had an adequate change management program at the Pickering site that complied with the applicable regulatory requirements.

###### Pickering Nuclear Generating Station

As a result of regulatory oversight, CNSC staff were satisfied with OPG’s performance for this specific area. There were no significant observations to report for 2017.

###### Pickering Waste Management Facility

As a result of the 2017 inspection at the DWMF, CNSC staff determined that OPG’s change management process was ineffective for the inspection of DSCs and for other generic documentation that was used by all OPG WMFs. OPG implemented a change management committee to manage governance and process changes for nuclear waste at all of its WMFs. OPG committed to applying the corrective action plan at PWMF with respect to change management. At the end of 2017, CNSC staff were monitoring the implementation of the corrective actions and overseeing the implementation of OPG’s changes at the PWMF.

##### Safety culture

CNSC staff were satisfied that OPG continued to foster a healthy safety culture at the Pickering site in 2017. CNSC will monitor OPG’s next safety culture self-assessment at the Pickering site, scheduled for 2018, and any improvement actions initiated.

##### Configuration management

CNSC staff determined that OPG maintained the configuration of its structures, systems and components (SSCs) at the Pickering site in compliance with its configuration management program and other applicable regulatory requirements.

###### Pickering Nuclear Generating Station

In 2016, CNSC staff inspected configuration management and identified points of non-compliance of low safety significance with OPG’s internal governance related to the documentation of temporary configuration changes at the PNGS. CNSC staff were satisfied with OPGs proposed corrective action plan and were monitoring OPGs implementation of the corrective actions at the PNGS, slated for completion by May 2019.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

##### Records management

CNSC staff determined that OPG continued to maintain and implement a document control and records management system at the Pickering site that complied with the applicable regulatory requirements.

###### Pickering Nuclear Generating Station

In 2017, CNSC staff inspected the training of personnel involved in contract management and identified deficiencies of low safety significance in the area of records management at the PNGS.

UPDATE: CNSC staff were reviewing the corrective action plan submitted by OPG in 2018.

OPG was planning to have a new records repository by the end of 2020. In 2018, CNSC staff will review this upgrade to ensure it meets the applicable requirements.

###### Pickering Waste Management Facility

As a result of the 2017 inspection at the DWMF that focused on OPG’s management system, CNSC staff identified minor issues of low safety significance regarding the control of documents and records that apply to the PWMF as well. OPG agreed to carry out the corrective action plan at the PWMF with respect to records management. At the end of 2017, CNSC staff were reviewing OPG’s corrective action plans and were satisfied with the progress.

##### Management of contractors
###### Pickering Nuclear Generating Station

In 2017, CNSC staff inspected supply management at the PNGS and confirmed compliance with the applicable regulatory requirements. However, CNSC staff did identify deficiencies of low safety significance with respect to the identification of technical requirements in OPG documentation and with OPGs review of the qualification of contractors and audits reports submitted by contractors. CNSC staff is satisfied with OPGs proposed corrective action plan and is monitoring OPGs implementation of one remaining corrective action at the PNGS.

###### Pickering Waste Management Facility

CNSC staff concluded that the interface between OPG and its contractors at the PWMF did not meet the applicable regulatory requirements in 2017. During an inspection at the DWMF, CNSC staff found that OPG was no longer performing receiving inspections which include verifying the DSC history dockets received from the vendors. Discontinuing receiving inspections and failing to reflect that change in its internal documentation significantly reduced OPG’s oversight of contractors. OPG agreed to carry out the corrective action plan at the PWMF regarding the management of vendors. At the end of 2017, CNSC staff were monitoring the implementation of corrective actions at the PWMF. See section 3.1.1 for further details.

CNSC staff concluded that OPG met the applicable regulatory requirements for business continuity at the PNGS and PWMF. CNSC staff verified that OPG had adequate contingency plans in place to maintain or restore critical safety and business functions in the event of disabling circumstances, such as a pandemic, severe weather or labour action.

##### Problem identification and operating experience

CNSC staff determined that OPG met the applicable regulatory requirements for problem identification and OPEX at the Pickering site.

###### Pickering Nuclear Generating Station

In 2017, CNSC staff inspected problem identification and OPEX at the PNGS and confirmed the overall compliance of the program with the applicable regulatory requirements. CNSC staff identified minor deficiencies with respect to the problem identification program. At the end of 2017, CNSC staff were reviewing OPGs proposed corrective action plan.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

##### Performance assessment, improvement and management review

CNSC staff confirmed that OPG continued to meet the applicable regulatory requirements for performance assessment, improvement and management at the PNGS and PWMF.

###### Pickering Nuclear Generating Station

In 2017, CNSC staff inspected OPG’s audit and self-assessment programs at the PNGS. Both the audit and self-assessment programs were found to comply with the applicable regulatory requirements, and CNSC staff were satisfied with the implementation of the programs. CNSC staff did identify one minor deficiency where all programs and procedures were not periodically independently assessed for effectiveness, specifically those for hours of work and fitness for duty. At the end of 2017, CNSC staff were reviewing OPG’s proposed corrective action plan and will monitor OPG’s implementation of the corrective action at the PNGS.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

#### 3.2.2 Human performance management

CNSC staff concluded that the human performance management SCA at the Pickering site met the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “satisfactory” ratings – unchanged from the previous year.

##### Human performance program

CNSC staff determined that the OPG human performance program for the PNGS and PWMF met the applicable regulatory requirements. CNSC staff had no significant observations at the PNGS or PWMF to report in this specific area for 2017.

##### Personnel training

CNSC staff determined that OPG had a well-documented and robust fleet-wide training system based on a systematic approach to training (SAT). The implementation of this system for the training programs at the PNGS and PWMF met the applicable regulatory requirements.

###### Pickering Nuclear Generating Station

In 2017, CNSC staff performed compliance verification inspections of training programs for authorized nuclear operator and contract management personnel. CNSC staff also performed desktop reviews of the training programs for chemical laboratory staff and radiation protection technicians. In all cases, CNSC staff concluded that the training programs were defined and documented in accordance with the OPG SAT-based training system and that OPG met the applicable regulatory requirements. Minor points of procedural non-compliance of low safety significance were identified with respect to documenting training objectives and the alignment of the training qualification description documents with governance. At the end of 2017, CNSC staff were satisfied with OPG’s progress to address the points of non-compliance.

###### Pickering Waste Management Facility

In 2017, CNSC staff verified that OPG completed the corrective actions that resulted from the training-focused inspection in 2016 and closed the associated action item.

##### Personnel certification
###### Pickering Nuclear Generating Station

CNSC staff determined that OPG’s personnel certification program at the PNGS met the applicable regulatory requirements. CNSC staff reviewed the staffing reports for certified personnel and they reviewed the applications for initial certification and renewal of certification. They confirmed that certified personnel at the PNGS possessed the knowledge and skills required to perform their duties safely and competently.

###### Pickering Waste Management Facility

This specific area does not apply to the PWMF because there are no CNSC-certified positions at the facility.

##### Initial certification examinations and requalification tests
###### Pickering Nuclear Generating Station

Based on previous inspections and regular compliance verification activities, CNSC staff concluded that the initial certification examination and requalification testing programs at the PNGS met the applicable regulatory requirements.

###### Pickering Waste Management Facility

This specific area does not apply to the PWMF because there are no CNSC-certified positions at the facility.

##### Work organization and design
###### Pickering Nuclear Generating Station

The minimum shift complement (MSC) at the PNGS met the applicable regulatory requirements.

In May 2017, CNSC staff inspected the MSC program at the PNGS. The scope of the inspection encompassed all aspects of the MSC to verify availability of sufficiently-qualified staff at the PNGS. CNSC staff confirmed that OPG complied with licence requirements and had processes and procedures in place to ensure the availability of a sufficient number of qualified staff. However, CNSC staff identified non-compliance of low safety significance in the areas of record keeping, training qualification records and procedural adherence. OPG provided a corrective action plan to address the findings. CNSC staff were satisfied with OPG’s proposed corrective actions and were monitoring OPG’s implementation of the actions at the PNGS. OPG had targeted the completion of all the actions by Q1 2019.

###### Pickering Waste Management Facility

This specific area does not apply to the PWMF.

##### Fitness for duty

CNSC staff determined that OPG met the applicable regulatory requirements for fitness for duty at the PNGS and PWMF.

CNSC staff asked OPG to provide an implementation plan for CNSC REGDOC-2.2.4, Fitness for Duty, Volume I: Managing Worker Fatigue by September 30, 2017. OPG committed to the full implementation of this regulatory document at the Pickering site by January 1, 2019. CNSC staff were satisfied with OPG’s implementation plan and will monitor its progress.

OPG committed to the implementation of CNSC REGDOC -2.2.4, Fitness for Duty Volume II: Managing Alcohol and Drug Use, except random testing, by July 2019. The planned implementation date for random testing is December 2019. CNSC staff will monitor OPG’s implementation progress.

UPDATE: Although CNSC staff found the plans to be acceptable, they note that the implementation could be impacted by legal challenges.

###### Pickering Nuclear Generating Station

In 2017, CNSC staff completed a desktop review to verify the accuracy of reporting of non-compliance with the limits to hours worked for certified staff at the PNGS (and DNGS). CNSC staff identified non-compliance with the OPG processes that are used to track, monitor, and report hours of work non-compliance. By the end of 2017, OPG was developing a corrective action plan that covered both the PNGS and DNGS.

Overall, CNSC staff were satisfied with the fitness for duty of workers at the PNGS.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

#### 3.2.3 Operating performance

CNSC staff concluded that the operating performance SCA at the Pickering site met or exceeded the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “fully satisfactory” ratings – unchanged from the previous year.

CNSC staff concluded that OPG met or exceeded the applicable regulatory requirements for the conduct of licensed activities at the PNGS and PWMF. CNSC staff determined that OPG continued to operate the PNGS and PWMF in a safe and secure manner, with adequate regard for health, safety, security, radiation, environmental protection and international obligations.

In 2017, OPG operated the PNGS and PWMF within its operating policies and principles and its operational safety requirements.

###### Pickering Nuclear Generating Station

PNGS experienced one unplanned reactor trip, zero stepbacks and four setbacks. CNSC staff determined that the trip and setbacks were controlled properly, and power reduction was adequately initiated by the reactor control systems. CNSC staff verified that, for all events, OPG staff followed approved procedures and took appropriate corrective actions.

###### Pickering Waste Management Facility

During the reporting period, OPG processed 54 DSCs at the PWMF, four DSCs more than OPG’s internal target. From the start of facility production to the end of 2017, OPG had processed 901 DSCs and placed them into storage at the PWMF.

##### Procedures

CNSC staff concluded that OPG had governance in place to ensure that procedures for the PNGS and PWMF are written in a consistent and usable manner. OPG had clearly documented expectations for procedural use and adherence, and a process to manage procedural change at the Pickering site.

CNSC staff were satisfied with the quality of the OPG procedures that they reviewed and found that they met the applicable regulatory requirements at the PNGS and PWMF.

##### Reporting and trending

CNSC staff determined that OPG’s reporting and trending met or exceeded the applicable regulatory requirements and expectations in 2017 for the PNGS and PWMF. During the reporting year, all scheduled reports were adequate and they were submitted to the CNSC in a timely manner.

###### Pickering Nuclear Generating Station

OPG submitted 33 reports for events that required a detailed event report in 2017. OPG followed up on all reported events with corrective actions and root-cause analyses, as appropriate.

###### Pickering Waste Management Facility

During 2017, CNSC staff received five event reports of low safety significance from OPG regarding the PWMF. The event reports are discussed in detail throughout section 3.2 under the applicable SCA.

##### Outage management performance
###### Pickering Nuclear Generating Station

OPG demonstrated good levels of performance and achievement of objectives during maintenance outages.

In 2017, there were there four planned outages (PNGS Units 1, 4, 5 and 8) and eight forced outages (PNGS Units 1, 4, 6 and 7). Overall, based on CNSC staff oversight, OPG executed planned outages safely and met the applicable regulatory requirements.

In addition to planned outages, OPG also safely undertook forced (unplanned) outages as required to fix or replace equipment.

CNSC staff conducted two outage management inspections and found that outage management performance at the PNGS met or exceeded the applicable regulatory requirements and expectations in 2017.

###### Pickering Waste Management Facility

This specific area does not apply to the PWMF.

##### Safe operating envelope
###### Pickering Nuclear Generating Station

CNSC staff determined that OPG operated within the safe operating envelope and met the applicable regulatory requirements for PNGS.

###### Pickering Waste Management Facility

This specific area does not apply to the PWMF.

##### Severe accident management and recovery

Through regulatory oversight activities, CNSC staff determined that severe accident management and recovery met the applicable regulatory requirements for the PNGS and met or exceeded them for the PWMF. The program was implemented at the Pickering site with an organizational structure that clearly establishes the roles and responsibilities of all program participants.

###### Pickering Nuclear Generating Station

CNSC staff had no significant observations at PNGS to report in this specific area for 2017.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

##### Accident management and recovery

CNSC staff determined that OPG’s accident management and recovery programs for the PNGS and PWMF met or exceeded the applicable regulatory requirements in 2017.

###### Pickering Nuclear Generating Station

OPG has a series of abnormal incident manuals and emergency operating procedures at the PNGS to detect abnormal conditions, mitigate causes of the incidents and accidents, return the plant to a safe and controlled state, and prevent further escalation to a more serious accident. CNSC staff were satisfied with these measures.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

#### 3.2.4 Safety analysis

CNSC staff concluded that the safety analysis SCA at the Pickering site met or exceeded the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “fully satisfactory” ratings, unchanged from the previous year.

##### Deterministic safety analysis

CNSC staff concluded that OPG’s deterministic safety analysis predicted adequate safety margins, and met or exceeded the applicable regulatory requirements at the PNGS and PWMF.

###### Pickering Nuclear Generating Station

CNSC staff determined that OPG had a well-managed program for deterministic safety analysis. OPG continued to implement CNSC REGDOC-2.4.1, Deterministic Safety Analysis. OPG submitted a revised implementation plan in November 2017. As of December 2017, CNSC staff were reviewing it and were satisfied with the progress to date.

As a key input for the implementation of REGDOC-2.4.1, OPG had submitted the identification and classification of common cause events for Pickering and the technical basis document in August 2016. In December 2017, OPG submitted the analysis and results to CNSC.

UPDATE: Based on CNSC staff’s review, OPG was expected to address CNSC staff comments on the analysis through the safety report update process. This was also one of the IIP actions to support continued operation until 2024.

In 2017, OPG submitted an updated fire hazard analysis and an updated fire safe shutdown analysis for the PNGS. CNSC staff’s review determined that the approach and methodology used were consistent with the applicable regulatory requirements.

There were no major concerns raised in the review of the findings that would affect the licensees’ fire protection program or fire hazard analysis. The level of compliance was satisfactory and the licensee continues to implement a comprehensive fire protection program at the PNGS in accordance with the applicable requirements.

###### Pickering Waste Management Facility

OPG established and maintained a safety analysis program that was effectively implemented at the PWMF and that fully satisfied the applicable regulatory requirements. Every five years, OPG submits a safety analysis report for the PWMF that identifies facility hazards and the measures in place to control or mitigate these hazards. The most recent revision to this document, submitted to CNSC staff in 2013, was reviewed by CNSC staff and found to be satisfactory. CNSC staff expect the next revision of the safety report for the PWMF to be submitted in 2018.

OPG continued to implement a comprehensive fire protection program at the PWMF in accordance with the applicable requirements.

##### Probabilistic safety assessment
###### Pickering Nuclear Generating Station

As requested by the Commission after Part 2 of the hearing for the PNGS licence renewal in 2013, OPG updated the probability safety assessments (PSAs) for both NGS Units 1, 4 and 5 to 8 to account for the enhancements required under the Fukushima Action Plan. OPG has used the results and insights of the updated PSAs to identify and optimize risk improvement tasks.

OPG developed and implemented a risk improvement plan to implement safety improvements for PSA values that were below the safety goal limit but above the administrative safety goal target, specifically for PNGS Units 1 and 4:

• severe core damage frequency (SCDF) and large release frequency (LRF) for internal fires
• LRF for internal events at power

The last update to the risk improvement plan was submitted in February 2018 (see section 3.2.5 for details).

In 2017, OPG submitted a full-scope PSA update for PNGS Units 5 to 8 that was compliant with CNSC regulatory standard S-294, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants. OPG planned to submit a full-scope PSA update for PNGS Units 1 and 4 that is compliant with S-294 by the end of 2018.

In 2015, OPG provided a plan for PSA updates to meet the requirements established in CNSC REGDOC-2.4.2, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants. OPG plans to fully implement REGDOC-2.4.2 at the PNGS by the end of 2020. CNSC staff were satisfied with OPG’s transition plan and will continue to monitor the implementation of REGDOC-2.4.2. This is also one of the IIP actions to support continued operation until 2024.

In addition, in response to the Commission’s direction on the renewal of the PNGS PROL, OPG submitted the pilot project report on a whole-site PSA for the PNGS in 2017. OPG and CNSC staff presented the preliminary results to the Commission in December 2017. CNSC staff agreed with OPG’s overall approach, and specifically, the methodology used to avoid double-counting accident sequences References 4. See section 2.4 for additional background information on whole-site PSAs.

The CNSC found that OPG’s performance in the PSA area at the PNGS met or exceeded the applicable regulatory requirements in 2017.

###### Pickering Waste Management Facility

This specific area does not apply to the PWMF.

##### Criticality safety

This specific area does not apply to the PNGS or PWMF.

##### Severe accident analysis
###### Pickering Nuclear Generating Station

OPG continued to support industry R&D programs in the area of severe accident analysis.

OPG, with other licensees, developed a severe-accident software simulator solution to improve its methods for conducting deterministic analyses of multi-unit severe accidents. CNSC staff completed the review and made some recommendations, as discussed in section 2.4.

OPG had scheduled the implementation of some modifications and provisions to arrest the progression of a beyond-design-basis accident and keep it at or below severe accident status, and to prevent challenges to containment integrity.

The emergency fire water cooling pipe connection to PNGS Units 1 and 4 was expected to be completed during a planned 2020 outage, and the restoration of emergency power to one main volume vacuum pump was expected to be completed by 2019.

###### Pickering Waste Management Facility

This specific area does not apply to the PWMF.

##### Management of safety issues (including R&D programs)
###### Pickering Nuclear Generating Station

The work by NPPs to address the remaining category-3 CANDU safety issues is described in section 2.4.

The following are highlights of two R&D projects that are currently ongoing.

Moderator sub-cooling requirements methodology

OPG submitted the conclusion drawn by a safety analysis issue review panel from the experimental results of the CNSC-sponsored contact boiling project that evaluates calandria tube strain. CNSC staff issued an interim report summarizing the results of the experiments and an evaluation of the results. OPG planned to address the outstanding issues over the next licence period. This issue was considered to be of low safety significance, as it only affected safety margins during postulated accidents of a low probability of occurrence.

Moderator temperature predictions

The accurate prediction of the moderator temperature is important for several design-basis accident analyses. The original work completed on moderator temperature predictions did not consider in detail the specific moderator nozzle configuration for PNGS Units 1 and 4. OPG recently completed several initiatives to address CNSC staff’s concerns, including analyses and experiments that represent the specific geometries of the moderator inlet nozzles for PNGS Units 1 and 4. Further experimental work was underway at McMaster University. CNSC staff will review the experimental results when they become available. This issue is considered to be of low safety significance, as the issue deals with the uncertainties in analyses generated by models that are robust overall.

CNSC staff continued to systematically evaluate OPG’s R&D program activities, as submitted to CNSC staff through annual reporting in accordance with CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants. These evaluations confirmed that OPG maintained or had access to robust R&D capability to address any emerging issues.

###### Pickering Waste Management Facility

This specific area does not apply to the PWMF.

#### 3.2.5 Physical design

CNSC staff concluded that OPG activities under the physical design SCA at the Pickering site met the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “satisfactory” ratings, unchanged from the previous year.

##### Design governance

CNSC staff concluded that OPG continued to meet the applicable regulatory requirements regarding design governance in 2017 for the PNGS and PWMF.

###### Pickering Nuclear Generating Station

Environmental qualification

CNSC staff determined that OPG met the applicable regulatory requirements. In 2017, CNSC staff reviewed OPG’s response to previous inspection findings on the efficiency and effectiveness of the environmental qualification program and concluded that OPG adequately addressed issues related to knowledge management and resourcing. Outstanding actions relating to the improvement of system performance monitoring plans and updates of environmental qualification documentation are targeted for completion in 2018.

OPG was conducting an evaluation under the IIP of existing environmental qualification assessments for life-limiting components to support operation beyond 2020. The resulting actions will be documented and resolved in accordance with OPG environmental qualification program requirements, and relevant documentation will be submitted to the CNSC by December 2019.

Pressure boundary design

OPG continued to implement a comprehensive pressure boundary program at the PNGS that was compliant with the applicable regulatory requirements.

Human factors in design

OPG completed a gap analysis and developed an implementation plan for CSA Group standard N290.12-14, Human factors in design for nuclear power plants by September 1, 2018.

###### Pickering Waste Management Facility

Pressure boundary design

CNSC staff determined that OPG continued to implement a comprehensive pressure boundary program at the PWMF that was compliant with the applicable regulatory requirements.

##### Site characterization

CNSC staff concluded that site characterization at the Pickering site met the applicable regulatory requirements. CNSC staff had no significant observations at the PNGS or the PWMF to report in this specific area for 2017.

##### Facility design

CNSC staff concluded that facility design at the Pickering site met the applicable regulatory requirements. CNSC staff had no significant observations at the PNGS or the PWMF to report in this specific area for 2017.

##### Structure design

CNSC staff concluded that OPG continued to meet the applicable regulatory requirements regarding structure design in 2017 for the PNGS and PWMF.

###### Pickering Nuclear Generating Station

In 2016, CNSC staff had inspected the preservation of the seismic design basis at the PNGS. CNSC staff concluded that OPG met the applicable regulatory requirements, with the exception of some minor deficiencies of low safety significance related to the verification of documents and maintenance of a plant configuration that is consistent with design documents. OPG provided a long-term corrective action plan. CNSC staff found the plan acceptable and were monitoring its implementation at the end of 2017.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

##### System design

CNSC staff concluded that OPG continued to meet the applicable regulatory requirements regarding system design in 2017 for the PNGS and PWMF.

The PNGS PSR identified modifications to protect containment by providing emergency power and water to the reactor air cooling units and by providing emergency power to the hydrogen igniters and the filtered air discharge system. In addition, modifications will be completed to make water from the fire protection system available to the steam generators, heat transport system and moderator system. These and other specific activities were documented in the IIP.

###### Pickering Nuclear Generating Station

Electrical power systems

In 2017, CNSC staff conducted desktop reviews and followed up on 2015 and 2016 compliance inspections. Based on these compliance activities, no major concerns were found and CNSC staff concluded that the electrical power systems met the applicable regulatory requirements at the PNGS.

Fire protection design

The licensee complied with the applicable regulatory requirements based on the results of CNSC’s ongoing compliance activity.

Independent third party reviews for design modifications and inspections of facility site condition was acceptable and yielded no major findings. The level of compliance was satisfactory, and the licensee continues to implement a comprehensive fire protection program at the PNGS.

Instrumentation and control

CNSC staff had no significant observations at the PNGS to report in this specific area for 2017. CNSC staff determined that OPG had improved the performance and reliability of instrumentation and control systems at the PNGS by verifying compliance with codes and standards, the corrective maintenance program and the aging management of instrumentation and control systems.

###### Pickering Waste Management Facility

CNSC staff determined that OPG continued to implement a comprehensive fire protection program at the PWMF in accordance with CSA Group standard N393-13, Fire protection for facilities that process, handle, or store nuclear substances.

##### Component design

CNSC staff concluded that OPG continued to meet the regulatory requirements applicable to components design in 2017 for the PNGS and PWMF.

###### Pickering Nuclear Generating Station

Fuel design

CNSC staff determined that OPG had a mature reactor fuel inspection and monitoring program. Fuel performance at the PNGS was acceptable in 2017. As a result of the corrective actions, the severity and frequency of observed black deposits continued trending downwards. OPG was able to adequately manage fuel performance issues while maintaining safe operations.

Cables

In 2017, there were no issues found during compliance verification activities (i.e., desktop reviews and compliance verification inspections of the electrical power systems). CNSC staff concluded that the cable management program at the PNGS met the applicable regulatory requirements.

PSA risk improvement plan

OPG developed and implemented a risk improvement plan to implement safety improvements for PSA values that were below the safety goal limit but above the administrative safety goal target.

CNSC staff reviewed and accepted the plan which addressed physical changes to the station as well as changes to the PSA modeling. Improvements to plant design included:

• removing heat from the reactor core (such as moderator heat-exchanger cooling and end-shield cooling)
• installation of passive autocatalytic recombiners
• tie-down of EME for high wind
• installation of flood barriers

These improvements resulted in a significant reduction in risk for internal fires and a significant reduction in severe core damage.

Since 2015, OPG has provided annual updates to CNSC on the progress and status of the risk improvement plan.

CNSC staff were satisfied with the implementation status of the risk improvement tasks, and they verified and confirmed that OPG had completed all the items by the end of 2017.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

#### 3.2.6 Fitness for service

CNSC staff concluded that the Fitness for service SCA at the Pickering site met the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “satisfactory” ratings, unchanged from the previous year.

CNSC staff determined that OPG has established and maintains fitness-for-service programs that have been effectively implemented at the PNGS and PWMF, and that satisfy the applicable regulatory requirements. The implemented programs ensure the safe physical condition of SSCs.

##### Equipment fitness for service/equipment performance
###### Pickering Nuclear Generating Station

CNSC staff determined that overall, equipment fitness for service and performance at the PNGS was satisfactory and met the applicable regulatory requirements.

Reliability of systems important to safety

CNSC staff determined that the reliability program at the PNGS met the applicable regulatory requirements.

CNSC staff reviewed OPG’s maintenance strategy to improve system availability and reliability,  and they determined that the existing reliability programs (and maintenance programs, described below) met regulatory requirements.

CNSC staff identified an area for improvement with the increasing unavailability of emergency power generators (EPGs) resulting primarily from long outages. It was noted that there was no simultaneous loss of EPGs; moreover, when EPG1 or EPG2 was unavailable, EPG3 was placed in standby state to maintain the reliability of the emergency power supply function. OPG had already implemented some corrective actions to address this issue and an action item was raised so that OPG would address issues identified by CNSC staff. CNSC staff also noticed that, according to the  2017 Annual Risk and Reliability Report, the EPGs’ unavailability time had been reduced. CNSC staff continue to monitor the effectiveness of OPG’s reliability improvement actions.

All special safety systems for PNGS Units 1, 4 and 5 to 8 met their unavailability targets in 2017.

###### Pickering Waste Management Facility

This specific area does not apply to the PWMF.

##### Maintenance

CNSC staff determined that OPG’s maintenance program met the applicable regulatory requirements for the PNGS and PWMF in 2017. OPG’s maintenance program for NPPs also governs preventative and corrective maintenance activities for the WMFs.

###### Pickering Nuclear Generating Station

The average preventive maintenance completion rate for the six units at the PNGS was 82% in 2017. This was slightly lower than the industry average, but acceptable to CNSC staff. The maintenance backlogs were also acceptable and are provided in table 18.

Table 18: Trend of maintenance backlogs and deferrals for critical components for PNGS, 2015 to 2017
Parameter Average quarterly work orders per unit Three-year trend Industry average
2015 2016 2017
Corrective maintenance backlog 26 19 7 down 4
Deficient maintenance backlog 96 109 104 stable 94
Deferrals of preventive maintenance 120 110 81 down 30

The corrective maintenance backlog was reduced; the quarterly average was close to the industry average for 2017. The management of deficient maintenance work was below the industry average. The number of preventive maintenance deferrals has been trending downward, but was more than twice the industry average.

CNSC staff conducted a focused desktop review in 2017 to determine the cause of the relatively high numbers for the deficient maintenance backlog and preventive maintenance deferrals. Among the causes revealed in the review, the lack of maintenance resources was identified as one of the major causes of the high number of preventive maintenance deferrals.

UPDATE: In January 2018, the CNSC asked OPG to provide a self-assessment and the associated corrective actions to ensure adequate maintenance resources were in place for the timely conduct of critical maintenance activities. OPG provided its first response in May 2018. CNSC staff reviewed the response and concluded that adequate resources were in place to complete the maintenance work per the required frequency. Overall, the significance of maintenance backlogs and deferrals for critical components was low because the deficient maintenance backlog had been stabilized during the previous four quarters and the system safety functions were always maintained. (This is continuously verified in maintenance inspections and maintenance-related event reviews.)

As part of the licence renewal, OPG confirmed it had implemented CNSC regulatory document RD/GD-210, Maintenance Programs for Nuclear Power Plants, which superseded CNSC regulatory standard S-210, Maintenance Programs for Nuclear Power Plants. This standard was added as compliance verification criteria in the proposed LCH for the licence renewal.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

##### Structural integrity

CNSC staff concluded that SSCs required for safe operation continued to meet the applicable structural integrity requirements established in the design basis or in CNSC-accepted standards and guidelines for the PNGS and PWMF in 2017.

###### Pickering Nuclear Generating Station

In 2017, OPG’s pressure boundary inspection results indicated that all inspected elements of the primary heat transport and auxiliary systems, steam generators, feeders and pressure tubes met CSA Group acceptance criteria. CNSC staff reviewed the results of the Unit 1 reactor building pressure test in November 2017 and found no significant issues.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

##### Aging management

CNSC staff concluded that OPG’s integrated aging management program met the applicable regulatory requirements at the PNGS and PWMF in 2017. OPG completed its transition to compliance with CNSC REGDOC-2.6.3, Aging Management in 2017 at the PNGS and PWMF.

###### Pickering Nuclear Generating Station

CNSC staff confirmed that the in-service inspection scope included in the major component LCMPs exceeded the minimum inspection requirements. Further, the major component LCMPs also included specific mitigating strategies should fitness for service assessments identify degradation mechanisms for which the acceptance criteria cannot be met up to the end of the evaluation period.

CNSC staff determined that OPG had adequate programs in place to confirm that fuel channels were fit for service for near-term operation. OPG submitted engineering assessments of degradation mechanisms that spanned the near-term and met all applicable CSA Group acceptance criteria. CNSC staff continued to monitor the implementation of the fuel channel life management project to further develop the analytical tools necessary to demonstrate pressure tube fitness for service for continued operation. CNSC staff were satisfied with the progress. See section 2.6 for further details. Also, see appendix H for details on the current and predicted future fuel channel conditions and the corresponding validity of analytical models of pressure tube fracture toughness for fuel channels at the PNGS (and the other NPPs in Ontario).

###### Pickering Waste Management Facility

There were no significant observations to report for this specific area at PWMF in 2017.

##### Chemistry control

CNSC staff determined that OPG’s chemistry control program met or exceeded the applicable regulatory requirements for the PNGS and PWMF in 2017.

###### Pickering Nuclear Generating Station

CNSC staff confirmed that the PNGS maintained acceptable performance in chemistry control in 2017 (see section 2.6).

In 2017, CNSC staff inspected the PNGS chemistry program and concluded that it complied with the applicable regulatory requirements and aligned with industry best practices.

###### Pickering Waste Management Facility

CNSC staff reviewed the 2017 quarterly reports for the PWMF and concluded that the facility has maintained acceptable performance related to chemistry. There were no chemistry-related incidents at the PWMF in 2017.

##### Periodic inspection and testing
###### Pickering Nuclear Generating Station

CNSC staff have determined that OPG has adequate and well maintained periodic inspection programs (PIPs) for pressure boundary systems, containment components and containment structures that comply with CSA Group standards N285.4 Periodic inspection of CANDU nuclear power plant components, N285.5 Periodic inspection of CANDU nuclear power plant containment components and N287.7 In-service examination and testing requirements for concrete containment structures.

###### Pickering Waste Management Facility

This specific area does not apply to the PWMF because periodic inspection and testing requirements are addressed under the scope of aging management at the facility.

CNSC staff concluded that the radiation protection SCA at the Pickering site met the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “satisfactory” ratings, unchanged from the previous year.

##### Application of ALARA

CNSC staff determined that OPG continued to implement an effective and well-documented program, based on industry best practices, to keep doses to persons as low as reasonably achievable (ALARA) at the PNGS and PWMF.

CNSC staff verified that OPG used ALARA initiatives, work planning and dose monitoring and control to work toward achieving the challenging ALARA targets established by OPG at the PNGS and PWMF.

###### Pickering Nuclear Generating Station

In 2017, CNSC staff conducted an inspection focused on the application of ALARA. It confirmed that OPG has a mature ALARA program to plan and control work activities that meets CNSC expectations. No regulatory non-compliance was identified as a result of this inspection.

###### Pickering Waste Management Facility

CNSC staff verified during 2017 that radiation exposures and doses to workers at the PWMF were below the regulatory dose limits and remained ALARA.

##### Worker dose control

CNSC staff determined that OPG continued to comply with the regulatory requirements to measure and record doses received by workers at the PNGS and PWMF.

Routine compliance verification activities conducted in 2017 indicated that performance in the area of worker dose control at the Pickering site was effective. Radiation doses to workers at the PNGS and PWMF were below the regulatory dose limits, as were the action levels established in OPG’s radiation protection program.

CNSC staff observed that no adverse trends or safety-significant unplanned exposures resulted from the licensed activities at the Pickering site in 2017.

The data on doses to workers at the Pickering site is provided in section 2.7.

###### Pickering Nuclear Generating Station

The maximum dose received by a worker at the PNGS in 2017 was 14.58 mSv, which was approximately 29% of the regulatory dose limit.

###### Pickering Waste Management Facility

The maximum dose received by a worker at the PWMF in 2017 was 0.9 mSv, which was 1.8% of the regulatory dose limit.

CNSC staff determined that OPG’s corporate radiation protection program, which covers the PNGS and PWMF, met the requirements of the Radiation Protection Regulations. The oversight applied by OPG for implementing and improving this program was effective at protecting workers at the PNGS and PWMF. OPG regularly measures the performance of its radiation protection program against industry-established objectives, goals and targets.

CNSC staff determined that OPG implemented radiological hazard controls that met the applicable regulatory requirements. These measures protected workers and ensured that radioactive contamination was controlled within the site boundaries for the PNGS and PWMF.

Contamination control action levels for surface contamination were not exceeded as a result of licensed activities at the PNGS and PWMF in 2017.

CNSC staff confirmed that no safety-significant incidents were identified through the reporting of safety performance indicators on personnel and loose contamination events.

OPG’s contamination control action levels were revised in 2017 for the Pickering site to ensure they were appropriate indicators of a failure of the radiation protection program. CNSC staff reviewed the revised action levels and found them to be appropriate.

##### Estimated dose to the public

CNSC staff determined that OPG continued to ensure the protection of the general public, in accordance with the Radiation Protection Regulations. The reported estimated dose to members of the general public from the Pickering site was 0.0018 mSv, well below the annual dose limit of 1 mSv for members of the general public (see section 2.7 for details).

#### 3.2.8 Conventional health and safety

CNSC staff concluded that the conventional health and safety SCA at the Pickering site met or exceeded the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “fully satisfactory” ratings, unchanged from the previous year.

##### Performance

CNSC staff determined that OPG met or exceeded the applicable requirements at the PNGS and PWMF for conventional health and safety performance.

OPG continues to demonstrate its ability to keep workers safe from occupational injuries while conducting its licensed activities at the PNGS and PWMF. Health- and safety-related incidents were reported by OPG on an ongoing basis, as applicable.

CNSC staff inspected the safety practices and controls OPG employs at the PNGS and PWMF to address conventional hazards, and they recorded their findings. CNSC staff did not identify any areas of concern regarding conventional health and safety in 2017.

###### Pickering Nuclear Generating Station

CNSC staff observed that the accident severity rate (ASR) for the PNGS was 2.8 and the accident frequency (AF) was 0.1 (see figures 11 and 12 in section 2.8). In 2017, there were two lost-time injuries. CNSC staff found the ASR and AF safety performance indicators at the PNGS to be acceptable.

###### Pickering Waste Management Facility

No health and safety related incidents or lost-time injuries at the PWMF were reported by OPG to CNSC staff in 2017.

CNSC staff participated in pre-inspection health and safety briefings with OPG staff and management while on site for inspections. CNSC staff found that the health and safety briefings were satisfactory.

##### Practices

CNSC staff determined that conventional health and safety practices met or exceeded the applicable regulatory requirements at the PNGS and PWMF in 2017.

The conventional health and safety work practices and conditions at the PNGS and PWMF continued to result in a high degree of personnel safety. OPG personnel at all levels exhibited proactive attitudes toward anticipating work-related hazards and preventing unsafe conditions. There continued to be a working environment where safe work practices were encouraged. CNSC staff verified that OPG had appropriate procedures in place at the PNGS and PWMF to ensure that the environment and the health of persons are protected against hazardous materials.

###### Pickering Waste Management Facility

CNSC staff observed safe work practices during site inspections at the PWMF. A positive indicator in this regard was the use of the job hazard analysis program that specifies OPG’s commitment to conducting pre-inspection tours of jobs and job sites, listing emergency procedures for these jobs, identifying the minimum level of personal protective equipment required, and listing the permits or work authorizations required before starting work.

##### Awareness

CNSC staff concluded that OPG met or exceeded the applicable regulatory requirements for awareness in 2017 at the PNGS and PWMF. CNSC staff determined that OPG continued to maintain a safe working environment at the PNGS and PWMF. CNSC staff had no significant observations at the PNGS or the PWMF to report in this specific area for 2017.

#### 3.2.9 Environmental protection

CNSC staff concluded that the environmental protection SCA at the Pickering site met the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “satisfactory” ratings, unchanged from the previous year.

##### Effluent and emissions control (releases)

CNSC staff observed that all airborne and waterborne radiological releases from the Pickering site remained below the regulatory limits and action levels in 2017. The releases are shown in figures 16 and 17 for PNGS Units 1, 4 and 5 to 8, respectively, as percentages of the applicable derived release limits (DRLs); Pickering B releases include those for the PWMF. The actual values for the releases and DRLs for the Pickering site are provided in appendix I.

OPG planned to complete the implementation of CSA Group standard N288.3.4-13, Performance testing of nuclear air-cleaning systems at nuclear facilities by September 2018 for both the PNGS and PWMF.

###### Pickering Waste Management Facility

As of December 14, 2017, OPG was fully compliant with the requirements of CSA Group standard N288.3.4-13, Performance testing of nuclear air-cleaning systems at nuclear facilities for the PWMF.

In the record of decision issued for the licence renewal of the PWMF, the Commission requested that CNSC staff provide an updated analysis to confirm that tritium releases from the PWMF were not increasing. CNSC staff trended the release data provided by OPG and confirmed that tritium releases at the PWMF have been on a downward trend since 2015, as shown in figure 18.

##### Environmental management system

CNSC staff concluded that OPG has established and implemented a corporate-wide environmental management system (EMS) at the Pickering site in accordance with CNSC REGDOC-2.9.1, Environmental Protection Policies, Programs and Procedures (2013) to assess the environmental risks associated with its nuclear activities at the PNGS and PWMF and to ensure that those activities are conducted in a way that prevents or mitigates adverse environmental effects. The EMS was also registered to ISO standard 14001: 2015 – Environmental management systems – Requirements with guidance for use. As a result of registration, the EMS is subject to periodic, independent, third-party audits and reviews to verify its sufficiency and to identify potential improvements.

##### Assessment and monitoring

CNSC staff reviewed and assessed the environmental monitoring data provided by OPG for the Pickering site and concluded that the general public and the environment in the vicinity of the site were protected. OPG met the applicable regulatory requirements for the PNGS and PWMF.

CNSC staff conducted independent environmental monitoring around the Pickering site in 2017 (see section 2.9 for a description of the IEMP). The results are available on the CNSC’s IEMP webpage. The IEMP results indicated that the general public and the environment in the vicinity of the Pickering site were protected and that there were no expected health impacts.

OPG had a transition plan in place to implement the requirements of CSA Group standard N288.7-15, Groundwater protection programs at Class I nuclear facilities and uranium mines and mills at the PNGS and PWMF by December 31, 2020. CNSC staff found the transition date to be acceptable.

###### Pickering Nuclear Generating Station

Fish barrier net (monitoring)

In November 2017, approximately 24,000 kg of fish biomass, predominately larvae and young-of-the-year (age-0) alewife, were impinged on the intake screen after the barrier net was removed for the winter, prior to lake ice formation. This quantity of alewife is equivalent to approximately 1500 kg of one-year old adult (age-1) fish). OPG notified both CNSC staff and Fisheries and Oceans Canada of this event. OPG conducted an investigation and in June 2017, OPG provided the results to both CNSC and Fisheries and Oceans Canada. OPG concluded that the event was attributable to rapid changes in the near-shore lake environment, specifically sudden changes in lake temperature, current direction and speed.

UPDATE: OPG submitted its detailed event investigation report to CNSC in April 2018 for review.

##### Protection of the public

CNSC staff confirmed that the general public in the vicinity of the Pickering site were protected, and that there were no expected health impacts. No reported hazardous substances released from the Pickering site exceeded regulatory limits in 2017.

Dose to the public is discussed in section 3.2.7.

##### Environmental risk assessment

CNSC staff determined that OPG continued to implement and maintain an effective environmental risk assessment (ERA) and management program at the Pickering site in accordance with the applicable regulatory requirements.

OPG submitted a site-wide ERA report (revision R000) for the Pickering site in April 2017, based on effluent and environmental monitoring data for the five-year period from 2011 to 2015. The ERA included an ecological risk assessment and a human health risk assessment for radiological and non-radiological (hazardous) chemicals of potential concern and physical stressors.

UPDATE: In March 2018, OPG submitted its revised ERA report (revision R001) for the Pickering site. Based on their reviews, CNSC staff drew the same conclusion in revisions R000 and R001, namely, that the ERA met the applicable regulatory requirements and that meaningful, adverse ecological and human health effects due to releases into the air and water from the PNGS and PWMF were unlikely. By the time of the PNGS licence renewal in 2018, OPG had complied with the requirements of CSA Group standard N288.6-12, Environmental risk assessments at Class I nuclear facilities and uranium mines and mills at the PNGS and PWMF.

###### Pickering Nuclear Generating Station

OPG also submitted a predictive effects assessment (PEA) in support of the licensing process for the continued operation of the reactor units and eventual stabilization and storage with surveillance phases (SSSP) and to demonstrate that its provisions to protect the environment are adequate.

CNSC staff found that the 2017 PEA provided an adequate evaluation of all potential risks to human health and the environment associated with the continued operation of the reactor units and eventual SSSP if the PNGS ceases commercial operation in the future. The results of the PEA review by CNSC staff indicate that meaningful human health or ecological effects attributable to the proposed SSSP activities are unlikely.

#### 3.2.10 Emergency management and fire protection

CNSC staff concluded that the emergency management and fire protection SCA at the Pickering site met the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “satisfactory” ratings, unchanged from the previous year.

CNSC staff determined that OPG continued to maintain comprehensive conventional, nuclear and fire emergency response capabilities at all times for the Pickering site that met the applicable regulatory requirements. This includes personnel and equipment for medical situations and events involving hazardous materials (HAZMAT), search and rescue, and fire response.

The PNGS emergency response team (ERT) responds to events at all times within the PNGS protected area (including the PWMF Phase I).

Emergency response within the Pickering site boundary (including the PWMF Phase II protected area) but outside the PNGS protected area is ensured by the City of Pickering Fire Department and Emergency Medical Services (EMS) with support from site personnel. Site support can include operations, security staff or ERT personnel.

##### Conventional emergency preparedness and response

CNSC staff had no significant observations at the PNGS or the PWMF to report for this specific area for 2017.

##### Nuclear emergency preparedness and response

OPG continued to support offsite emergency management organizations and commitments throughout 2017. OPG’s nuclear emergency preparedness program is documented in the Consolidated Nuclear Emergency Plan (CNEP) which governs the Pickering site.

Training and exercises are conducted annually at the Pickering site to ensure all areas of the site have adequate emergency notification and response capability from the PNGS ERT, City of Pickering Fire Department and Region of Durham Paramedic Services.

###### Pickering Nuclear Generating Station

OPG implemented version 1 of CNSC REGDOC-2.10.1, Nuclear emergency preparedness and response (2014) at the PNGS by September 2017.

In 2017, OPG completed the implementation of a real-time automatic data transfer system for the PNGS which will provide prompt plant information to staff in the CNSC’s Emergency Operations Centre during a nuclear emergency.

In December 2017, OPG conducted a full-scale exercise (Exercise Unified Control) at the PNGS. The exercise was designed to test the preparedness and response capabilities and capacities of more than 30 organizations, including the CNSC and some non-governmental agencies. The exercise progressed to a severe accident, which tested OPG’s ability to respond to extreme events. CNSC staff inspected the exercise to assess OPG’s compliance with the applicable regulatory requirements, and specifically, the CNEP.

UPDATE: CNSC staff identified a number of findings of compliance and non-compliance during the inspection. The findings of non-compliance were in the area of human performance, relating to awareness and adherence to the procedures used during the emergency exercise. OPG developed a corrective action plan and CNSC staff were monitoring its implementation.

###### Pickering Waste Management Facility

OPG has a facility emergency program for the PWMF that includes radiation response emergency procedures. OPG also incorporates the CNEP as part of its onsite requirements for nuclear response at the PWMF.

OPG had a transition plan to implement the requirements of CNSC REGDOC-2.10.1, Nuclear Emergency Preparedness and Response (2016), version 2, at the PWMF by December 31, 2018. CNSC staff found the transition date to be acceptable.

##### Fire emergency preparedness and response

OPG has an extensive fire drill and training program which includes the Wesleyville Fire Training Academy located near Wesleyville, Ontario where live fire training is conducted for the PNGS ERT and the City of Pickering Municipal Fire Department.

###### Pickering Nuclear Generating Station

CNSC staff inspected the fire protection program in 2017 and concluded that OPG complied with the applicable regulatory requirements. However points of non-compliance in OPG’s governance were observed for the effective management of transient and combustible material and for deficiencies with the fire protection surveillance process. OPG provided a corrective action plan. CNSC staff will continue to monitor OPG’s corrective actions through regular compliance oversight activities.

CNSC staff also performed a reactive field inspection of fire protection equipment at the PNGS. OPG was found to be non-compliant with the applicable requirements (National Fire Protection Association 1962) for maintaining records of the maintenance and inspection of fire protection equipment. OPG provided a corrective action plan which CNSC staff found to be acceptable.

In addition to CNSC compliance activities, the PNGS is required to conduct expert third-party reviews (TPRs), an annual plant condition inspection, a bi-annual fire drill audit and a tri-annual fire protection program audit.

By incorporating the CNSC’s compliance findings and TPR observations and recommendations into the drill and training program, the ERT’s performance continued to improve.

###### Pickering Waste Management Facility

OPG has a facility emergency program for the PWMF that includes basic fire response by facility staff who respond to small fires with fire extinguishers.

On January 23, 2017, OPG reported an event that occurred at Storage Building #3 of the PWMF to CNSC staff whereby the due date for the fire hydrant flush and drain maintenance was exceeded. OPG stated that there were no environmental, health, safety or security implications for the facility or personnel as a result of the event. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

On June 22, 2017, OPG reported an event that occurred at Storage Building #3 of the PWMF to CNSC staff in which the fire protection system booster panel failed, rendering three of five beam detectors unavailable. OPG stated that there were no environmental, health, safety or security implications for the facility or personnel as a result of the event. OPG notified CNSC staff in September 2017 that the impairment was cleared. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

On August 3, 2017, OPG reported an event that occurred at the PWMF processing building to CNSC staff involving an emergent fire impairment in which a panel module failed, impairing the fire detection panel. OPG stated that there were no residual environmental, health, safety or security implications for the facility or personnel as a result of this event, with the implementation of the plan for rectifying impairments. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

#### 3.2.11 Waste management

CNSC staff concluded that the waste management SCA at the Pickering site met or exceeded the performance objectives and applicable regulatory requirements. As a result, the PNGS received a “fully satisfactory” rating, unchanged from the previous year, and the PWMF received a “satisfactory” rating, also unchanged from the previous year.

##### Waste characterization

CNSC staff determined that OPG’s waste characterization met or exceeded the applicable regulatory requirements at the PNGS and PWMF. OPG continued to employ effective programs for the characterization of radioactive and hazardous wastes at the PNGS and PWMF during 2017. CNSC staff had no significant observations at the PNGS or the PWMF to report in this specific area for 2017.

##### Waste minimization

CNSC staff determined that OPG’s waste management programs for minimizing radioactive waste met or exceeded the applicable regulatory requirements at the PNGS and PWMF.

###### Pickering Waste Management Facility

Minimal radioactive waste is generated from the waste management activities conducted at the PWMF. Nonetheless, OPG has set a goal to minimize the amount of radioactive waste generated in operational activities. Annual volumes amount to less than one drum, which is sent to the PNGS for segregation as necessary and eventually transported to the WWMF for processing and storage.

##### Waste management practices

CNSC staff determined that OPG’s waste management practices met or exceeded the applicable regulatory requirements at the PNGS and PWMF. OPG continued to employ effective radioactive and hazardous waste management practices at the Pickering site during 2017. OPG used waste management procedures to ensure that waste generated at the facility was separated properly.

###### Pickering Waste Management Facility

As of October 31, 2017, OPG had fully implemented the requirements of CSA Group standards N292.0-14, General principles for the management of radioactive waste and irradiated fuel, N292.2-13, Interim dry storage of irradiated fuel and N292.3-14, Management of low- and intermediate-level radioactive waste for the PWMF.

##### Decommissioning plans

The preliminary decommissioning plans (PDPs) for the PNGS and PWMF met or exceeded the applicable regulatory requirements in 2017.

In 2017, OPG revised PDPs for all of its facilities for the period ending in 2022. OPG selected a deferred decommissioning strategy for the PNGS and an immediate decommissioning strategy for the PWMF, after the PNGS is decommissioned. The associated financial guarantee is discussed in section 2.15.

#### 3.2.12 Security

CNSC staff concluded that the security SCA at the Pickering site met the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “satisfactory” ratings, unchanged from the previous year for the PNGS, downgraded from the previous year for the PWMF.

##### Facilities and equipment

CNSC staff determined that OPG met the applicable regulatory requirements for facilities and equipment at the PNGS and PWMF. OPG continued to sustain its security equipment through lifecycle management at the Pickering site. No significant equipment failures were reported in 2017. OPG had processes in place to adequately prevent security events at the PNGS and PWMF.

###### Pickering Nuclear Generating Station

OPG committed to improving the PNGS preventive maintenance program in 2017 to ensure that adequately qualified personnel are available to maintain security equipment effectively.

Cyber security

OPG maintains a cyber security program for the PNGS. CNSC staff concluded that the program is compliant with applicable regulatory requirements. No cyber security events were reported in 2017.

OPG was updating its cyber security program for the PNGS to achieve compliance with CSA Group standard N290.7-14, Cyber security for nuclear power plants and small reactor facilities by November 30, 2019. CNSC staff were satisfied with the progress.

###### Pickering Waste Management Facility

OPG had physical protection systems and a security program in place at the PWMF that were appropriate for a high-security nuclear facility.

CNSC staff confirmed that OPG updated its security operating procedures and ensured that its contingency plans continued to meet the design basis threat as approved by the CNSC.

CNSC staff inspected security at the PWMF in 2017 and issued three low-risk compliance actions to OPG. CNSC staff were satisfied with the resulting corrective actions and considered the inspection closed.

On October 24, 2017, OPG reported an event that occurred at the PWMF to CNSC staff involving security. CNSC staff followed up on the event onsite during a routine inspection. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

##### Response arrangements

CNSC staff determined that OPG met the applicable regulatory requirements for response arrangements at the PNGS and PWMF.

###### Pickering Nuclear Generating Station

CNSC staff were monitoring the implementation of corrective actions in response to findings made during compliance verification activities at the PNGS in 2016. These findings were in the areas of training and decision making. OPG implemented corrective actions to address them by March 30, 2018. CNSC staff were meeting with the licensee and will follow up until the corrective actions are completed.

OPG has also developed an incident command course, which provides valuable training and information for both the offsite response force and the PNGS onsite nuclear response force. OPG updates the course material based on the outcomes and opportunities for improvement noted in previous security exercises.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

##### Security practices

OPG has procedures in place at the PNGS and PWMF to guide plant and security personnel in security practices. CNSC staff determined that OPG implemented security practices at the PNGS and PWMF that met the applicable regulatory requirements.

###### Pickering Nuclear Generating Station

OPG had implemented a corrective action plan to reduce the number of reportable events related to employees who do not follow procedures. CNSC staff conducted a follow-up inspection to verify the corrective measures to mitigate the issues.

OPG had submitted a detailed implementation plan to meet the new requirements for security screening, which CNSC staff assessed as acceptable.

###### Pickering Waste Management Facility

CNSC staff had no significant observations at the PWMF to report in this specific area for 2017.

##### Drills and exercises

CNSC staff determined that OPG’s drill and exercise program met the applicable regulatory requirements for the PNGS and PWMF. CNSC staff had no significant observations at the PNGS or the PWMF to report in this specific area for 2017.

#### 3.2.13 Safeguards and non-proliferation

CNSC staff concluded that the safeguards and non-proliferation SCA at the Pickering site met the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “satisfactory” ratings, unchanged from the previous year.

##### Nuclear material accountancy and control

CNSC staff confirmed that OPG’s accountancy and control of nuclear material at the PNGS and PWMF complied with the applicable regulatory requirements in 2017.

##### Access and assistance to the IAEA

CNSC staff verified that OPG met the applicable regulatory requirements for access and assistance at the PNGS and PWMF. OPG granted adequate access and assistance to the IAEA for safeguards activities, including inspections and the maintenance of equipment at the PNGS and PWMF, pursuant to the Canada-IAEA safeguards agreements and the facilities’ licence conditions.

###### Pickering Nuclear Generating Station

In 2017, the IAEA performed one physical inventory verification, one design information verification and three unannounced inspections at the PNGS to verify the nuclear material inventory and ensure the absence of undeclared nuclear material and activities.

OPG granted access to the IAEA in October 2017 and provided assistance for a site survey to identify potential locations for additional IAEA surveillance equipment in the spent fuel bay area, with a goal of optimizing the current safeguards approach at that facility.

###### Pickering Waste Management Facility

In 2017, the IAEA performed one short-notice, random inspection and five unannounced inspections at the PWMF to verify the nuclear material inventory and ensure the absence of undeclared nuclear material and activities.

The IAEA did not perform a physical inventory verification at the PWMF in 2017. CNSC staff performed an evaluation of OPG’s preparedness for a physical inventory verification at the PWMF. CNSC staff concluded that OPG was adequately prepared for an IAEA physical inventory verification at the PWMF in 2017, had one been conducted.

CNSC staff confirmed that OPG met the applicable regulatory requirements for operational and design information for the PNGS and PWMF. OPG submitted its annual operational program with quarterly updates for the PNGS and PWMF to the CNSC on time. OPG submitted the annual update to the information pursuant to the IAEA Additional Protocol to the CNSC on time. CNSC staff were satisfied with the information provided and concluded that it met CNSC’s submission requirements.

###### Pickering Waste Management Facility

In addition, OPG also submitted an updated design information questionnaire for the PWMF which was reviewed by CNSC staff and subsequently submitted to IAEA. CNSC staff were satisfied with the information provided and concluded that it met the CNSC’s submission requirements.

##### Safeguards equipment, containment and surveillance

CNSC staff confirmed that OPG met the applicable regulatory requirements for safeguards equipment, containment and surveillance for the PNGS and PWMF. OPG supported IAEA equipment operation and maintenance activities at the Pickering site, including routine maintenance of surveillance equipment, to ensure the effective implementation of safeguards measures at the PNGS and PWMF.

###### Pickering Nuclear Generating Station

In September 2017, OPG reported an event to the CNSC involving an unexpected loss of external power to IAEA surveillance equipment overnight from September 19 to September 20, 2017. The event was immediately reported to the IAEA. The IAEA subsequently confirmed that continuity of knowledge was maintained, and therefore there was no impact on safeguards implementation at the facility. CNSC staff were satisfied with the corrective actions taken by the licensee for this event.

###### Pickering Waste Management Facility

On September 29, 2017, OPG reported an event that occurred at the PWMF to CNSC staff involving the breakage of an IAEA COBRA seal on a DSC. CNSC staff later received confirmation from the IAEA that continuity of knowledge was maintained as the metal seal was intact at all times. The IAEA replaced the seals on the DSC on October 30, 2017 and confirmed that no further follow-up action was required. OPG stated that there were no environmental, health, safety or security implications for the facility or personnel as a result of this event. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

#### 3.2.14 Packaging and transport

CNSC staff concluded that the packaging and transport SCA at the Pickering site met the performance objectives and applicable regulatory requirements. As a result, the PNGS and PWMF received “satisfactory” ratings, unchanged from the previous year.

##### Package design and maintenance, packaging and transport, and registration for use

CNSC staff determined that OPG had a packaging and transport program for the PNGS and PWMF that ensured compliance with the Packaging and Transport of Nuclear Substances Regulations, 2015 and the Transportation of Dangerous Goods Regulations.

No packaging and transport events were reported in 2017.

For onsite movements of nuclear substances, OPG ensured a level of safety equivalent to that required for offsite transportation to protect the health and safety of workers, the general public and the environment.

CNSC staff had no significant observations at the PNGS or the PWMF to report in this specific area for 2017.

#### 3.2.15 Other matters of regulatory interest

##### Public Information Program

OPG continued regular communications about the Pickering site to engage residents and stakeholders and inform them about the facilities. CNSC staff determined that OPG met the regulatory requirements applicable to public information and disclosure and provided sufficient information on the status of the Pickering site through a variety of communication activities, including community events, facility tours, ongoing website updates and the use of social media.

###### Pickering Nuclear Generating Station

In the fall of 2017, OPG hosted a series of open houses ahead of its licence renewal to generate discussion about the future of the PNGS, gauge the clarity of messaging and clarify any misconceptions about the PNGS.

###### Pickering Waste Management Facility

In the record of decision for the 2017 licence renewal of the PWMF, the Commission encouraged OPG to make data available to the general public on contaminants of potential concern. CNSC staff confirmed that OPG has made that information available to the general public on its website.

##### Indigenous relations

CNSC staff noted that OPG has a dedicated Indigenous engagement program. Throughout 2017, OPG met and shared information with interested Indigenous communities and organizations, particularly the Williams Treaties First Nations, the Mohawks of the Bay of Quinte and the Métis Nation of Ontario. Information and discussion topics included OPG’s current operations at the Pickering site, the PWMF licence renewal, the PNGS licence renewal application, fish impingement and entrainment, procurement, employment and training opportunities, environmental protection and performance, and monitoring program results.

### 3.3 Point Lepreau

The safety assessment for each safety and control area (SCA) is facility-specific. General information relevant to the SCAs is provided in section 2. The CNSC regulatory documents and CSA Group standards that were identified as regulatory requirements for the Point Lepreau site as of December 2017 are listed in appendix E.

Overall safety assessment

The CNSC staff safety assessment of the Point Lepreau site (which includes the Point Lepreau Nuclear Generating Station and the Solid Radioactive Waste Management Facility (SRWMF)) for 2017 resulted in the performance ratings shown in table 19. Based on the observations and assessments of the SCAs, CNSC staff concluded that Point Lepreau operated safely. The overall rating was “satisfactory,” unchanged from the integrated plant rating from the previous year.

Table 19: Performance ratings for Point Lepreau, 2017
Safety and control area Rating *
Management system SA
Human performance management SA
Operating performance SA
Safety analysis FS
Physical design SA
Fitness for service SA
Conventional health and safety FS
Environmental protection SA
Emergency management and fire protection SA
Waste management SA
Security SA
Safeguards and non-proliferation SA
Packaging and transport SA
Overall rating SA

Legend:

• FS – Fully satisfactory
• SA – Satisfactory
• BE – Below expectations
• UA – Unacceptable

* Also applies to the SRMWF

#### 3.3.0 Introduction

The Point Lepreau Nuclear Generating Station (Point Lepreau or PLNGS) is located on the Lepreau Peninsula, 40 kilometres southwest of Saint John, New Brunswick. It is owned and operated by New Brunwick Power Corporation (NB Power) and consists of a single CANDU reactor with a rated capacity of 705 megawatts electrical (MWe). The Point Lepreau site includes the SRWMF located a short distance from the power reactor within the exclusion zone. The waste storage process includes short-term storage in the reactor building prior to being transferred for long-term storage at the SRWMF. The SRWMF is used for the storage of solid radioactive waste, including spent nuclear fuel produced solely at Point Lepreau. The CNSC regulates the station and the SRWMF under a single power reactor operating licence (PROL).

The assessments in this section apply equally to the PLNGS and the SRWMF, unless noted otherwise. The information presented below for each SCA is station-specific; general information is provided in section 2.

##### Licensing

In June 2016, NB Power applied to have its PROL renewed References 17 for a period of five years. Part 1 of the Commission hearing was held on January 26, 2017, and Part 2 was held on May 10 and 11, 2017. In June 2017, the Commission issued a new PROL for a period of five years authorizing NB Power to operate the PLNGS and SRWMF until June 30, 2022. The PROL has not been amended since it was granted.

##### Licence conditions handbook

CNSC staff issued a new licence conditions handbook (LCH) when the PROL was issued on June 30, 2017. It had not undergone any revisions as of the end of 2017.

##### Periodic safety review

With the introduction of periodic safety reviews (PSRs) to the CNSC regulatory framework, CNSC staff recommended a five-year operating licence to provide adequate time for NB Power to complete a PSR in accordance with CNSC REGDOC-2.3.3, Periodic Safety Reviews. Licence condition 3.4 of the licence, in conjunction with the LCH, requires NB Power to perform a PSR in accordance with REGDOC-2.3.3. NB Power submitted a high-level project execution plan and a PSR basis document in support of a 10-year licensing period, from 2022 to 2032.

UPDATE: Following a sufficiency check of the PSR basis document that revealed a few missing elements, NB Power submitted a revised and updated version of the document on March 15, 2018. CNSC staff were reviewing the PSR basis document with a target completion date of July 31, 2018. NB Power will submit the safety factor reports in 2018 and early 2019. CNSC staff will review the PSR deliverables to gain confidence in the safety case for the continued operation of PLNGS.

##### Fisheries Act authorization

In April 2016, NB Power submitted, for CNSC staff’s review, a preliminary self-assessment of serious harm to fish due to cooling-water intake, in accordance with the Fisheries Act. CNSC staff reviewed the assessment and met with NB Power to discuss the additional information needed.

NB Power provided a revised self-assessment under the Fisheries Act to the CNSC in January 2017. CNSC staff completed its technical review of the self-assessment and concluded that authorization was required under subsection 35(1) of the Fisheries Act. The conclusions were shared with Fisheries and Oceans Canada, which concurred with CNSC’s recommendation.

UPDATE: NB Power provided a partial draft application under the Fisheries Act to the CNSC on March 27, 2018 prior to final submission. CNSC staff reviewed the draft application for technical completeness and provided comments to NB Power on April 26, 2018. NB Power was on target to submit a complete draft to CNSC for review by December 2018.

##### Event initial reports

No event initial reports pertaining to Point Lepreau were submitted to the Commission for the period from January 1, 2017 to June 1, 2018.

##### Compliance program

The annual CNSC effort on the compliance program is tabulated in appendix G for Point Lepreau. The inspections at the Point Lepreau site that were considered in the safety assessments for this regulatory oversight report are presented in appendix J.

#### 3.3.1 Management system

CNSC staff concluded that the management system SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

##### Management system

CNSC staff determined that NB Power’s management system at Point Lepreau met the applicable regulatory requirements in 2017. NB Power has successfully implemented the 2012 version of CSA Group standard N286-12, Management system requirements for nuclear facilities. In 2017, CNSC staff verified the actions taken as a result of the gap analysis NB Power conducted against the 2005 version of N286 and determined that NB Power’s disposition of the gap was satisfactory.

##### Organization

CNSC staff determined that NB Power had an adequately defined organizational structure, roles and responsibilities at Point Lepreau. As a result of regulatory oversight, CNSC staff were satisfied with NB Power’s performance in this specific area.

##### Change management

CNSC staff determined that NB Power had an adequate change management program that complied with the applicable regulatory requirements. As a result of regulatory oversight, CNSC staff were satisfied with NB Power’s performance in this specific area.

##### Safety culture

CNSC staff were satisfied that NB Power continued to foster a healthy safety culture at Point Lepreau in 2017. In 2016, a safety culture self-assessment was undertaken. CNSC will monitor OPG’s next safety culture self-assessment at Point Lepreau, scheduled for 2019, and any improvement actions initiated.

##### Configuration management

NB Power kept the configuration of its structures, systems and components (SSCs) compliant with its configuration management program and regulatory requirements. This was confirmed during the CNSC plant outage inspections and field inspections conducted in 2017.

##### Records management

CNSC staff determined that NB Power continued to maintain and implement a document control and records management system that meets the applicable requirements.

Following a CNSC inspection of chemistry control in September 2017, NB Power initiated a corrective action plan for the chemistry process documentation. NB Power plans to complete all corrective actions by the end of September 2018. CNSC staff were satisfied with the progress.

##### Management of contractors

CNSC staff conducted an inspection in 2015 to verify that procedures and processes were in place for contractor management and effectively implemented, in accordance with CSA Group standard N286-05, Management system requirements for nuclear power plants. CNSC staff identified non-compliance related to the oversight of contractors and the documentation of performance evaluations. CNSC staff continued to verify the implementation of the NB Power’s corrective action plans and in 2017 confirmed that all actions were complete and satisfactory.

CNSC staff concluded that NB Power met the applicable regulatory requirements for business continuity.

NB Power had adequate contingency plans (such as the emergency response plan and the pandemic response plan) to maintain or restore critical business functions in the event of disabling circumstances (such as a pandemic, severe weather or labour action) References 17.

##### Problem identification and operating experience

CNSC staff determined that NB Power continued to meet the applicable regulatory requirements for problem identification and OPEX. As a result of regulatory oversight, CNSC staff were satisfied with NB Power performance in this specific area.

##### Performance assessment, improvement and management review

CNSC staff confirmed that NB Power met the applicable regulatory requirements for performance assessment, improvement, and management review.

In 2017, CNSC staff conducted a desktop review of the independent assessment program which allows NB Power to independently evaluate the performance and effectiveness of activities, programs, processes and work to compare actual results with expected results. CNSC staff were satisfied with the implementation of this program and are currently monitoring NB Power’s endeavour for continuous improvement in this area.

#### 3.3.2 Human performance management

CNSC staff concluded that the human performance management SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

##### Human performance program

CNSC staff determined that the NB Power human performance program met the applicable requirements. In 2017, compliance activities did not identify any deviations from regulatory requirements.

##### Personnel training

NB Power had a well-documented and robust training system based on a systematic approach to training (SAT). The implementation of this system for the training programs at Point Lepreau met the applicable regulatory requirements.

In 2017, CNSC staff inspected the non-licensed operator training program. CNSC staff found that the training program was defined and documented in accordance with NB Power’s SAT-based training system. A minor procedural point of non-compliance of low safety significance was identified with respect to the accessibility of continuing training records. CNSC staff were satisfied with NB Power’s progress to address the non-compliance.

##### Personnel certification

CNSC staff determined that NB Power’s personnel certification program met the applicable regulatory requirements. CNSC staff reviewed the staffing reports for certified personnel, and the applications for initial certification and renewal of certification. They confirmed that certified personnel at Point Lepreau possessed the knowledge and skills required to perform their duties safely and competently.

##### Initial certification examinations and requalification tests

In 2017, CNSC staff inspected the conduct of both simulator-based initial certification examinations for shift supervisors and written certification examinations. A point of non-compliance of low safety significance related to simulator modelling capabilities was observed by the CNSC staff during the simulator-based initial certification examinations. At the request of CNSC staff, NB Power provided a corrective action plan and strategies for the short, medium and long terms that were being implemented to improve the simulator modelling. CNSC staff were reviewing the submission.

With the exception of the deficiency mentioned above, CNSC staff concluded that the initial certification examination and requalification testing programs for certified personnel at Point Lepreau met the applicable regulatory requirements.

##### Work organization and job design

The minimum shift complement at Point Lepreau met the applicable regulatory requirements.

UPDATE: In March 2018, CNSC staff approved a request by NB Power to modify the minimum shift complement requirements. The change consisted of replacing the requirement for a mechanical maintainer with one for an electrical instrumentation and control maintainer. CNSC staff found the request acceptable.

In 2017, one violation of the minimum shift complement was reported to the CNSC at Point Lepreau; it had no impact on safety.

##### Fitness for duty

CNSC staff determined that NB Power met the applicable regulatory requirements for fitness for duty at Point Lepreau.

As part of its fitness-for-duty provisions, NB Power developed procedures that limit the hours worked by staff. In quarterly reports submitted in the past year to CNSC, NB Power reported that its certified staff was fully compliant with the limits on hours of work at Point Lepreau.

In 2017, CNSC staff completed a desktop review to verify the accuracy of reporting of non-compliance with the limits of hours of work for certified staff. The desktop review confirmed that NB Power’s reporting was accurate and it made two recommendations.

CNSC staff were satisfied with NB Power’s phased implementation plan for CNSC REGDOC-2.2.4 Fitness for Duty Volume I: Managing Worker Fatigue. NB Power committed to fully implementing the regulatory document by June 30, 2022.

In late 2017, CNSC staff requested that NB Power submit an implementation plan for CNSC REGDOC-2.2.4 Fitness for Duty, Volume II: Managing Alcohol and Drug Use with a supporting gap analysis.

UPDATE: NB Power submitted its implementation plan in early 2018; it committed to fully implementing the regulatory document by December 1, 2019. CNSC staff found the implementation date to be satisfactory.

#### 3.3.3 Operating performance

CNSC staff concluded that the operating performance SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

CNSC staff concluded that NB Power met the applicable regulatory requirements for the conduct of licensed activities at Point Lepreau. CNSC staff determined that NB Power continued to operate Point Lepreau in a safe and secure manner, with adequate regard for health, safety, security, radiation, environmental protection and international obligations. NB Power operated Point Lepreau within the bounds of its operating policies and principles, and its operational safety requirements.

In 2017, Point Lepreau experienced zero unplanned reactor trips, zero stepbacks and five setbacks (although the five setbacks were associated with only two separate events).

CNSC staff determined that the setbacks were controlled properly and that power reduction was adequately initiated by the reactor control systems. CNSC staff verified and confirmed that, for all events, NB Power staff followed approved procedures and took appropriate corrective actions.

##### Procedures

CNSC staff determined that the Point Lepreau procedures meet the applicable regulatory requirements.

CNSC staff continued to monitor the implementation of NB Power’s corrective action plan to address weaknesses identified in previous reporting periods in the areas of procedural adequacy and adherence. Although points of non-compliance had been identified during inspections in previous years, they did not present an immediate risk to the health and safety of persons or the environment. Overall, NB Power continues to improve and has made progress addressing these areas through training and process improvements. CNSC staff were satisfied with NB Power’s implementation of the improvements that were completed in 2017.

##### Reporting and trending

During the reporting year, all scheduled reports were adequate and submitted to CNSC in a timely manner. CNSC staff determined that reporting and trending at Point Lepreau met the applicable regulatory requirements and expectations in 2017. For instance, a CNSC desktop review determined that NB Power trends and reports hours of work to CNSC staff’s satisfaction.

##### Outage management performance

NB Power’s performance and achievement of objectives during maintenance outages was good.

NB Power completed a planned maintenance outage in 2017. CNSC staff performed a related inspection to verify NB Power’s compliance with the regulatory requirements associated with the outage and concluded that NB Power complied with the applicable regulatory requirements. In particular, CNSC staff determined that NB Power met both the maintenance requirements in the inspected areas of sub-criticality and the heat sink requirements during the outage.

CNSC staff found that NB Power’s outage management performance at Point Lepreau met the applicable regulatory requirements.

##### Safe operating envelope

CNSC staff determined that NB Power operated within the safe operating envelope (SOE) and met the applicable regulatory requirements for Point Lepreau. Minor SOE-related points of non-compliance were being addressed to the satisfaction of CNSC staff further to a November 2016 inspection finding concerning inconsistencies in SOE documentation.

##### Severe accident management and recovery

CNSC staff determined that severe accident management and recovery met the applicable regulatory requirements at Point Lepreau. NB Power submitted a preliminary implementation plan for CNSC REGDOC-2.3.2 Accident Management, version 2. CNSC staff were satisfied with NB Power’s plan to complete the full implementation by November 2020.

##### Accident management and recovery

CNSC staff completed the assessment of NB Power’s revision of its abnormal operating procedures and were satisfied with their implementation. Subsequently, CNSC staff closed the action item which had been open since 2014. NB Power continued to maintain an accident management and recovery program that meets the applicable requirements.

#### 3.3.4 Safety analysis

CNSC staff concluded that the safety analysis SCA at Point Lepreau met or exceeded the performance objectives and applicable regulatory requirements. As a result, the station received a “fully satisfactory” rating, unchanged from the previous year.

##### Deterministic safety analysis

The deterministic safety analysis predicted adequate safety margins and met or exceeded the applicable regulatory requirements at Point Lepreau.

CNSC staff determined that NB Power has a well-established program for deterministic safety analyses. NB Power continued to implement CNSC REGDOC-2.4.1 Deterministic Safety Analysis. NB Power submitted a detailed, thorough methodology for identifying and prioritizing areas in which the current safety report could be updated to align with REGDOC-2.4.1. CNSC staff were satisfied with NB Power’s submission and progress leading up to full compliance. The implementation plan will be revised in 2018 to fully describe the second phase of the implementation.

In June 2016, NB Power submitted an updated version of the Point Lepreau safety report to the CNSC. This version included new sections on probabilistic safety assessments (PSAs), fire hazards and severe accident management guidelines. CNSC staff completed the review of the safety report in early April 2017 and determined that it meets requirements.

Point Lepreau submitted the updated fire hazard analysis (FHA) and fire safe shutdown analysis (FSSA) in August 2017. CNSC staff determined that the approach and methodology were consistent with the applicable regulatory requirements. In December 2017, NB Power proposed to change the date for the next submission of both the FHA and FSSA. Given that the documents were updated and submitted to the CNSC in August 2017, CNSC staff accepted NB Power’s proposal for the next five-year submission in 2022, in lieu of the previous deadline of 2019.

UPDATE: CNSC is completing its review of the updated interim submission in 2018.

##### Probabilistic safety assessment

The second PSA update was submitted in 2016. The next PSA update is expected in 2021.

The CNSC found that NB Power’s performance in the area of PSAs met or exceeded the applicable regulatory requirements in 2017.

##### Criticality safety

This specific area does not apply to Point Lepreau.

##### Severe accident analysis

NB Power has updated the beyond-design-basis accident analysis for an event involving a loss of coolant with a loss of emergency core cooling. CNSC staff concluded that NB Power exceeded expectations in severe accident analysis due to this improvement. Based on regulatory oversight, CNSC staff were fully satisfied with NB Power’s performance in this specific area

##### Management of safety issues (including R&D programs)

NB Power’s R&D activities are reported to the CNSC through annual reporting in accordance with clause 3.6 of CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants. CNSC staff’s evaluations confirmed NB Power maintained a robust R&D capability to address any emerging issues. The remaining CANDU safety issues did not present a regulatory concern with regard to the safety of the operating reactor. Further information is provided in section 2.4.

The following supporting R&D project is currently ongoing:

Moderator subcooling requirements methodology

NB Power submitted the conclusion of a review, by a safety analysis issue review panel, of the experimental results from the CNSC-sponsored calandria tube strain contact boiling project. These experiments were done at Canadian Nuclear Laboratories’ facilities, under a contract with the CNSC. CNSC staff issued an interim report summarizing the results of the experiments and an evaluation of the results. NB Power plans to address the outstanding issues over the next licensing period. This issue was considered to be of low safety significance, because it addressed safety margins during postulated severe accidents having a low probability of occurrence.

#### 3.3.5 Physical design

CNSC staff concluded that the physical design SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

##### Design governance

CNSC staff concluded that NB Power continued to meet the applicable regulatory requirements and expectations regarding design governance in 2017.

Environmental qualification

The environmental qualification program was implemented and maintained in accordance with CSA Group standard N290.13-05, Environmental Qualification of Equipment for CANDU Nuclear Power Plants.

Human factors in design

NB Power completed the implementation of CSA Group standard N290.12-14, Human factors in design for nuclear power plants at Point Lepreau in 2017.

Fire protection

As the Point Lepreau site includes the SRWMF, NB Power submitted its implementation plan for CSA Group standard N393, Fire protection for facilities that process, handle, or store nuclear substances in September 2017. NB Power committed to complying with the standard by March 2022. CNSC staff were satisfied with NB Power’s progress and will continue to monitor the implementation.

##### Site characterization

CNSC staff had no significant observations at Point Lepreau to report in this specific area for 2017.

##### Facility design

CNSC staff had no significant observations at Point Lepreau to report in this specific area for 2017.

##### Structure design

CNSC staff concluded that the structure design specific area continued to meet the applicable regulatory requirements. As a result of regulatory oversight, CNSC staff were satisfied with NB Power’s performance in this specific area.

##### System design

CNSC staff concluded that system design at Point Lepreau met the applicable requirements.

Electrical power system

In 2017, CNSC staff conducted desktop reviews and followed up on a previous electrical power system (EPS) inspection conducted in 2011. Based on these compliance activities, no major issues were found. CNSC staff planned to perform an inspection in September 2018. CNSC staff concluded that the EPS at Point Lepreau met the applicable regulatory requirements in 2017.

Fire protection design

NB Power complied with the applicable regulatory requirements based on the results of CNSC’s ongoing compliance activities, including field inspections, independent third party reviews for design modifications and inspections of facility conditions.

Independent third party reviews submitted for design modifications were acceptable and no major findings were made.

The level of compliance was satisfactory and NB Power continued to implement a comprehensive fire protection program at Point Lepreau in accordance with CSA Group standard N293, Fire protection for nuclear power plants.

Instrumentation and control

No safety significant events were reported to CNSC in this specific area. As a result of regulatory oversight, CNSC staff were satisfied with NB Power’s performance for this specific area.

##### Component design

In 2017, CNSC staff concluded that NB Power met the applicable regulatory requirements for component design at Point Lepreau.

Fuel design

CNSC staff determined that NB Power had a mature reactor fuel inspection program. CNSC staff reviewed the annual fuel report (AFR) and concluded that it was consistent with those from previous years. Based on this review, CNSC staff determined that fuel performance at Point Lepreau was acceptable in 2017 and that NB Power’s fuel inspection program, for which its inspections are reported to the CNSC through the AFR, was satisfactory. CNSC staff noted that the defect rate at Point Lepreau was above the industry target by one defect per unit, per year. NB Power was able to adequately manage fuel performance issues while maintaining safe operations.

Cables

In 2017, there were no major issues found during compliance verification activities for cables related to component design.

During an inspection in 2011, CNSC staff identified non-compliance in the cable condition monitoring program. As of 2017, NB Power’s corrective actions were acceptable to CNSC staff. The next update on the implementation of remaining corrective actions will be provided to the CNSC by June 2018, following the 2018 planned outage. CNSC staff were satisfied with NB Power’s progress.

CNSC staff concluded that the cable management program at Point Lepreau met the applicable regulatory requirements.

##### Facility design

CNSC staff concluded that the facility design specific area continued to meet the applicable requirements. As a result of regulatory oversight, CNSC staff were satisfied with NB Power performance in this specific area.

#### 3.3.6 Fitness for service

CNSC staff concluded that the fitness for service SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

##### Equipment fitness for service and equipment performance

CNSC staff determined that the overall equipment fitness for service and performance at Point Lepreau was satisfactory and met the applicable regulatory requirements.

NB Power has procedures to monitor the fitness for service of equipment to support continued safe operation. CNSC staff have verified the adequacy of these procedures. NB Power has implemented, to the satisfaction of CNSC staff, the corrective actions identified from a previous inspection in 2016.

Reliability of systems important to safety

CNSC staff determined that the reliability program at Point Lepreau met the applicable regulatory requirements. All special safety systems for Point Lepreau met their unavailability targets in 2017.

##### Maintenance

In 2017, CNSC staff determined that the maintenance program met the applicable regulatory requirements at Point Lepreau.

In 2015, CNSC staff conducted a reactive inspection and identified non-compliance relating to NB Power’s system health monitoring process. CNSC staff continued monitoring NB Power’s progress in implementing the corrective actions in 2017.

UPDATE: NB Power completed the corrective actions in January 2018 to CNSC staff’s satisfaction.

The average preventive maintenance completion rate at the Point Lepreau NGS was 95 percent, which compared favourably with the industry average of 88 percent. The maintenance backlogs, for which data is provided in table 20, were acceptable.

Table 20: Trend of maintenance backlogs and deferrals for critical components at Point Lepreau, 2015 to 2017
Parameter Average quarterly work orders per unit Three-year trend Industry average
2015 2016 2017
Corrective maintenance backlog 1 1 2 stable 4
Deficient maintenance backlog 142 114 71 down 94
Deferrals of preventive maintenance 1 6 1 stable 30

As table 20 illustrates, the quarterly average number of work orders has been trending downward since 2015. In addition, the corrective maintenance backlog, deficient maintenance backlog and number of deferrals of preventive maintenance of critical components were all better than the industry averages.

CNSC staff determined that the overall safety significance of the maintenance backlogs and deferrals for critical components was negligible at Point Lepreau.

##### Structural integrity

CNSC staff concluded that the SSCs continued to meet the applicable structural integrity requirements at Point Lepreau.

In 2017, pressure boundary inspection results indicated that all inspected elements of the primary heat transport and auxiliary systems, steam generators, feeders and pressure tubes met the acceptance criteria in the applicable CSA Group standards.

##### Aging management

NB Power’s aging management program met the applicable regulatory requirements at Point Lepreau.

NB Power implemented CNSC REGDOC-2.6.3, Aging Management in July 2017. CNSC staff were reviewing NB Power’s aging management with a focus on fuel channels to ensure that it complies with REGDOC-2.6.3.

CNSC staff have confirmed that the lifecycle management plans for major components meet the basic requirements and provide an adequate basis for Point Lepreau’s periodic inspection plans.

CNSC staff determined that NB Power had adequate programs in place to confirm that fuel channels were fit for service for near-term operation. NB Power submitted engineering assessments of degradation mechanisms in accordance with the applicable requirements in the CSA Group standards.

NB Power implemented an aging management program for cables which led CNSC staff to close the related action notice in January 2017, as described in the component design specific area.

##### Chemistry control

CNSC staff inspected chemistry control in September 2017. While CNSC staff confirmed that Point Lepreau maintained system chemistry within the required parameters, they identified non-compliance of low safety significance relating to documentation.

UPDATE: NB Power acknowledged the points of non-compliance and committed to providing an update after it revises the appropriate documentation and implements it by October 31, 2018. CNSC staff were satisfied with NB Power’s progress.

##### Periodic inspections and testing

NB Power had a well-managed periodic inspection program (PIP) at Point Lepreau.

NB Power has provided an implementation plan for updating its PIP to comply with the 2014 version (update 1) of CSA Group standard N285.4, Periodic inspection of CANDU nuclear power plant components, as well as an implementation plan to comply with the 2013 version of CSA Group standard N285.5, Periodic inspection of CANDU nuclear power plant containment components. CNSC staff accepted the implementation plans and confirmed that both standards will be implemented, based on the gaps identified, by June 30, 2022. CNSC staff were satisfied with the plans and timelines and were monitoring NB Power’s progress.

NB Power has confirmed that the gap analyses for the N287 series of CSA Group standards will be carried out as part of the PSR comparison against modern codes and standards; this may lead to further updates to the reactor building management plan. CNSC staff were satisfied with NB Power’s progress implementing CSA Group standard N287.7, In-service examination and testing requirements for concrete containment structures for CANDU nuclear power plant components.

CNSC staff concluded that the radiation protection SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

##### Application of ALARA

NB Power continued to implement an effective and well-documented program that was based on industry best practices to keep doses as low as reasonably achievable (ALARA) at Point Lepreau. ALARA measures were integrated into planning, scheduling and work control. Point Lepreau met the applicable regulatory requirements with respect to ALARA.

##### Worker dose control

CNSC staff determined that NB Power continued to comply with the applicable regulatory requirements to measure and record doses received by workers at Point Lepreau. Routine compliance verification activities conducted in 2017 indicated that performance in the area of worker dose control at Point Lepreau was highly effective.

In 2017, radiation doses to workers were below the regulatory dose limits and action levels in the Point Lepreau radiation protection program. The data for doses to workers at Point Lepreau are provided in section 2.7.

There were no action level exceedances related to worker exposures (acute or annual exposures),  nor any unscheduled reports in this specific area in 2017.

CNSC staff did not observe any adverse trends or safety-significant, unplanned exposures due to the licensed activities at Point Lepreau in 2017. The maximum dose received by a worker at Point Lepreau in 2017 was 11.40 mSv, which is approximately 23% of the regulatory dose limit.

CNSC staff determined that NB Power implemented a radiation protection program at Point Lepreau that satisfied the requirements of the Radiation Protection Regulations. NB Power regularly measures the performance of its radiation protection program against industry-established objectives, targets and best practices. The oversight applied by NB Power in implementing and improving this program was effective for protecting workers at Point Lepreau in 2017.

CNSC staff determined that NB Power implemented radiological hazard controls that met or exceeded the applicable regulatory requirements. These measures protected workers and ensured that radioactive contamination was controlled within site boundaries.

NB Power continued to ensure measures remained in place to monitor and control radiological hazards. In 2017, no contamination control action levels were exceeded.

CNSC staff inspected radiological hazard control and confirmed compliance with the applicable regulatory requirements at Point Lepreau. CNSC staff also confirmed that NB Power’s initiatives for continuous improvement in this area were effectively implemented.

CNSC staff reviewed safety performance indicator reports on personnel and loose contamination events and confirmed that no safety-significant incidents were identified.

##### Estimated dose to the public

CNSC staff determined that NB Power continued to ensure the protection of members of the general public in accordance with the Radiation Protection Regulations. The reported doses to members of the general public from Point Lepreau were estimated at 0.0007 mSv, well below the annual dose limit of 1 mSv for a member of the general public (see section 2.7 for details).

#### 3.3.8 Conventional health and safety

CNSC staff concluded that the conventional health and safety SCA at Point Lepreau met or exceeded the performance objectives and applicable regulatory requirements. As a result, the station received a “fully satisfactory” rating, unchanged from the previous year.

##### Performance

CNSC staff determined that NB Power met or exceeded the applicable regulatory requirements at Point Lepreau regarding conventional health and safety performance. CNSC staff observed that the accident severity rate (ASR) for Point Lepreau remained at zero in 2017, unchanged from 2016. Accident frequency (AF) increased from 0.11 in 2016 to 0.33 in 2017 (see figures 11 and 12 in section 2.8 for additional data). The ASR and AF values at Point Lepreau were found to be acceptable by CNSC staff.

##### Practices

CNSC staff determined through quarterly field inspection that NB Power met or exceeded the applicable regulatory requirements at Point Lepreau in 2017 regarding practices for scaffolding and ladders, awareness for barriers and warning signs, personal protective equipment and housekeeping.

The conventional health and safety work practices and conditions at Point Lepreau continued to achieve a high degree of personnel safety. There continued to be a working environment where safe work practices were encouraged.

CNSC staff verified that NB Power had appropriate procedures at Point Lepreau to ensure the environment and the health of persons are protected against hazardous materials.

##### Awareness

In 2017, CNSC staff observed that the personnel at Point Lepreau remained sufficiently aware of conventional hazards in the workplace. CNSC staff confirmed that NB Power continued to meet or exceed the applicable regulatory requirements for awareness in 2017 at Point Lepreau. As a result of regulatory oversight, CNSC staff were satisfied with NB Power performance in this specific area.

#### 3.3.9 Environmental protection

CNSC staff concluded the environmental protection SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

##### Effluent and emissions control (releases)

CNSC staff reviewed the reported airborne and waterborne radiological releases from Point Lepreau in 2017 and confirmed that they remained below the regulatory limits. The releases are shown in figure 19 as percentages of the applicable derived release limits (DRLs). The actual values of releases and DRLs are provided in appendix I.

NB Power has committed to implementing CSA Group standard N288.5, Effluent monitoring programs at Class I nuclear facilities and uranium mines and mills by June 30, 2018.

Both CSA Group standards N288.8, Establishing and implementing action levels for releases to the environment from nuclear facilities and N288.3.4, Performance testing of nuclear air-cleaning systems at nuclear facilities will be reviewed and implemented as part of the PSR under prerequisites for comparison against modern codes and standards. The PSR as a whole will be completed in June 2021. The report for the radiological impact on the environment safety factor, which will include both of these standards, was planned for submission to the CNSC for review in the fall of 2018.

Figure 19 presents the airborne and waterborne radiological releases from Point Lepreau in 2017.

##### Environmental management system

NB Power has established and implemented a corporate-wide environmental management system in accordance with CNSC REGDOC- 2.9.1, Environmental Protection Policies, Programs and Procedures (2013) to assess environmental risks associated with its nuclear activities and to ensure that these activities are conducted in a way that prevents or minimizes adverse environmental effects.

NB Power was reviewing the 2017 version of CNSC REGDOC-2.9.1 under its PSR, which will be completed in June 2021, as part of the report for the radiological impact on the environment safety factor.

##### Assessment and monitoring

CNSC staff reviewed and assessed the NB Power environmental monitoring data and concluded that the general public and the environment in the vicinity of Point Lepreau were protected. NB Power met the applicable regulatory requirements for 2017.

NB Power has aligned its radiation environmental monitoring program with CSA Group standard N288.4-10, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills.

NB Power has committed to implementing CSA Group standard N288.7, Groundwater protection programs at Class I nuclear facilities and uranium mines and mills by December 30, 2020.

CNSC staff conducted independent environmental monitoring program (IEMP) work around the Point Lepreau site in 2017 (see section 2.9 for details). The results are available on the CNSC’s IEMP webpage. The IEMP results indicate that the general public and the environment in the vicinity of Point Lepreau site were protected and that there were no expected health impacts.

##### Protection of the public

No hazardous substances released from Point Lepreau exceeded the applicable regulatory limits. Dose to the public is discussed in section 2.7.

##### Environmental risk assessment

CNSC staff determined that NB Power continued to implement and maintain an effective environmental risk assessment and management program at the Point Lepreau site in accordance with the applicable regulatory requirements.

In January 2017, NB Power submitted a revised environmental risk assessment (ERA) report, based on effluent and environmental monitoring data from 2007 (pre-refurbishment) and the three-year period between 2013 and 2015 (post-refurbishment). The ERA included an ecological risk assessment and a human health risk assessment for radiological and/or what are considered non-radiological (hazardous) chemicals of potential concern and physical stressors to the environment.

CNSC staff completed a detailed technical review of the 2017 ERA and found the methodology to be consistent with the applicable requirements. Overall, significant adverse ecological and human health effects from physical stressors and radiological or non-radiological releases from Point Lepreau were unlikely.

Future revisions to the ERA will include an assessment of the magnitude and extent of the thermal plume from discharged cooling water and a broad risk assessment of its effect on the inter-tidal and near-surface zones. Additional assessment of the potential ecological and human health effects from the releases of non-radiological (hazardous) chemicals of potential concern will also be included in future revisions to the ERA.

NB Power committed to implementing CSA Group standard N288.6-12, Environmental risk assessments at Class I facilities and uranium mines and mills by June 30, 2020.

#### 3.3.10 Emergency management and fire protection

CNSC staff concluded that the emergency management and fire protection SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

##### Conventional emergency preparedness and response

NB Power maintained and continued to support comprehensive, conventional emergency response capability at all times at Point Lepreau. This included personnel and equipment for medical situations and events involving hazardous material (HAZMAT), search and rescue and fire response.

CNSC staff concluded that NB Power’s conventional emergency preparedness and response met the applicable regulatory requirements in 2017.

##### Nuclear emergency preparedness and response

CNSC staff determined that NB Power maintained and continued to support comprehensive nuclear emergency preparedness and response capability at all times that met the applicable regulatory requirements. NB Power continued to support offsite emergency management organizations and commitments.

NB Power planned to be fully compliant with version 1 of CNSC REGDOC-2.10.1, Nuclear Emergency Preparedness and Response in 2018.

UPDATE: In April 2018, CNSC confirmed that NB Power complied with REGDOC‑2.10.1, version 1.

CNSC staff requested that NB Power prepare an implementation plan to share plant data information with the CNSC during an emergency. CNSC staff reviewed NB Power’s implementation plan and found it to be acceptable. NB Power submitted a status update on the implementation of the plan on November 23, 2017; CNSC staff were reviewing it at the end of 2017.

In November 2017, NB Power provided the detailed design documentation for the new Offsite Emergency Operations Centre. CNSC staff began their review in 2017.

In October 2018, NB Power planned to conduct a full-scale (two-day) nuclear emergency exercise named Synergy Challenge 2018 at the Point Lepreau site, in partnership with the NB Emergency Measures Organization and stakeholders. The objectives of Synergy Challenge 2018 were to test the overall emergency response capabilities of the participating organizations, with an emphasis on the recovery phase.

##### Fire emergency preparedness and response

Through the licensing and compliance activities performed, CNSC staff determined that NB Power maintained comprehensive fire response capability and a fire protection program that met the applicable regulatory requirements.

NB Power has an extensive fire drill and training program that includes a training facility at the Point Lepreau site where live fire training is conducted.

In addition to CNSC compliance activities, NB Power conducts expert third party reviews (TPRs) that cover an annual plant condition inspection, bi-annual fire drill audit and tri-annual fire program audit.

By incorporating the results of the CNSC compliance findings and TPR observations and recommendations into the drill and training program, the emergency response team’s performance continued to improve.

#### 3.3.11 Waste management

CNSC staff concluded that the waste management SCA at Point Lepreau and at the SRWMF met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

##### Waste characterization

CNSC staff determined that NB Power’s waste characterization met the applicable regulatory requirements. NB Power continued to employ effective programs for the characterization of radioactive and hazardous wastes throughout 2017. As a result of regulatory oversight, CNSC staff were satisfied with NB Power performance in this specific area.

##### Waste minimization

CNSC staff determined that NB Power’s waste management programs for minimizing radioactive waste met the applicable regulatory requirements. As a result of regulatory oversight, CNSC staff were satisfied with NB Power’s performance in this specific area.

##### Waste management practices

CNSC staff determined that NB Power’s waste management practices met the applicable regulatory requirements.

NB Power completed a gap analysis and the implementation plan for CSA Group standard N292.0-14, General principles for the management of radioactive waste and irradiated fuel. NB Power planned to comply with this standard by July 2018. In September 2017, NB Power sent confirmation to the CNSC that the implementation of CSA Group standard N292.3-14, Management of low- and intermediate-level radioactive waste was complete. CNSC staff were satisfied with the progress and continued to monitor NB Power’s implementation of both standards.

###### Solid Radioactive Waste Management Facility (SRWMF)

The Point Lepreau site includes the SRWMF. The SRWMF is located within the exclusion area of the Point Lepreau NGS and comprises the Phase I, II and III sites which provide the storage of solid radioactive material produced in the operation of PLNGS. The following is a description of each phase:

• Phase I of the facility is used to store operational waste.
• Phase II is a dry storage facility for spent fuel.
• Phase II Extension provides an additional area prepared in 2006 to allow for the dry storage of spent fuel. Approval is required prior to commissioning and use in accordance with licence condition 15.2 of the current PROL.
• Phase III of the facility stores waste from retubing and other operations completed during the refurbishment outage.

As the SRWMF is located a short distance from the station at the Point Lepreau site, waste must be transported from the station to the facility. CNSC regulatory oversight activities concerning these waste transfers concluded that NB Power had demonstrated consistent and compliant management and control of waste handling and storage, and it has taken the necessary measures to operate the SRWMF safely, meeting all the applicable regulatory requirements.

In 2017, CNSC staff completed a field inspection at the SRWMF. This inspection found minor issues of low safety significance (e.g., graffiti posted on a canister, radiation transport placards present on an empty shipping container and radiation stickers on yellow containers that did not contain any information) that were addressed by NB Power to the satisfaction of CNSC staff.

CNSC staff had conducted an inspection with a focus on waste management practices in April 2016. During this inspection, CNSC staff confirmed that NB Power complied with the regulatory requirements; however, they identified non-compliance relating to the protection from the elements of the fuel canister sampling valves. In February 2017, NB Power developed and implemented a corrective action plan to address the non-compliance to CNSC staff’s satisfaction.

The PROL (licence condition 15.4) requires NB Power to submit a quarterly report on the SRWMF. CNSC staff reviewed all reports and additional information submitted for 2017 and were satisfied with NB Power’s submissions.

CNSC staff confirmed that NB Power took the necessary measures to operate the SRWMF safely and met all the applicable regulatory requirements.

##### Decommissioning plans

The preliminary decommissioning plan (PDP) for Point Lepreau met the applicable regulatory requirements in 2017. The associated financial guarantee is discussed in section 3.3.15.

In September 2017, NB Power submitted its implementation plan for CSA Group standard N294-09, Decommissioning of facilities containing nuclear substances. NB Power committed to complying with the standard by February 2018. CNSC staff were satisfied with the progress.

#### 3.3.12 Security

CNSC staff concluded that the security SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

##### Facilities and equipment

CNSC staff determined that NB Power met the applicable regulatory requirements for facilities and equipment. NB Power continued to sustain security equipment through lifecycle management at Point Lepreau.

Cyber security

NB Power maintains a cyber security program at Point Lepreau. No cyber security events were reported in 2017.

CNSC staff conducted an inspection in 2017 with a focus on cyber security, and identified points of non-compliance of low safety significance. NB Power submitted a corrective action plan to address the identified non-compliance. CNSC staff were satisfied with the proposed actions and were monitoring progress.

NB Power was updating the cyber security program at Point Lepreau to comply fully with CSA Group standard N290.7-14, Cyber security for nuclear power plants and small reactor facilities by December 31, 2019. CNSC staff were satisfied with the progress.

CNSC staff concluded that there were no safety-significant issues in this area.

##### Response arrangements

CNSC staff determined that NB Power met the applicable regulatory requirements for response arrangements at Point Lepreau.

In 2017, CNSC staff measured the effectiveness of this area through a force-on-force security exercise evaluation and a field inspection. NB Power addressed deficiencies related to training techniques and to improving management oversight and procedural rigour that were identified in the exercise report and began implementing corrective action plans.

The areas for improvement identified in the field inspection report were resolved by NB Power in a timely manner.

Based on the review of the reports, CNSC staff concluded that NB Power complied with the applicable regulatory requirements. CNSC staff concluded that there were no safety-significant issues in the area of response arrangements.

##### Security practices

CNSC staff determined that NB Power implemented security practices at Point Lepreau that met the applicable regulatory requirements.

CNSC staff inspected NB Power’s Security Program in 2017. CNSC staff determined that there were adequate procedures in place; however, staff identified instances of non-compliance with procedures relating to access to the protected area. NB Power took appropriate corrective action to address the non-compliance in a timely manner, to CNSC staff’s satisfaction.

There were no safety-significant findings in this specific area. CNSC staff continued to monitor and review reportable events related to deviations from security procedures at Point Lepreau.

NB Power intended to meet the new requirements for security screening once the CNSC had updated REGDOC-2.12.2, Site Access Security Clearance.

##### Drills and exercises

CNSC staff determined that NB Power’s exercise and drill program met the applicable regulatory requirements.

In 2017, NB Power continued to improve its drill and exercise program and performed those activities at an acceptable level. NB Power met all the applicable regulatory requirements in this specific area. Further, NB Power resolved the area for improvement identified through one of the exercises.

As a result of findings made during compliance verification activities, CNSC staff concluded that elements of the drill and exercise program needed to address the areas for improvement outlined in the exercise report. NB Power provided an implementation plan to address several findings that were made during the compliance activity. CNSC staff concluded that there were no safety significant issues in this specific area.

#### 3.3.13 Safeguards and non-proliferation

CNSC staff concluded that the safeguards and non-proliferation SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, the station received a “satisfactory” rating, unchanged from the previous year.

##### Nuclear material accountancy and control

CNSC staff confirmed that NB Power’s accountancy and control of nuclear material at Point Lepreau complied with the applicable regulatory requirements in 2017. Based on their regulatory oversight, CNSC staff were satisfied with NB Power’s performance in this specific area.

##### Access and assistance to the IAEA

In 2017, CNSC staff confirmed that NB Power met the applicable regulatory requirements for access and assistance. NB Power granted adequate access and assistance to the International Atomic Energy Agency (IAEA) for safeguard activities, including inspections, equipment  maintenance and routine applications of seals at Point Lepreau.

In 2017, the IAEA performed one physical inventory verification, one short-notice random inspection and two unannounced inspections at Point Lepreau.

CNSC staff confirmed that NB Power met the applicable regulatory requirements for operational and design information for Point Lepreau.

NB Power submitted its annual operational program, with quarterly updates for Point Lepreau, and the annual update to the information pursuant to the IAEA Additional Protocol to the CNSC in a timely manner. The information that was provided met CNSC’s submission requirements.

##### Safeguards equipment, containment and surveillance

CNSC staff concluded that NB Power supported IAEA equipment operation and maintenance activities at Point Lepreau, including the maintenance and installation of surveillance equipment, to ensure the effective implementation of safeguards measures at the facility.

In September 2017, NB Power reported an event to the CNSC regarding the movement of a platform at the canister site at Point Lepreau. This resulted in the movement of an IAEA camera without prior notification to the IAEA. The IAEA subsequently confirmed that continuity of knowledge was maintained; therefore, there was no impact on safeguards implementation at the facility. CNSC staff were satisfied with the corrective actions taken by NB Power for this event. This event did not affect the overall rating of this SCA.

#### 3.3.14 Packaging and transport

CNSC staff concluded that the packaging and transport SCA at Point Lepreau met the performance objectives and applicable regulatory requirements. As a result, it received a “satisfactory” rating, unchanged from the previous year.

The transport of nuclear substances to and from the facility was conducted in a safe manner.

For onsite movement of nuclear substances, NB Power ensured a level of safety equivalent to that required for offsite transportation to protect the health and safety of workers, the general public and the environment.

##### Packaging design and maintenance, packaging and transport, and registration for use

CNSC staff determined that NB Power had a packaging and transport program at Point Lepreau that ensured compliance with the Packaging and Transport of Nuclear Substances Regulations, 2015 and the Transportation of Dangerous Goods Regulations.

No packaging and transport events were reported in 2017.

#### 3.3.15 Other matters of regulatory interest

##### Public information program

CNSC staff determined that NB Power met the applicable regulatory requirements related to information and disclosure in 2017. NB Power provided sufficient information on the status of Point Lepreau through a variety of communication activities. Prior to its 2017 licence renewal, NB Power hosted various information sessions in surrounding communities to discuss the licence renewal application.

##### Indigenous relations

CNSC staff observed that NB Power had a dedicated Indigenous engagement program. Throughout 2017, it met and shared information with interested Indigenous communities and organizations, particularly the Wolastoqey Nation in New Brunswick, Mi'gmawe'l Tplu'taqnn Incorporated, the Peskotomuhkati Nation at Skutik, the Sipekne’katik First Nation, the Union of New Brunswick Indians and Mawiw Council Inc. Information and discussion topics included NB Power’s current operations at Point Lepreau, application for Fisheries Act authorization, waste management, environmental monitoring, environmental and regulatory approval processes, education, cultural awareness and sensitivity.

##### Financial guarantees

In 2017, CNSC staff completed the review of NB Power’s 2015 annual update plan for the financial guarantees for Point Lepreau. CNSC staff concluded that the value of the funds was sufficient based on the revised estimates. As of March 31, 2017, the value of the financial guarantee was $689.7 million, which exceeded the required$567.8 million.

### 3.4 Bruce A and B

The safety assessment for each safety and control area (SCA) is facility-specific. General information relevant to the SCAs is provided in section 2. The CNSC regulatory documents and CSA Group standards that were identified as regulatory requirements for Bruce A and Bruce B, as of December 2017, are listed in appendix E.

Overall safety assessment

The safety assessment of Bruce A and B for 2017 resulted in the performance ratings shown in table 21. Based on the observations and assessments of the SCAs, CNSC staff concluded that Bruce A and B operated safely. The overall ratings were “fully satisfactory” for Bruce A and “satisfactory” for Bruce B; both were unchanged from the integrated plant ratings for the previous year.

Table 21: Performance ratings for Bruce A and B, 2017
Safety and control area Bruce A Bruce B
Management system SA SA
Human performance management SA SA
Operating performance FS FS
Safety analysis FS FS
Physical design SA SA
Fitness for service SA SA
Conventional health and safety FS SA
Environmental protection SA SA
Emergency management and fire protection SA SA
Waste management FS FS
Security SA SA
Safeguards and non-proliferation SA SA
Packaging and transport SA SA
Overall rating FS SA

Legend:

• FS – Fully Satisfactory
• SA – Satisfactory
• BE – Below Expectations
• UA – Unacceptable

#### 3.4.0 Introduction

Bruce A and Bruce B Nuclear Generating Stations are located on the shores of Lake Huron in the Municipality of Kincardine, Ontario. The facilities are operated by Bruce Power under a lease agreement with the owner, OPG.

Bruce A has four CANDU reactors (Units 1–4) with gross power of 831 megawatts electrical (MWe) each. Bruce B has four CANDU reactors (Units 5–8) with gross power of 872 MWe each. All eight units were operational throughout 2017.

This regulatory oversight report groups the two stations together, because Bruce A and B have one power reactor operating licence (PROL) and Bruce Power uses common programs at both stations. However, the performance of each station is assessed separately due to the differences in implementation of some programs at Bruce A and Bruce B.

The Western Waste Management Facility (WWMF) is also located at the same site. However, since it is operated by OPG under a different licence, it is assessed separately in section 3.5 of this regulatory oversight report.

Bruce Power also operates the Central Maintenance and Laundry Facility (CMLF) at the Bruce site. The CMLF handles nuclear substances associated with the maintenance of contaminated equipment and instruments, repair of contaminated suits and laundry of protective clothing. Since it operated under a different licence than Bruce A and B for much of 2017 (see next section), the general statements in the safety assessment of the Bruce site cannot be considered to apply to CMLF also.

##### Licensing

The PROL for Bruce A and B expires on May 31, 2020.

On July 1, 2017, the waste nuclear substances licence (WNSL) which authorizes the operation of the CMLF was revoked. The work authorized under the WNSL supports the licensed activities at Bruce A and B and is also authorized by the PROL. Therefore, no amendment to the PROL was necessary as a result of the WNSL revocation. Since the CMLF is a low-risk installation, a straightforward change was made to expand the Bruce licence condition handbook (LCH) to cover the ongoing operation of the CMLF, in addition to Bruce A and B. No amendments were made to the Bruce A and B PROL in 2017.

In June 2017, Bruce Power submitted a licence renewal application References 6 to the CNSC, two years prior to the expiry of the existing licence, in order to support the planning activities needed to refurbish Units 3–8 (such as defining the scope of the work). Bruce Power requested a licence period of ten years, which would encompass operation and activities related to the refurbishment (major component replacement (MCR) project).

UPDATE: Part 1 of the Commission hearing for the PROL renewal was conducted in March 2018 and Part 2 was conducted in May 2018.

##### Fisheries Act authorization

Bruce Power submitted a draft Fisheries Act authorization application to the CNSC in 2016. Based on feedback from the CNSC, Bruce Power submitted a revised application in May 2017, which CNSC staff shared with the interested Indigenous communities. CNSC staff completed a technical review and requested further information from Bruce Power on uncertainty analyses and details about methods for determining the fish biomass and monitoring. CNSC staff determined that Bruce Power made satisfactory progress with the Fisheries Act authorization application.

UPDATE: Bruce Power submitted a revised draft Fisheries Act authorization application to CNSC in May 2018. CNSC staff completed a sufficiency review of the draft application in August 2018 and deemed it to be sufficient, providing Bruce Power incorporated additional information requested by the CNSC and local Indigenous communities. As Crown consultation coordinator, CNSC staff requested comments on the draft application from the Historic Saugeen Métis, the Métis Nation of Ontario and the Saugeen Ojibway Nation. Bruce Power was consulting the Indigenous communities to adequately address their information requests in the final application. Bruce Power’s formal submission to DFO was expected later in 2018.

##### Periodic safety review

Bruce Power conducted a periodic safety review in support of the 2018 renewal of its PROL and the planned refurbishment of Units 3–8. Bruce Power developed an integrated implementation plan (IIP) which proposed safety improvements and included timeframes for implementation. CNSC staff accepted Bruce Power’s IIP in September 2017.

UPDATE: In 2018, Bruce Power submitted the first annual update to the IIP. CNSC staff’s review confirmed that nine of the IIP items were completed and that satisfactory progress was being made with the remainder of the actions.

##### Licence conditions handbook

Two revisions were made to the old Bruce licence conditions handbook (LCH) in 2017. One of the revisions was related to the revocation of the CMLF’s WNSL and the extension of the LCH to cover the activities governed by the WNSL. Appendix F shows a summary of the changes that were made to the LCH in 2017.

##### Refurbishment

The MCR project involves Units 3–8 and is slated to begin in 2020 with Unit 6. As noted above, Bruce Power completed the refurbishment of Units 1 and 2 in 2012. The MCR project includes replacing major components, such as the steam generators, fuel channels and feeders.

##### Event initial report

Three event initial reports (EIRs) pertaining to the Bruce site were submitted to the Commission for the period from January 1, 2017 to June 1, 2018. Details for these EIRs are provided in table 22.

Table 22: Event initial reports for Bruce A and B
Subject Brief description
Electrical shock to worker References 18

On March 27, 2017, a worker was injured while performing post-maintenance testing of a 13.8kV circuit breaker in Unit 5 at Bruce B, in accordance with the applicable procedure. The worker contacted the live portion of the circuit and received an electrical shock. Emergency plant personnel responded and treated the worker who was then sent to the Kincardine Hospital and later transferred to London Hospital’s burn unit.

All work crews at Bruce A and B were stood down until they had a face-to-face safety discussion with their managers. Bruce Power also put compensatory measures in place for all electrical work.

The Ministry of Labour (MOL) led the investigation of this event. As provided in the MOU with the MOL, CNSC staff assisted the MOL with its investigation. CNSC staff followed up on the event by reviewing numerous documents, inspecting the scene of the event and interviewing the licensee’s staff.

CNSC staff determined that Bruce Power’s corrective actions to prevent a re-occurrence of this issue were adequate.

CNSC staff conducted a reactive inspection to follow up on this event and found that work protection practices were needed to prevent a reoccurrence for this job. Also, CNSC staff determined that the responsible Bruce Power work group performing the post-maintenance testing had not implemented the requirements of the electrical safety program during the 2017 planned outage of Unit 5. Based on follow-up monitoring activities, CNSC staff concluded that the issues were addressed by Bruce Power.

Seal leak of primary heat transport system pump (Unit 3) References 19

On August 2, 2017, during the planned maintenance outage of Unit 3, a seal failure in pump 4 of the primary heat transport system resulted in a leak of heavy water outside of containment that caused a tritium airborne hazard in the area. As a precautionary measure, access to Bruce A was restricted to essential personnel and clean-up was performed by staff wearing appropriate personnel protective equipment (PPE). Some increased airborne tritium emissions occurred that were below Bruce Power’s action levels. The total dose attributed to this event for all workers was 1.72 mSv and the highest individual dose was 0.63 mSv, well below regulatory limits. CNSC staff confirmed that Bruce Power responded appropriately. The emissions were monitored and found to be below release limits, such that there was minimal safety impact on workers, the general public or the environment.

In response to a CNSC staff request, Bruce Power completed a root cause analysis of these failures since 2003. Bruce Power identified a number of common causes for the repeat events and probable causes for the Unit 3 event; however, it did not identify the specific root cause of the failure. Bruce Power developed a corrective action plan to address all of the probable causes.

Seal leak of primary heat transport pump (Unit 4). References 20

On March 4, 2018, while Bruce A Unit 4 was operating, indications of a potential problem were received in the control room and a unit shutdown was initiated. After shutdown was initiated, a leak developed on the gland seal of pump 4 of the primary heat transport system. The leak stopped when reactor pressure reached 3 MPa during reactor shutdown. However, five drums of heavy water leaked out of containment into a dyked area of the powerhouse, causing a tritium and loose contamination hazard in the area. As a precautionary measure, access to Bruce A was restricted to essential personnel and clean-up was performed by staff wearing appropriate PPE. The leak was contained in a dyked area.

##### Compliance program

The CNSC’s annual effort on the compliance program is tabulated in appendix G for Bruce A and Bruce B. The inspections at the Bruce site that were considered in the safety assessments in this regulatory oversight report are tabulated in appendix J.

#### 3.4.1 Management system

CNSC staff concluded that the management system SCA at Bruce A and B met the performance objectives and applicable regulatory requirements. As a result, each station received a “satisfactory” rating, unchanged from the previous year.

##### Management system

Bruce Power has implemented and complied with the requirements of CSA Group standard N286-05, Management system requirements for nuclear power plants. CNSC staff determined that Bruce Power’s management system documentation was adequate. CNSC staff continued to monitor Bruce Power’s implementation of CSA Group standard N286-12, Management system requirements for nuclear facilities, which was slated for completion by December 2018. CNSC staff were satisfied with the progress.

##### Organization

CNSC staff determined that Bruce Power had an adequately defined organizational structure and roles and responsibilities. At the end of 2017, no ongoing actions were identified as a result of regulatory oversight activities.

##### Change management

CNSC staff determined that Bruce Power had an adequate change management program that complied with the applicable regulatory requirements.

Bruce Power was providing annual progress updates on closing out the remaining design change packages related to the restart of Bruce Units 1 and 2, with an estimated completion date of 2019.

##### Safety culture

CNSC staff were satisfied that Bruce Power continued to foster a healthy safety culture at Bruce A and B in 2017. CNSC staff verified that the safety culture program at Bruce A and B met an established process for self-assessments of safety culture at planned intervals.

The last safety culture assessment undertaken at Bruce Power in 2016 included contractors; it was the first to integrate a self-assessment of the security culture. The CNSC will monitor Bruce Power’s next safety culture self-assessment, planned for 2019, and any improvement actions initiated.

##### Configuration management

Bruce Power maintained the configuration of its structures, systems, and components (SSCs) in compliance with its configuration management programs and regulatory requirements.

Bruce Power has a strategy to reduce the number of temporary configuration changes (TCCs). The CNSC confirmed that although TCCs at Bruce A continued to decrease, they were still above the target. TCCs at Bruce B did not exceed the target. CNSC staff will continue to monitor the implementation of the corrective actions to reduce the number of TCCs at both stations.

##### Records management

CNSC staff determined that Bruce Power continued to maintain and implement a records management system that complied with the applicable requirements. Bruce Power took corrective actions to improve in the area of completeness of records, where an issue was identified in 2017.

##### Management of contractors

CNSC staff confirmed in 2017 that the interfaces between Bruce Power and its contractors were planned, defined, controlled and understood in accordance with the applicable regulatory requirements.

In 2017, CNSC staff inspected the contractor management program and identified non-compliance of low risk significance relating to the qualifications of subcontractors, oversight of contractors that performed activities under Bruce Power’s management system and oversight of the contractors’ documentation. Bruce Power provided a corrective action plan that was to be completed in 2018. CNSC staff found this plan acceptable and were monitoring its implementation.

CNSC staff concluded that Bruce Power met the applicable regulatory requirements for business continuity.

Bruce Power had an adequate contingency plan to maintain or restore critical safety and business functions in the event of disabling circumstances, such as a pandemic, severe weather or labour action.

##### Problem identification and operating experience

CNSC staff determined that Bruce Power met the applicable regulatory requirements for problem identification and operating experience (OPEX).

In 2017, CNSC staff inspected the implementation of Bruce Power’s OPEX program, including its implementation by contractors. The inspection confirmed that Bruce Power identified and implemented OPEX from within its organization and from the Canadian and international nuclear industry.

In 2017, CNSC staff also inspected Bruce Power’s problem identification and resolution program and concluded that the root cause analysis and other methods of investigation met the applicable regulatory requirements.

##### Performance assessment, improvement and management review

CNSC staff confirmed that Bruce Power continued to meet the applicable regulatory requirements for performance assessment, improvement and management review. There were no significant observations to report in 2017.

#### 3.4.2 Human performance management

CNSC staff concluded that Bruce Power met the performance objectives and the applicable regulatory requirements for the human performance management in 2017. As a result, each station received a “satisfactory” rating unchanged from the previous year.

##### Human performance program

Through regulatory oversight, CNSC staff determined that Bruce Power had implemented and maintained a human performance program that met the applicable regulatory requirements. Bruce Power has implemented several initiatives such as “You Can Count on Me. Every Step. Every Time. Every Day.” which aimed to continuously improve human performance at Bruce A and B.  No ongoing actions were identified as result of regulatory oversight activities.

##### Personnel training

Bruce Power had a well-documented and robust training system based on a systematic approach to training (SAT). The implementation of this system for the training programs at Bruce A and B met the applicable regulatory requirements.

In 2017, CNSC staff inspected the training program for engineering division personnel. CNSC staff found that the training program was defined and documented in accordance with the Bruce Power SAT-based training system. A point of procedural non-compliance of low safety significance was identified with respect to linking engineering and training staff to the appropriate qualifications. CNSC staff were satisfied with Bruce Power’s prompt correction of this non-compliance.

##### Personnel certification

CNSC staff determined that Bruce Power’s personnel certification program met the applicable regulatory requirements. CNSC staff reviewed the staffing reports for certified personnel, the applications for initial certification and renewal of certification, and confirmed that certified personnel at Bruce A and B possessed the knowledge and skills required to perform their duties safely and competently.

##### Initial certification examinations and requalification tests

CNSC staff concluded that the initial certification examination and requalification testing programs for certified personnel at Bruce A and B met the applicable regulatory requirements.

In 2017, CNSC staff conducted compliance verification activities focused on the administration of simulator-based initial certification examinations at Bruce A and simulator-based requalification tests at Bruce B. Most of the findings generated recommendations for continuous improvement. CNSC staff observed some points of non-compliance of low safety significance during the design review of a simulator-based initial certification examination at Bruce A. CNSC staff noted that although Bruce Power had more than the minimum number of valid design features for a simulator-based certification examination, some of the additional design features provided did not meet the intent of the applicable regulatory requirements. Since the simulator-based certification examination met the minimum design requirements, these points of non-compliance did not impact the validity of the subject examination. Bruce Power implemented a corrective action plan to address these findings which was reviewed and found acceptable by CNSC staff.

In 2017, Bruce Power submitted its proposal to change the examination methodology for one of the required certification examinations to multiple-choice question format. CNSC staff reviewed Bruce Power’s proposal and accepted the use of the proposed format on a pilot basis for administering general certification examinations.

##### Work organization and job design

The minimum shift complement at Bruce A and B met the applicable regulatory requirements. Bruce Power had a workforce planning process in place to ensure that an adequate number of workers was maintained for Bruce A and B.

In 2017, Bruce A and B had four reportable events involving violations of minimum shift complement; all of them were promptly reported and deemed to have minimal to no impact on the safe operation of the stations (see section 2.2).

Bruce Power reported numerous hours-of-work violations in 2017. In order to reduce the non-compliance in meeting the minimum complement, Bruce Power put measures in place to prevent exceeding the limits on hours of work. For details on reducing the incidence of hours of work that exceed the limits, see the section on fitness for duty.

##### Fitness for duty

In 2017, Bruce Power exceeded the hours-of-work limits at Bruce A and B for certified staff on several occasions to maintain the minimum shift complement (62 at Bruce A and 59 at Bruce B). These exceedances, which were required to maintain a minimum shift complement, had a potential impact on worker fatigue and could have affected the performance of workers. Bruce Power’s efforts to prevent the likelihood of future hours-of-work violations were ongoing. CNSC staff will continue to monitor Bruce Power’s implementation of CNSC REGDOC-2.2.4, Fitness for Duty Volume I: Managing Worker Fatigue and progress in addressing the issue of worker fatigue.

As a result of non-compliance relating to limits on hours of work, in January 2017, CNSC staff performed a focused desktop review of fatigue management to determine whether Bruce Power had put measures in place to reduce the number of points of non-compliance and mitigate the effects of worker fatigue. CNSC staff identified findings of low significance specifically related to having a better-defined process for managing fatigue and strengthening requirements in procedures for preventing or mitigating the risk of fatigue-related errors. Based on CNSC staff findings, Bruce Power committed to revising its procedures and planned to incorporate the requirements of REGDOC-2.2.4. Bruce Power’s strategy to reduce hours-of-work exceedances was found acceptable to CNSC staff.

Bruce Power also committed to implementing CNSC REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use. Full implementation was expected by December 2019.

#### 3.4.3 Operating performance

CNSC staff concluded that the operating performance SCA at Bruce A and B met or exceeded the performance objectives and applicable regulatory requirements. As a result, each station received a “fully satisfactory” rating, unchanged from the previous year.

CNSC staff concluded that Bruce Power met or exceeded the applicable regulatory requirements for the conduct of licensed activities at both Bruce A and B. CNSC staff noted that Bruce Power continued to operate Bruce A and B in a safe and secure manner, with adequate regard for health, safety, security, radiation and environmental protection, and international obligations. Bruce Power operated both stations within the bounds of their operating policies and principles and operational safety requirements.

In 2017, Bruce A experienced two trips, no stepbacks and no setbacks. Bruce B experienced no trips, one stepback and six setbacks. All transients were controlled properly and power reduction was automatically initiated by the reactor control systems. There was no impact on reactor safety. CNSC staff confirmed that Bruce Power staff followed approved procedures and took appropriate corrective actions for all transients.

##### Procedures

CNSC staff determined that Bruce Power had well-defined processes for procedure preparation, review, validation, issuance and revision. The majority of the observations in this specific area for 2017 revealed compliance. CNSC staff were satisfied with the quality of the Bruce Power procedures and found that they met the applicable regulatory requirements.

##### Reporting and trending

During 2017, Bruce Power submitted 92 event reports to the CNSC in accordance with CNSC REGDOC 3.1.1, Reporting Requirements for Nuclear Power Plants. Two of the events resulted in EIRs as previously described in table 22, section 3.4. Bruce Power posted information on all event reports on its website.

All scheduled reports in 2017 were submitted to the CNSC in a timely manner and were adequate.

CNSC staff determined that the reporting and trending practices at Bruce A and B met or exceeded the applicable regulatory requirements and expectations in 2017.

##### Outage management performance

Bruce Power demonstrated good levels of performance and achievement of objectives during maintenance outages. In 2017, Bruce A experienced five forced outages among four reactors. Bruce B experienced six forced outages among four reactors (mostly at Unit 7). All forced outages were initiated by Bruce Power to perform repairs as required, mainly on service equipment that had malfunctioned unexpectedly.

In 2017, Bruce A had one planned outage and Bruce B had two planned outages. All planned and unplanned (forced) outages were followed up appropriately by Bruce Power. CNSC staff conducted inspections on all planned outages which confirmed that all outage-related undertakings, including reactor shutdown guarantees and heat sink management, were performed safely by Bruce Power.

CNSC staff found that Bruce Power’s outage management performance met or exceeded regulatory requirements and expectations in 2017.

##### Safe operating envelope

CNSC staff determined that Bruce Power operated within the safe operating envelope (SOE) and met the applicable regulatory requirements. Bruce Power continued to implement ongoing improvements of the SOE in 2017. CNSC staff were satisfied with the progress of SOE implementation at both stations.

##### Severe accident management and recovery

CNSC staff determined that severe accident management and recovery met the applicable regulatory requirements for Bruce A and Bruce B. Bruce Power demonstrated the effectiveness of severe accident management guidelines (SAMGs) through ongoing exercises and plant drills at both Bruce A and Bruce B. Updating the SAMGs to include counter-measures for multi-unit events was in progress. In 2017, CNSC started a focused desktop review of the documentation for Bruce A and Bruce B SAMGs, including recent updates. CNSC staff expected the review to be completed in 2019.

##### Accident management and recovery

CNSC staff determined that Bruce Power’s accident management and recovery programs met the applicable regulatory requirements in 2017. There were no significant observations to report in 2017.

#### 3.4.4 Safety analysis

CNSC staff concluded that the safety analysis SCA at Bruce A and B met or exceeded the performance objectives and applicable regulatory requirements. As a result, each station received a “fully satisfactory” rating, unchanged from the previous year.

##### Deterministic safety analysis

CNSC staff concluded that both the Bruce A and B safety analyses predicted adequate safety margins. Bruce Power met the applicable regulatory requirements for safe operation. CNSC staff determined that Bruce Power had a well-managed program to conduct deterministic safety analyses and that the existing safety analysis remained adequate during the continued implementation of CNSC REGDOC-2.4.1, Deterministic Safety Analysis. The implementation of REGDOC-2.4.1 is a long-term process; Bruce Power completed the first phase (three years) in 2017. In January 2017, Bruce Power submitted the technical basis documents for Bruce A common mode events (CME) and the analytical results, for CNSC staff review. The analyses of common mode events for Bruce A and B were incorporated into the updated Bruce A and B safety reports. These updates were submitted along with other safety report updates before the end of 2017 and were being reviewed by CNSC staff.

UPDATE: Bruce Power submitted the updated fire protection assessment (code compliance review, fire hazard assessment (FHA) and fire safe shutdown analysis (FSSA)) in 2017. In January 2018, CNSC staff determined that the fire safety analysis, which included the FHA and FSSA, met the applicable regulatory requirements.

##### Probabilistic safety assessment

CNSC staff determined that Bruce Power complied with CNSC regulatory document S‑294, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants and was in transition to implementing CNSC REGDOC-2.4.2, Probabilistic Safety Analysis (PSA) for Nuclear Power Plants. Full implementation of REGDOC-2.4.2 was expected by June 2019. As part of the transition plan, Bruce Power submitted the new PSA methodologies and computer codes in April 2017. CNSC staff reviewed these submissions and concluded that the methodologies met the requirements of REGDOC-2.4.2. In addition, Bruce Power committed to submit a whole-site PSA methodology by the end of 2018. No ongoing issues were identified as a result of regulatory oversight activities. CNSC staff found that Bruce Power’s performance in PSA met or exceeded the applicable regulatory requirements in 2017.

##### Criticality safety

Both the booster fuel assemblies and the low-void reactivity fuel demonstration fuel bundles were in storage. CNSC staff found that Bruce Power’s criticality safety program complied with the applicable regulatory requirements. There were no criticality events and no ongoing issues identified at Bruce A and B during 2017.

##### Severe accident analysis

Bruce Power continued to support industry R&D programs in the area of severe accident analysis. Bruce Power was developing a plan for the design and installation phases of the containment filtered venting system that it had selected; it will provide additional defense in depth when installed. No ongoing improvements were identified as a result of regulatory oversight activities in 2017.

Bruce Power, with other licensees, developed a severe accident software simulator solution to improve its methods of deterministic analysis for multi-unit severe accidents. CNSC staff completed the review of the resulting modelling summary report and proposed some recommendations, as discussed in section 2.4.

##### Management of safety issues (including R&D programs)

The work by NPPs to address the remaining category 3 CANDU safety issues is described in section 2.4.

The following are highlights of two R&D projects that were ongoing in 2017.

###### Moderator subcooling requirements methodology

Bruce Power submitted the review of experimental results, using the safety analysis issue review panel process, for the CNSC-sponsored contact boiling project to test calandria tube strain.  CNSC staff issued an interim report summarizing the results of the experiment along with an  evaluation of the results. The outstanding issues will be addressed over the next licensing period.

###### Moderator temperature predictions

The original experiments to validate moderator temperature predictions involved a moderator nozzle configuration different from that for Bruce A. To provide additional confirmation, Bruce Power completed several initiatives which included submitting technical reports and performing  more experiments that represent the specific geometries of the moderator inlet nozzles for the Bruce A (and PNGS Units 1 and 4) reactors. This experimental work was underway at McMaster University. CNSC staff will review the experimental results over the next licence period.

#### 3.4.5 Physical design

CNSC staff concluded that the physical design SCA at Bruce A and B met the performance objectives and applicable regulatory requirements. As a result, each station received a “satisfactory” rating, unchanged from the previous year.

##### Design governance
###### Environmental qualification

CNSC staff determined that Bruce Power met the applicable regulatory requirements.

Bruce Power has identified components required for replacement to ensure ongoing environmental qualification. The impact of service life extension will be included in revised design documentation for environmental qualification, in keeping the requirements of Bruce Power’s governing document.

In 2017, CNSC staff reviewed Bruce Power’s response to previous inspection findings on the efficiency and effectiveness of the environmental qualification program for Bruce A and B and concluded that Bruce Power adequately addressed issues related to the definition of roles and responsibilities in the environmental qualification process, as well as knowledge management. Additional ongoing actions were being taken to improve walkdown checklists for system performance monitoring. At the end of 2017, CNSC staff were reviewing Bruce Power’s corrective actions.

CNSC staff also reviewed Bruce Power’s submission on the Bruce A seismic margin assessment upgrades. CNSC staff confirmed that all seismic upgrade installations were completed in 2017 and were available for service.

###### Pressure boundary design

CNSC staff determined that Bruce Power had a documented pressure boundary program that met the applicable requirements.

In 2017, CNSC staff inspected the implementation of the pressure boundary program, specifically the processes for system code classification, reconciliation and registration, as well as the service agreement with the authorized inspection agency (which for Bruce Power is Ontario’s Technical Standards and Safety Authority). CNSC staff found that the implementation of the pressure boundary program for both code classification and the design registration reconciliation process met the applicable regulatory requirements.

###### Human factors in design

Bruce Power completed a gap analysis and developed an implementation plan to implement CSA Group standard N290.12-14, Human factors in design for nuclear power plants by September 1, 2018.

UPDATE: An inspection at Bruce Power conducted in early 2018 confirmed that Bruce Power’s updated human program for factors in design complied with N290.12-14.

##### Site characterization

CNSC staff concluded that site characterization at Bruce A and B met the applicable regulatory requirements. There were no significant observations to report in 2017 for this specific area.

##### Facility design

CNSC staff concluded that facility design for Bruce A and B met the applicable regulatory requirements. There were no significant observations to report in 2017 for this specific area.

##### Structure design

CNSC staff concluded that structure design for Bruce A and B met the applicable regulatory requirements.

In 2017, CNSC staff reviewed Bruce Power’s submission in response to the inspection conducted in 2016 on the seismic design preservation program. CNSC staff monitored the implementation of the corrective actions, which were ongoing at the end of 2017.

##### System design
###### Electrical systems

CNSC staff concluded that Bruce Power’s electrical power systems met the applicable regulatory requirements.

Bruce Power continued to upgrade the controls for the standby generators (SGs). In 2017, the upgrades for SG3 at Bruce A and SG7 and SG8 at Bruce B were completed. The upgrades on the remaining SGs were on schedule and CNSC staff were satisfied with Bruce Power’s progress.

In 2017, Bruce Power reported two emergency transfer scheme (ETS) vulnerabilities which would only be a concern for a short time during a safety system test (SST). The SSTs that affect the availability of SGs for the ETS have been identified and deferred until the test procedures are revised and validated. While this condition needed to be resolved, the risk to the stations remained low. CNSC staff considered the actions taken in response to this event to be acceptable and were monitoring Bruce Power’s completion of the corrective actions, which included an ETS design change.

In 2017, the CNSC inspected the Bruce B electrical power systems and verified that they were capable of performing their intended safety functions and that the equipment was being tested and maintained as required.

###### Fire protection design

Bruce Power’s fire protection program met the applicable regulatory requirements in 2017. Bruce Power continued the implementation of design modification improvements for CSA Group standard N293-12, Fire protection for nuclear power plants, which is slated for completion in 2020 at A Bruce and Bruce B. These improvements were included in the IIP for the PSR.

###### Instrumentation and control

Bruce Power initiated the replacement of the digital control computer as a part of Bruce Power’s assets management plan. The first replacement was planned for Unit 6 in 2021. CNSC staff had no safety significant observation at this early stage.

##### Component design

CNSC staff concluded that Bruce Power met the applicable regulatory requirements for component design.

###### Fuel design

CNSC staff determined that Bruce Power had a well-developed reactor fuel inspection program. Fuel performance at Bruce was acceptable in 2017. The fuel defect rate for Units 1 and 2 at Bruce A continues to trend downwards and the trend in observations of end-plate cracking was stable at Bruce B. In 2017, Bruce Power continued to implement its corrective action plan to address fuel bundle vibration due to acoustically active channels at Bruce B. Bruce Power was able to satisfactorily manage fuel performance issues while maintaining safe operations.

###### Cables

In 2017, no deviations from regulatory requirements were found during compliance verification activities (i.e., desktop reviews, PSRs). As a result, CNSC staff concluded that the cable management program at Bruce A and B met the applicable regulatory requirements.

#### 3.4.6 Fitness for service

CNSC staff concluded that the fitness for service SCA at Bruce A and B met the performance objectives and applicable regulatory requirements. As a result, each station received a “satisfactory” rating, unchanged from the previous year.

##### Equipment fitness for service and equipment performance

CNSC staff determined that the overall equipment fitness for service and performance at Bruce A and B was satisfactory and met the applicable regulatory requirements.

In January 2017, CNSC staff inspected Bruce Power’s pressure boundary program and reviewed an event report related to pipe hanger failures in the Bruce A steam reject system. Bruce Power developed a corrective action plan to proactively implement the modified design on the remaining hangers in the Bruce A steam reject system by 2019. The risk in the interim was negligible and CNSC staff found this plan to be acceptable.

In August 2017, circulating pump number four for the Unit 3 heat transport system experienced a triple seal failure while the unit was shutting down. Bruce Power performed a detailed root-cause analysis of this event and presented the findings to the Commission. It determined that the rotating assembly was misaligned or imbalanced. Bruce Power completed the repairs and the unit returned to service. Bruce Power put additional measures in place, such as enhanced vibration monitoring, to prevent a reoccurrence of this event. CNSC staff will closely monitor Bruce Power’s measures to address the root causes of the equipment failure. A detailed description of this event is provided in table 22, section 3.4.

###### Reliability of systems important to safety

CNSC staff determined that the reliability program at Bruce A and B met the applicable regulatory requirements.

For Bruce A, all special safety systems met their unavailability targets in 2017, with the exception of emergency cooling injection (ECI) for Units 1 and 3. This unavailability was caused by the modified ECI system testing program which uses a new fail-pass parameter aligned with the safety analysis and resulted in a conservative assumption that the ECI was unavailable. The unavailability target exceedance occurred due to the reportable event for the quicker-than-analyzed opening of the ECI valve during the scheduled SST at Units 1 and 3. This resulted in a conservative assumption that ECI was unavailable. The valves were promptly adjusted to meet the timing requirements. The valve stroke time did not meet the current design criteria for water hammer analysis for a postulated event involving a secondary side line break. CNSC staff were satisfied with the corrective actions that Bruce Power took to address this event. Bruce Power had to confirm that no additional gaps existed for SSTs revised during the return to service of Units 3 and 4 by June 2018.

For Bruce B, all special safety systems met their unavailability targets in 2017.

As described above under the system design specific area, Bruce Power continued to install control upgrades for all the SGs, enhancing the reliability of the Class III power system. In 2017, the SGs that were not yet upgraded continued to meet their availability targets through a sufficient supply of spare parts.

##### Maintenance

In 2017, CNSC staff determined that the maintenance program met the applicable requirements at Bruce A and B.

The average preventive maintenance completion rates were 88 percent for Bruce A and 87 percent for Bruce B (matching the industry average of 88 percent). The maintenance backlogs for Bruce A and B were acceptable and are provided in tables 23 and 24, respectively.

Table 23: Three-year trend of maintenance backlogs and deferrals for critical components for Bruce A, 2015 to 2017
Parameter Average quarterly work orders per unit Three- year trend Industry average
2015 2016 2017
Corrective maintenance backlog 4 2 3 stable 4
Deficient maintenance backlog 123 123 100 down 94
Deferrals of preventive maintenance 18 12 6 down 30
Table 24: Three-year trend of maintenance backlogs and deferrals for critical components for Bruce B, 2015 to 2017
Parameter Average quarterly work orders per unit Three- year trend Industry average
2015 2016 2017
Corrective maintenance backlog 6 3 2 down 4
Deficient maintenance backlog 180 165 127 down 94
Deferrals of preventive maintenance 28 14 7 down 30

For Bruce A and B, the corrective maintenance backlogs were kept below industry average. The deficient maintenance backlogs were reduced to within the range of the industry average. The number of preventive maintenance deferrals for critical components was reduced to below the industry average.

CNSC staff determined that the overall safety significance of maintenance backlogs and deferrals for critical components was negligible for Bruce A and B.

##### Structural integrity

CNSC staff concluded that SSCs met the applicable structural integrity requirements for both Bruce A and B.

In 2017, pressure boundary inspection results for Units 4 to 8 indicated that all inspected elements of the primary heat transport and auxiliary systems, steam generators, feeders and pressure tubes were fit for continued operation. The results of containment inspections for Unit 5 indicated that all of the inspected elements of containment components were fit for continued operation. All inspection findings were evaluated by Bruce Power to confirm that acceptance criteria in the CSA Group standards for structural integrity were met. CNSC staff determined that appropriate corrective actions (such as repairs or replacement of components) were taken to restore margins.

##### Aging management

CNSC staff determined that Bruce Power’s integrated aging management program met the applicable regulatory requirements at Bruce A and Bruce B. In 2017, Bruce Power completed the implementation of its aging management governance to comply with CNSC REGDOC-2.6.3, Fitness for Service: Aging Management.

Based on available information, CNSC staff confirmed that there was an adequate basis for Bruce Power’s periodic inspection plans.

CNSC staff determined that Bruce Power had adequate programs in place to confirm that fuel channels were fit for service for near-term operation. Bruce Power submitted engineering assessments of degradation mechanisms that spanned the near term and met all the applicable acceptance criteria in CSA Group standards.

In support of future pressure tube engineering assessments (addressing operation of Bruce units up to their respective MCR outages), Bruce Power submitted detailed plans for activities. These plans include the development and validation of a revised pressure tube fracture toughness model applicable to hydrogen equivalent concentration (HEQ) levels in excess of 120 ppm (current limit of model validity) and the implementation of a probabilistic evaluation methodology to demonstrate fracture protection of pressure tubes.

To justify the operation of pressure tubes beyond an HEQ of 120 ppm, Bruce Power will be required to demonstrate that pressure tube fracture toughness is sufficient for safe operation. CNSC staff considered that the existing regulatory process, which was used to monitor additional validation of the existing fracture toughness model up to an HEQ of 120 ppm, was adequate to ensure that the pressure tubes will continue to meet CSA Group acceptance criteria.

See appendix H for details on the current and predicted future fuel channel conditions and the corresponding validity of analytical models of pressure tube fracture toughness for fuel channels at Bruce A and B (and the other NPPs in Ontario).

To ensure these activities are completed in a timely manner, CNSC staff recommended (as part of the 2018 licence renewal) that the Commission impose a specific licence condition, obliging Bruce Power to demonstrate sufficient pressure tube fracture toughness. CNSC staff also intended to closely monitor Bruce Power’s progress on its planned activities to ensure that they were completed according to the required schedules (see section 2.6).

##### Chemistry control

CNSC staff determined that Bruce Power’s chemistry control program met the applicable regulatory requirements. Bruce Power took appropriate actions to maintain the chemistry control parameters within acceptable limits. The storage of hazardous materials and process chemicals onsite was well managed. In the first half of 2017, an increasing (positive) trend in the overall chemistry index for Bruce A and B was attributed to the chemistry improvements made to the condensate extraction system.

In 2017, CNSC staff inspected chemistry control at Bruce A and B and concluded that Bruce Power met all the applicable regulatory requirements for monitoring critical chemistry parameters during the guaranteed shutdown state. Bruce Power provided an adequate corrective action plan, with a target implementation of mid-2018, to address minor issues of negligible safety significance related to independent verification of laboratory results.

##### Periodic inspections and testing

CNSC staff determined that Bruce Power had adequate and well maintained periodic inspection programs in place at Bruce A and B for pressure boundary systems, containment components and containment structures that met the applicable regulatory requirements.

Bruce Power carries out a relief valve testing program to confirm that overpressure protection devices on pressure boundary systems will perform their intended function in the event of operating pressure transients. Bruce Power reported several relief valve test failures on balance-of-plant pressure boundary systems in 2017. CNSC staff confirmed that Bruce Power had implemented adequate corrective actions and concluded that station safety has not been impacted.

CNSC staff concluded that the radiation protection SCA at Bruce A and B met or exceeded the performance objectives and applicable regulatory requirements. As a result, each station received a “fully satisfactory” rating, an improvement over the previous year.

##### Application of ALARA

CNSC staff determined that Bruce Power continued to implement a highly effective and well-documented radiation protection program based on industry best practices to keep doses to persons as low as reasonably achievable (ALARA) at Bruce A and B. CNSC staff verified that Bruce A and B used ALARA initiatives in work planning and in dose monitoring and control to achieve the challenging ALARA targets established by Bruce A and B. The collective dose observed at the site aligned with those targets. CNSC staff concluded that Bruce Power’s application of ALARA met the applicable regulatory requirements and achieved planned goals with a noticeable, improving trend.

In September 2017, CNSC staff conducted an inspection focused on the specific area of ALARA planning. The inspection identified several compliant findings and one area requiring improvement related to the self-assessment of the ALARA program. This area did not pose a risk to the health and safety of workers and was of low safety significance. Bruce Power developed a corrective action that was reviewed CNSC staff and found acceptable.

##### Worker dose control

CNSC staff determined that Bruce Power continued to comply with the regulatory requirements to measure and record doses received by workers at Bruce A and B.

Routine compliance verification activities in 2017 confirmed that performance in the area of worker dose control at Bruce A and B was highly effective. Radiation doses to workers were below the regulatory dose limits and action levels established in the Bruce Power radiation protection program. The data for doses to workers at Bruce A and B are provided in section 2.7.

Safety performance indicators related to worker dose control include tracking of occurrences involving doses received from unplanned exposures or uptakes. CNSC staff observed no adverse trends or safety-significant, unplanned exposures due to the licensed activities at Bruce A and B in 2017.

In 2017, CNSC staff conducted a focused inspection on worker dose control at Bruce A and B. The inspection identified non-compliance of low safety significance related to problem identification and resolution, adherence to radiation protection procedures, selection of appropriate radiological exposures permits and control of procedure revisions. Subsequently, Bruce Power developed corrective action plans which CNSC staff reviewed and found acceptable. All corrective actions from this focused inspection were implemented and closed, except for one related to improvements in the directions given to workers in the selection and use of the appropriate radiological exposures permit for work execution (scheduled for completion in April 2018).

CNSC staff determined that the Bruce Power radiation protection program met the requirements of the Radiation Protection Regulations and confirmed that Bruce Power regularly measures the performance of its program against industry-established objectives, goals and targets.

The oversight applied by Bruce Power in implementing and improving this program was highly effective in protecting workers at both Bruce A and B in 2017.

CNSC staff determined that Bruce Power implemented radiological hazard controls that met the applicable regulatory requirements. These measures protected workers and ensured that radioactive contamination was monitored and controlled within site boundaries.

CNSC staff confirmed that no safety-significant incidents were identified relating to personal and loose contamination events. This was also confirmed in the performance indicator results.

The number of personal contamination events (PCEs) was reduced noticeably in 2017. When compared to other WANO members, Bruce Power achieved a world industry-best performance for PCEs with less than 0.4 PCEs per outage day in 2017, compared to an industry standard of 1.0 PCEs per outage day.

##### Estimated dose to the public

CNSC staff determined that Bruce Power continued to ensure the protection of the general public in accordance with the Radiation Protection Regulations.

In 2017, the reported dose to the public from the Bruce site was 0.0021 mSv, well below the annual dose regulatory limit of 1 mSv (see section 2.7) for members of the general public. There were no significant reportable issues in this area during the reporting year.

#### 3.4.8 Conventional health and safety

CNSC staff concluded that the conventional health and safety SCA at Bruce A met or exceeded the applicable regulatory requirements, while at Bruce B it met the applicable regulatory requirements. As a result, Bruce A received a “fully satisfactory” rating, and Bruce B received a “satisfactory” rating, both unchanged from the previous reporting year.

##### Performance

CNSC staff determined that the performance specific area met or exceeded applicable regulatory requirements at Bruce A, but did not meet those requirements at Bruce B in 2017.

Health and safety related incidents were promptly reported by Bruce Power on an ongoing basis. CNSC staff have reviewed Bruce Power’s corrective actions relating to those incidents and concluded that these actions were appropriate.

During field inspections, CNSC staff observed safety practices and controls being employed to address conventional hazards at both Bruce A and B.

In March 2017, a worker received an electrical shock while performing post-maintenance testing of a circuit breaker at Unit 5 (see table 22 in section 3.4 for details). CNSC staff conducted a reactive compliance inspection at Bruce B and found two points of procedural non-compliance: one of medium safety significance and the other of low safety significance. These points of non-compliance related to work protection practices and the implementation of Bruce Power’s electrical safety procedures. In order to prevent a reoccurrence, Bruce Power improved hazard identification and training and made additional procedural changes for clarity so that workers can determine whether the maintenance work is being performed on an energized or de-energized bus. CNSC staff determined that the corrective actions were adequate and that performance metrics were established to drive improvement.

##### Practices

CNSC staff determined that Bruce Power met or exceeded the applicable regulatory requirements at Bruce A and B in 2017. There were no reportable issues on this area during the reporting year.

The conventional health and safety work practices and conditions at Bruce A and B continued to achieve a high degree of personnel safety. There continues to be a safe working environment where safe work practices are encouraged.

CNSC staff verified that Bruce Power has appropriate procedures in place to ensure the protection of the environment and the health of persons against hazardous materials.

##### Awareness

CNSC staff concluded that Bruce Power met the applicable regulatory requirements in this area in 2017 at both Bruce A and B. All deficiencies from field inspections were adequately addressed throughout the year. Despite promptly addressing these deficiencies, there was an adverse trend with respect to housekeeping findings in 2017 at Bruce A and B. CNSC staff determined that all these findings were not safety significant.

#### 3.4.9 Environmental protection

CNSC staff concluded that the environmental protection SCA at Bruce met the performance objectives and applicable regulatory requirements. As a result, each station received a “satisfactory” rating, unchanged from the previous year.

##### Effluent and emissions control (releases)

Bruce Power had committed to implementing CSA Group standard N288.5, Effluent monitoring programs at Class I nuclear facilities and uranium mines and mills by December 31, 2018.

CNSC staff found that all airborne and waterborne radiological releases to the environment from Bruce A and B remained below regulatory limits and action levels in 2017. The releases are shown in figures 20 and 21 as percentages of the applicable derived release limits (DRLs) for Bruce A and B, respectively. The actual values of the releases and DRLs are provided in appendix I.

Bruce Power plans to implement CSA Group standard N288.3.4, Performance testing of nuclear air-cleaning systems at nuclear facilities in 2018.

##### Environmental management system

Bruce Power has implemented an environmental management program in accordance with CNSC REGDOC-2.9.1, Environmental Protection Policies, Programs and Procedures (2013). This REGDOC was subsequently updated in 2017. Bruce Power’s full implementation of the 2017 revision of REGDOC-2.9.1 is expected in 2020.

In the fall of 2017, Bruce Power also transitioned to the new ISO standard 14001:2015, Environmental management systems – Requirements with guidance for use References 8. See section 2.9 for further details.

##### Assessment and monitoring

CNSC staff determined that Bruce Power’s programs for assessment and monitoring met the applicable regulatory requirements in 2017. CNSC staff reviewed and assessed the 2017 environmental monitoring data and concluded that the general public and the environment in the vicinity of Bruce Power were protected.

In November 2017, CNSC staff inspected Bruce Power’s environmental protection program. CNSC staff concluded that the control, monitoring, analysis and reporting of environmental data and associated processes were well-developed and consistently implemented, and they complied with the applicable regulatory requirements.

An environmental assessment had been conducted prior to the refurbishment of Bruce A Units 1 and 2. Based on the review of the final environmental assessment follow-up monitoring report in 2016, staff from the CNSC and Environment and Climate Change Canada confirmed that no significant adverse effects resulted from the refurbishment (which concluded in 2012) and that the environmental assessment follow-up monitoring program was completed. Aspects of the follow-up monitoring program will continue as part of Bruce Power’s ongoing environmental monitoring program.

Bruce Power was working toward full implementation of CSA Group standard N288.7, Groundwater protection programs at Class I nuclear facilities and uranium mines and mills by December 31, 2020.

##### Protection of the public

During 2017, CNSC staff concluded that there were no hazardous substances released to the environment from Bruce Power that posed an unacceptable risk to the environment or the general public. CNSC staff observed only two minor exceedances of the provincial effluent limits for Bruce Power. In one instance, Bruce B exceeded the ammonia discharge limit; on another occasion, Bruce B exceeded an acute toxicity limit. Both instances were reported to the Ontario Ministry of the Environment and Climate Change and corrective actions were taken to prevent a reoccurrence.

Dose to the public is discussed in section 3.4.7

##### Environmental risk assessment

CNSC staff determined that Bruce Power continued to implement and maintain an effective environmental risk assessment (ERA) and management program at the Bruce site in accordance with the applicable regulatory requirements.

In June 2017, Bruce Power submitted an updated ERA report and a predictive environmental risk assessment (PEA) report for the Bruce site based on effluent and environmental monitoring data for the five-year period between 2012 and 2016. The ERA included an ecological risk assessment (EcoRA) and a human health risk assessment (HHRA) for radiological and non-radiological (hazardous) chemicals of potential concern and physical stressors. The purpose of the PEA was to assess the potential changes to the baseline ERAs and HHRAs due to future activities at the site, including refurbishment activities.

CNSC staff found the methodology to be consistent with the applicable requirements.

Overall, meaningful adverse ecological and human health effects from physical stressors and radiological and non-radiological releases from the Bruce NPP were unlikely.

Although the 2017 ERA report for Bruce A and B provided a complete evaluation of all potential risks to human health and the environment associated with the facility operations, CNSC staff provided comments to Bruce Power with specific recommendations to validate several ERA conclusions and to improve the quality of the ERA. CNSC staff also made recommendations regarding the means to reduce assessment uncertainties for future versions of the ERA.

Bruce Power had committed to implementing CSA Group standard N288.6, Environmental risk assessments at Class I facilities and uranium mines and mills by December 30, 2018.

#### 3.4.10 Emergency management and fire protection

CNSC staff concluded that the emergency management and fire protection SCA at the Bruce Power site met the performance objectives and applicable regulatory requirements. As a result, each station received a “satisfactory” rating, unchanged from the previous year.

##### Conventional emergency preparedness and response

Bruce Power maintained and continued to support a comprehensive conventional emergency response capability at all times onsite and inside the protected areas of Bruce A and B. This included personnel and equipment for medical situations and events involving search and rescue, hazardous material (HAZMAT) and fire response.

CNSC staff concluded that Bruce Power’s conventional emergency preparedness and response met the applicable regulatory requirements.

##### Nuclear emergency preparedness and response

CNSC staff determined that Bruce Power continued to support and maintain a comprehensive nuclear emergency preparedness and response capability at all times that met the applicable regulatory requirements. Bruce Power continued to support offsite emergency management organizations and commitments as well.

Bruce Power had plans to be fully compliant with version 1 of CNSC REGDOC 2.10.1, Nuclear Emergency Preparedness and Response in 2018.

In December 2017, CNSC staff inspected a corporate emergency exercise to assess compliance with REGDOC-2.10.1 and Bruce Power’s Nuclear Emergency Plan. The exercise was designed to test Bruce Power’s capability to respond to a nuclear emergency and to demonstrate the effectiveness of emergency facilities, equipment and response personnel. The inspection identified one point of non-compliance of low safety significance relating to assurance of effective training on the Disaster LAN (DLAN) electronic data transfer system. Bruce Power planned corrective action for 2018.

In August 2017, under subsection 12(2) of the General Nuclear Safety and Control Regulations, CNSC staff asked Bruce Power to submit a plan to implement auto data transfer to the CNSC emergency operations centre, based on the lessons learned from the Huron Resolve corporate drill in 2016. In response to CNSC staff’s request, Bruce Power committed to conducting a feasibility assessment of options for automatic connectivity between plant data systems and DLAN in 2018.

##### Fire emergency preparedness and response

CNSC staff determined that Bruce Power maintained a comprehensive fire response capability and fire protection program that met the applicable regulatory requirements.

Bruce Power had an extensive fire drill and training program that included its new Emergency and Protective Services Training Facility located on the Bruce Power site, where live fire training was conducted.

In April 2017, CNSC staff inspected a Bruce A and B fire drill and identified an area of non-compliance related to radio communications for fire response teams. Bruce Power replaced its radio system and updated radio communications. The development and definition phase was completed with the site-wide radio system project scheduled for completion in 2020. CNSC staff were satisfied with the proposed corrective action plan.

In addition to CNSC compliance activities, Bruce Power is required to conduct expert third party reviews (TPRs), an annual plant condition inspection, a bi-annual fire drill audit and a tri-annual fire program audit. After incorporating the results of the CNSC’s compliance findings and TPR observations and recommendations into the drill and training program, CNSC staff observed that the emergency response team’s performance continued to improve.

#### 3.4.11 Waste management

CNSC staff determined that the waste management SCA at Bruce A and B met or exceeded the performance objectives and applicable regulatory requirements. As a result, each station received a “fully satisfactory” rating, unchanged from the previous year.

##### Waste characterization

CNSC staff determined that Bruce Power’s waste characterization met the applicable regulatory requirements. Bruce Power continued to employ effective programs for the characterization of radioactive and hazardous wastes during 2017.

##### Waste minimization

CNSC staff determined that Bruce Power’s waste management programs met or exceeded the applicable regulatory requirements for minimizing radioactive waste. Bruce Power minimized the production of radioactive wastes through various plans, programs and procedures, and it minimized the impacts from such wastes on workers and the environment. There were only observations of compliance from field inspections in this specific area in 2017.

Bruce Power continued to employ effective programs to minimize radioactive and hazardous wastes during 2017.

##### Waste management practices

CNSC staff determined that Bruce Power’s waste management practices met the applicable regulatory requirements. Bruce Power continued to employ effective radioactive and hazardous waste management practices during 2017. Bruce Power carried out waste management procedures to ensure that waste generated at the facility was separated properly.

##### Decommissioning plans

CNSC staff concluded that the preliminary decommissioning plans (PDPs) for Bruce A and B submitted by OPG met or exceeded the applicable regulatory requirements in 2017. OPG is liable for the Bruce Power site and it is therefore responsible for providing the PDPs and cost estimates. A deferred decommissioning strategy was selected for the decommissioning of Bruce A and B. In 2017, OPG revised the PDPs for all of its facilities for the period ending in 2022. The Commission accepted the PDPs and associated financial guarantee. The associated financial guarantee is discussed in section 2.15.

#### 3.4.12 Security

CNSC staff determined that Bruce Power’s security program met the performance objectives and applicable requirements. All corrective action plans in response to inspection findings were implemented to the satisfaction of CNSC staff. As a result each station received a “satisfactory” rating, unchanged from the previous year.

##### Facilities and equipment

CNSC staff determined that Bruce Power met the applicable regulatory requirements for facilities and equipment. Bruce Power continued to sustain its security equipment through lifecycle management. No significant equipment failures were reported in 2017. Bruce Power had measures in place to adequately prevent security events.

Bruce Power made numerous investments in facilities and equipment. In 2017, Bruce Power invested in bulk vehicle screening equipment that will be used to enhance screening measures presently employed at Bruce A and B. In response to a CNSC staff request, Bruce Power not only performed repairs but also replaced all aging security camera equipment at Bruce A. Bruce Power initiated several new capital investments in 2017 to replace aging security equipment and systems across Bruce A and B, including cameras and detection and search equipment.

###### Cyber security

Bruce Power maintains a cyber security program at Bruce A and B. CNSC staff concluded that the program complied with the applicable regulatory requirements. No cyber security events were reported in 2017.

Bruce Power was updating its current cyber security program at Bruce A and B to fully comply with CSA Group standard N290.7-14, Cyber security for nuclear power plants and small reactor facilities by December 31, 2020. CNSC staff were satisfied with the progress in 2017.

CNSC staff concluded that there were no safety significant issues for this specific area.

##### Response arrangements

CNSC staff determined that Bruce Power met the applicable regulatory requirements for response arrangements.

Bruce Power maintains a nuclear response force that met the applicable requirements. Findings raised during the 2016 security exercise were addressed to the satisfaction of CNSC staff and subsequently closed. The 2017 inspection findings were being addressed to the satisfaction of CNSC staff.

CNSC staff concluded that there were no safety significant issues in the area of response arrangements.

##### Security practices

CNSC staff determined that Bruce A and B implemented security practices that met or exceeded the applicable regulatory requirements.

Bruce Power has procedures in place at Bruce A and B to provide guidance to security personnel in all areas. Bruce Power has a multi-faceted security awareness program that is fully integrated into the Bruce Power governance process. During the reporting period, Bruce Power commenced monthly site-wide lockdown drills with Bruce Power staff. Through its centre of excellence program, Bruce Power also sponsored a World Institute of Nuclear Security (WINS) workshop on incident planning and emergency response.

Bruce Power intends to meet the new requirements for security screening once CNSC REGDOC-2.12.2, Site Access Security Clearance is updated.

CNSC staff concluded that there were no safety-significant issues for this specific area.

##### Drills and exercises

CNSC staff determined that Bruce Power’s exercise and drill program met the applicable regulatory requirements.

In the previous year, CNSC staff identified some deficiencies of low safety significance during the compliance verification activities that were conducted during the force-on-force exercise; these included elements of the Bruce Power drills and exercises program. Bruce Power had provided adequate responses to address the deficiencies identified by CNSC staff and it implemented changes to its program. In 2017, CNSC staff performed a follow-up inspection of the drill and exercise program, and they were satisfied with the corrective actions being taken to address the deficiencies. During the reporting period, Bruce Power commenced site-wide lockdown drills with Bruce Power staff. This activity was seen as a good practice that should be shared with industry peers.

CNSC staff found that there were no safety-significant issues for this specific area.

#### 3.4.13 Safeguards and non-proliferation

CNSC staff concluded that the safeguards and non-proliferation SCA at Bruce A and B met the performance objectives and all applicable regulatory requirements. As a result, each station received a “satisfactory” rating, unchanged from the previous year.

##### Nuclear material accountancy and control

CNSC staff concluded that Bruce Power’s accountancy and control of nuclear material complied with the applicable regulatory requirements at both Bruce A and B in 2017.

##### Access and assistance to the IAEA

CNSC staff concluded that Bruce Power met the applicable regulatory requirements for access and assistance. Bruce Power granted adequate access and assistance to the International Atomic Energy Agency (IAEA) for safeguards activities, including inspections and the maintenance of equipment at both Bruce A and B.

In 2017, the IAEA performed one physical inventory verification (PIV) and five unannounced inspections (UIs) at Bruce A to verify the nuclear material inventory and ensure the absence of undeclared nuclear material and activities.

The IAEA performed one PIV, one design information verification (DIV) and four UIs at Bruce B.

Bruce Power granted access and provided assistance to the IAEA in October for a survey to site potential locations for additional IAEA surveillance equipment in the irradiated fuel bay area, in order to optimize the current safeguards approach at Bruce A and B.

CNSC staff confirmed that Bruce Power met the applicable regulatory requirements for operational and design information. Bruce Power submitted its annual operational program with quarterly updates for both Bruce A and B to the CNSC on time. Bruce Power submitted the annual update to the information pursuant to the IAEA Additional Protocol to the CNSC on time. The information provided met CNSC’s submission requirements.

##### Safeguards equipment containment and surveillance

CNSC staff confirmed that Bruce Power supported IAEA equipment operation and maintenance activities at Bruce A and B, including routine maintenance of surveillance equipment, to ensure the effective implementation of safeguards measures at the stations.

In September 2017, Bruce B reported that the fuel handling operators discovered a broken IAEA seal that had been attached to an electrical junction box through which the cables to the bundle counter detectors were installed. Bruce Power immediately notified this event to the IAEA, and the seal was replaced by the IAEA the following day. The IAEA performed a follow-up visit and confirmed that the electrical junction box had not been tampered with and it was resealed. Bruce Power provided additional training to staff on the reporting procedure and planned to revise the operational manual. CNSC staff were satisfied with the corrective actions taken by the licensee for this event.

#### 3.4.14 Packaging and transport

CNSC staff concluded that the packaging and transport SCA at Bruce A and B met the performance objectives and applicable regulatory requirements. As a result, each station received a “satisfactory” rating, unchanged from the previous year.

The transport of nuclear substances to and from the facility was conducted in a safe manner.

For the onsite movement of nuclear substances, Bruce Power ensured a level of safety equivalent to that required for offsite transportation in order to protect the health and safety of workers, the general public and the environment.

##### Package design and maintenance, packaging and transport, and registration for use

CNSC staff determined that Bruce Power had a packaging and transport program at Bruce A and B that ensures compliance with the Packaging and Transport of Nuclear Substances Regulations and the Transportation of Dangerous Goods Regulations.

There were two separate incidents involving damage to radioactive packages during shipment, when material within the packages shifted during transport. There was no release of material from the packages and the material was properly secured within the packages before they were returned to the Bruce site. CNSC staff determined that there was no impact on the health or safety of persons or the environment as a result of the reported events. Bruce Power changed its procedures to ensure that such incidents do not reoccur. CNSC staff were satisfied with these changes.

#### 3.4.15 Other matters of regulatory interest

##### Public information program

CNSC staff determined that Bruce Power met the applicable regulatory requirements related to public information and disclosure. Bruce Power provided sufficient information on the status of Bruce A and B through a variety of communication activities.

Bruce Power proactively engaged with community members about its ten-year licence renewal application to include major component replacement activities through various community meetings, open houses, social media and advertising campaigns.

Bruce Power conducted extensive research on the effectiveness of its communication program with the general public and how to improve and refine messaging to have a greater impact on its target audiences.

##### Indigenous relations

CNSC staff noted that Bruce Power had a dedicated Indigenous engagement program. Throughout 2017, it met and shared information with interested Indigenous communities and organizations, particularly the Saugeen Ojibway Nation, the Métis Nation of Ontario and the Historic Saugeen Métis.

Information and discussion topics included Bruce Power’s current operations at the Bruce site, the Fisheries Act authorization application, environmental impacts (including to fish) and the licence renewal application.

### 3.5 WWMF and RWOS-1

The safety assessment presented below for each SCA is facility-specific. General information relevant to the SCAs is provided in section 2. The CNSC regulatory documents and CSA Group standards that were identified as regulatory requirements for the WWMF, as of December 2017, are listed in appendix E.

Overall safety assessment

The CNSC staff safety assessment of the WWMF and the Radioactive Waste Operations Site-1 (RWOS-1) for 2017 resulted in the performance ratings presented in table 25. Based on observations and the assessments of the SCAs, CNSC staff concluded that both the WWMF and RWOS-1 operated safely. The overall rating for the WWMF and RWOS-1 was “satisfactory”, unchanged from the previous year.

Table 25: Performance ratings for the WWMF and RWOS-1, 2017
Safety and control area Rating
Management system SA
Human performance management SA
Operating performance FS
Safety analysis FS
Physical design SA
Fitness for service SA
Conventional health and safety FS
Environmental protection SA
Emergency management and fire protection SA
Waste management SA
Security SA
Safeguards and non-proliferation SA
Packaging and transport SA
Overall rating SA

Legend:

• FS – Fully Satisfactory
• SA – Satisfactory
• BE – Below Expectations
• UA – Unacceptable

#### 3.5.0 Introduction

The WWMF and RWOS-1 are located at the site of the Bruce A and Bruce B Nuclear Generating Stations on the east shore of Lake Huron, in Tiverton, Ontario, 20 kilometres northeast of Kincardine and 30 kilometres southwest of Port Elgin. The CNSC regulates the WWMF under a WFOL and the RWOS-1 under a waste nuclear substance licence (WNSL). The facilities are owned and operated by OPG.

At the WWMF, OPG processes and stores DSCs containing used nuclear fuel (high-level radioactive waste) generated solely at Bruce A and B. OPG also manages the low- and intermediate-level radioactive waste (LILW) generated from the operation of OPG-owned (or previously owned) facilities including the DNGS, PNGS and Bruce A and B. Finally, OPG manages the LILW generated from the refurbishment of Bruce A.

The current WWMF licence allows the limited import and export of nuclear substances occurring primarily as contaminants in laundry, packaging, shielding or equipment. These activities were previously authorized under a temporary possession licence.

The WFOL for WWMF spans over two separate areas – the LILW Storage Facility and the Used Fuel Dry Storage Facility (UFDSF) – within the overall boundary of the Bruce site. The LILW Storage Facility consists of the Waste Volume Reduction Building, the Transportation Package Maintenance Building, 14 above-ground low-level storage buildings (LLSBs), two above-ground refurbishment waste storage buildings and various in-ground containers, trenches and tile holes for the storage of ILW. The UFDSF is located within its own protected area, separate from the protected area of Bruce A and B, but within the boundary of the Bruce site. The UFDSF contains one DSC processing building and four DSC storage buildings (Storage Buildings 1, 2, 3 and 4). The WWMF has the capacity to store 2,000 DSCs. The transfer of loaded DSCs from Bruce A and B to the WWMF is conducted on Bruce Power and OPG property with a security escort.

OPG is authorized under the WFOL to construct four additional DSC storage buildings (Storage Buildings 5, 6, 7 and 8), 11 additional LLSBs, 270 additional in-ground containers, 30 in-ground containers for heat exchangers, one large-object processing building and one waste-sorting building. The new structures will provide additional storage for used nuclear fuel and additional storage and processing facilities to manage LILW.

, OPG stores LILW generated at the Douglas Point Nuclear Generating Station and PNGS Units 1–4 at the RWOS-1. This site comprises a number of in-ground waste storage structures, including concrete-lined trenches and steel-lined concrete holes.

Unless stated otherwise, observations or conclusions in this report about the WWMF also pertain in general to the RWOS-1.

##### Licensing

In May 2016, OPG submitted a request to the CNSC to have the WWMF licence renewed References 21 for a period of 10 years until May 31, 2027. The public hearing for the licence renewal was held in Ottawa on April 12, 2017. The record of decision and the renewed WFOL were issued on May 29, 2017.

No licensing actions were conducted for the RWOS-1 in 2017.

The license conditions handbook (LCH) for the WWMF was issued on October 25, 2017. No revisions to the LCH have been made since it was issued.

The WNSL for the RWOS-1 did not have an associated LCH.

##### Event initial reports

No event initial reports pertaining to the WWMF or RWOS-1were submitted to the Commission for the period from January 1, 2017 to June 1, 2018.

##### Compliance program

The CNSC’s annual effort on the compliance program is tabulated in appendix G for the WWMF and RWOS-1. The inspections at the WWMF and RWOS-1 that were considered in the safety assessments in this regulatory oversight report are tabulated in appendix J.

#### 3.5.1 Management system

CNSC staff concluded that the management system SCA at the WWMF met the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “satisfactory” rating, unchanged from the previous year.

##### Management system

CNSC staff determined that OPG’s nuclear management system at the WWMF met the applicable regulatory requirements in 2017. OPG had completed the transition to the 2012 version of CSA Group standard N286-12, Management system requirements for nuclear facilities.

CNSC staff conducted a desktop review of OPG’s nuclear waste management documentation for the WWMF and determined that it met the applicable regulatory requirements. However, during a 2017 inspection at the DWMF, CNSC staff identified minor issues of low safety significance regarding the clarity and consistent application of documentation that were also applicable at the WWMF. OPG committed to applying its corrective action plan at the WWMF as well as the DWMF. At the end of 2017, CNSC staff were monitoring the implementation of the corrective actions and confirming the implementation of OPG’s changes at the WWMF.

##### Organization

CNSC staff determined that OPG had continued to adequately define organizational structures and roles and responsibilities at the WWMF.

CNSC staff had no significant observations at the WWMF to report in this specific area for 2017.

##### Change management

CNSC staff determined that OPG continued to have an adequate change management program at the WWMF that complies with the applicable regulatory requirements.

As a result of an inspection in 2017 at the DWMF, CNSC staff determined that the OPG change management process was ineffective for the inspection of DSCs and for other generic documentation that was used by all OPG WMFs. OPG created a change management committee to manage governance and process changes for nuclear waste at all of its WMFs. OPG committed to applying the corrective action plan at the WWMF with respect to change management. At the end of 2017, CNSC staff were monitoring the implementation of the corrective actions and overseeing the implementation of OPG’s changes at the WWMF.

##### Safety culture

CNSC staff were satisfied that OPG continued to foster a healthy safety culture at the WWMF in 2017. The CNSC will monitor OPG’s next safety culture self-assessment at the WWMF scheduled for 2018 and any improvement actions initiated.

##### Configuration management

CNSC staff determined that OPG maintained the configuration of its structures, systems and components (SSCs) at the WWMF in compliance with its configuration management program and other applicable regulatory requirements. CNSC staff had no significant observations at the WWMF to report in this specific area for 2017.

##### Records management

CNSC staff determined that OPG continued to maintain and implement a document control and records management system at the WWMF and RWOS-1 that met the applicable regulatory requirements.

As a result of an inspection at the DWMF that focused on OPG’s management system, CNSC staff identified minor issues of low safety significance regarding the control of documents and records that apply to the WWMF as well. OPG committed to applying the corrective action plan at the WWMF with respect to records management. At the end of 2017, CNSC staff were reviewing OPG’s corrective action plans and were satisfied with the progress.

##### Management of contractors

CNSC staff concluded that the interface between OPG and its contractors at the WWMF did not meet the applicable regulatory requirements in 2017. As a result of an inspection at the DWMF, CNSC staff noted that OPG was no longer performing the receiving inspection, including the verification of the DSC history docket received from vendors. The discontinuation of receiving inspections and failure to reflect the change in its internal documentation significantly reduced OPG’s oversight of vendors. OPG committed to applying the corrective action plan at the WWMF regarding the management of vendors. At the end of 2017, CNSC staff was monitoring the implementation of the corrective actions at the WWMF. See section 3.1.1 for further details.

CNSC staff concluded that OPG continued to meet the applicable regulatory requirements for business continuity at the WWMF. CNSC staff verified that OPG had adequate contingency plans in place to maintain or restore critical safety and business functions in the event of disabling circumstances, such as a pandemic, severe weather or labour action.

##### Problem identification and operating experience

CNSC staff determined that OPG continued to meet the applicable regulatory requirements for problem identification and OPEX at the WWMF. CNSC staff had no significant observations at the WWMF to report for this specific area in 2017.

##### Performance assessment, improvement and management review

CNSC staff confirmed that OPG continued to meet the applicable regulatory requirements for performance assessment, improvement and management at the WWMF.

CNSC staff had no significant observations at the WWMF to report in this specific area for 2017.

#### 3.5.2 Human performance management

CNSC staff concluded that the human performance management SCA at the WWMF met the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “satisfactory” rating, unchanged from the previous year.

##### Human performance program

CNSC staff determined that OPG’s human performance program at the WWMF continued to meet the applicable regulatory requirements. CNSC staff had no significant observations at the WWMF to report for this specific area for 2017.

##### Personnel training

CNSC staff confirmed that OPG continued to have a well-documented and robust fleet-wide training program based on a systematic approach to training. The implementation of this system for the training programs at the WWMF met the applicable regulatory requirements.

In 2017, CNSC staff verified that OPG satisfactorily completed the corrective actions that resulted from the training-focused inspection in 2016. Subsequently, CNSC staff closed the action item.

##### Personnel certification

This specific area does not apply to the WWMF because there are no CNSC-certified positions at the facility.

##### Initial certification examinations and requalification tests

This specific area does not apply to the WWMF because there are no CNSC-certified positions at the facility.

##### Work organization and job design

This specific area does not apply to the WWMF.

##### Fitness for duty

CNSC staff determined that OPG continued to meet the applicable regulatory requirements for fitness for duty at the WWMF.

CNSC staff asked OPG to provide an implementation plan for CNSC REGDOC-2.2.4, Fitness for Duty, Volume I: Managing Worker Fatigue by September 30, 2017. OPG committed to fully implementing this regulatory document at the WWMF by January 1, 2019. CNSC staff were satisfied with OPG’s implementation plan and will monitor its progress.

CNSC staff asked OPG to provide an implementation plan for CNSC REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use by March 31, 2018. However, at the WWMF, although staff are predominantly OPG employees, personnel affected by this regulatory document are all employees of Bruce Power, and thus will be subject to Bruce Power’s implementation plan. As noted in section 3.4.2, Bruce Power committed to completing the implementation of  REGDOC-2.2.4, Volume II by December 2019.

#### 3.5.3 Operating performance

CNSC staff concluded that the operating performance SCA at the WWMF met or exceeded the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “fully satisfactory” rating ,unchanged from the previous year.

CNSC staff confirmed that OPG continued to meet or exceed the applicable regulatory requirements for the conduct of licensed activities at the WWMF. CNSC staff determined that OPG continued to operate the WWMF in a safe and secure manner, with adequate regard for health, safety, security, radiation protection, environmental protection and international obligations.

In 2017, OPG operated the WWMF within the bounds of its operating policies and principles and operational safety requirements.

On August 23, 2017, OPG reported an event that occurred at the WWMF to CNSC staff regarding an unplanned power outage at the UFDSF. Class IV power at the dry storage facility was lost and restored after six hours. OPG stated that there were no environmental, health, safety or security implications for the facility or personnel as a result of this event. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

This section is divided into the following subsections: high-level waste operations, low- and intermediate-level waste operations, and construction activities.

###### High-level waste operations

In 2017, OPG processed 100 DSCs at the WWMF. Since the start of facility production to the end of 2017, OPG had processed and placed 1,364 DSCs into storage at the WWMF.

###### Low- and intermediate-level waste operations

At the WWMF, OPG processes and stores LILW generated by the DNGS, PNGS and Bruce Power. OPG conducts LLW incineration and compaction activities in order to minimize storage volume 70-fold (incineration) and 5-fold (compaction) in accordance with the “3 Rs”: reduce, reuse and recycle. The total volume of LILW received at the WWMF in 2017 was 2,240 m3.

###### Construction activities

OPG did not construct any additional buildings at the WWMF in 2017.

##### Procedures

CNSC staff concluded that OPG had governance to ensure that procedures for the WWMF were written in a consistent and usable manner. OPG had clearly documented expectations for procedural use and adherence, and a process to manage procedural change at the WWMF.

CNSC staff were satisfied with the quality of OPG’s procedures and found that they continued to meet the applicable regulatory requirements.

##### Reporting and trending

CNSC staff confirmed that OPG’s reporting and trending met or exceeded the applicable regulatory requirements and expectations in 2017 for the WWMF.

During the reporting year, all scheduled reports for the WWMF were submitted to CNSC in a timely manner and were adequate.

During 2017, CNSC staff received six low-safety significance event reports from OPG regarding the WWMF. The event reports are discussed in detail under their applicable SCAs in section 3.5.

##### Outage management performance

This specific area does not apply to the WWMF.

##### Safe operating envelope

This specific area does not apply to the WWMF.

##### Severe accident management and recovery

CNSC staff determined that severe accident management and recovery continued to meet or exceeded the applicable regulatory requirements for the WWMF in 2017. The program was implemented with an organizational structure that clearly establishes the roles and responsibilities of all program participants. CNSC staff had no significant observations to report at the WWMF in this specific area for 2017.

##### Accident management and recovery

Through regulatory oversight, CNSC staff determined that OPG’s accident management and recovery program for the WWMF continued to meet or exceed the applicable regulatory requirements in 2017. CNSC staff had no significant observations to report in this specific area at the WWMF for 2017.

#### 3.5.4 Safety analysis

CNSC staff concluded that the safety analysis SCA at the WWMF met or exceeded the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “fully satisfactory” rating, unchanged from the previous year.

##### Deterministic safety analysis

CNSC staff determined that OPG’s deterministic safety analysis predicted adequate safety margins, and met or exceeded the applicable regulatory requirements at the WWMF. OPG submits a safety analysis report for the WWMF every five years that identifies facility hazards and the measures in place to control or mitigate these hazards. The most recent approved revision to this document was submitted to CNSC staff in 2012, who were satisfied with the update. OPG submitted a revision to the WWMF safety report in November 2017 and it was undergoing CNSC review.

OPG continued to implement a comprehensive fire protection program at the WWMF in accordance with the applicable requirements.

OPG submitted the updated fire hazard analysis, code compliance review, and fire protection program audit for the WWMF. CNSC staff determined that the approach and methodology used was generally consistent with applicable requirements for the fire protection program audit. At the end of 2017, CNSC staff were reviewing the fire hazard analysis and code compliance review.

##### Probabilistic safety assessment

This specific area does not apply to the WWMF.

##### Criticality safety

This specific area does not apply to the WWMF.

##### Severe accident analysis

This specific area does not apply to the WWMF.

##### Management of safety issues (including R&D programs)

This specific area does not apply to the WWMF.

#### 3.5.5 Physical design

CNSC staff concluded that the physical design SCA at the WWMF met the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “satisfactory” rating ,unchanged from the previous year.

##### Design governance

CNSC staff concluded that OPG continued to meet the applicable regulatory requirements regarding design governance in 2017 for the WWMF.

###### Pressure boundary design

CNSC staff confirmed that OPG continued to implement a comprehensive pressure boundary program at the WWMF that complied with the applicable regulatory requirements.

##### Site characterization

CNSC staff had no significant observations at the WWMF to report in this specific area for 2017.

##### Facility design

CNSC staff had no significant observations at the WWMF to report in this specific area for 2017.

##### Structure design

CNSC staff confirmed that OPG continued to meet the applicable regulatory requirements regarding structure design in 2017 for the WWMF.

CNSC staff had no significant observations at the WWMF to report in this specific area for 2017.

##### System design

CNSC staff confirmed that OPG continued to meet the applicable regulatory requirements regarding system design in 2017 for the WWMF.

###### Fire protection design

CNSC staff confirmed that OPG continued to implement a comprehensive fire protection program at the WWMF in accordance with CSA Group standard N393-13, Fire protection for facilities that process, handle, or store nuclear substances.

##### Component design

CNSC staff confirmed that OPG continued to meet the applicable regulatory requirements regarding component design in 2017 for the WWMF.

On September 12, 2017, OPG reported an event that occurred at the WWMF to CNSC staff regarding a pressure vessel certificate of inspection. In 2016, the Technical Standards and Safety Authority inspected propane tanks at the WWMF and determined that a certificate of inspection was not required. However, on August 2, 2017, OPG confirmed that the certificate of inspection was required, and the Technical Standards and Safety Authority issued the certificates the next day.

OPG stated that there were no environmental, health, safety or security implications for the facility or personnel as a result of this event and that no effective dose was received from this event. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

#### 3.5.6 Fitness for service

CNSC staff concluded that the fitness for service SCA at the WWMF met the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “satisfactory” rating unchanged from the previous year.

CNSC staff determined that OPG established and maintained fitness-for-service programs that were effectively implemented at the WWMF and satisfied the applicable regulatory requirements. The implemented programs ensure the safe physical condition of SSCs.

##### Equipment fitness for service and equipment performance

This specific area does not apply to the WWMF.

##### Maintenance

CNSC staff determined that OPG’s maintenance program met the applicable regulatory requirements for the WWMF in 2017. CNSC staff had no significant observations at the WWMF to report in this specific area for 2017.

##### Structural integrity

CNSC staff confirmed that SSCs important for safe operations at the WWMF continued to meet the applicable structural integrity requirements established in the design basis or in CNSC-accepted standards and guidelines for the WWMF in 2017.

##### Aging management

CNSC staff confirmed that OPG’s integrated aging management program at the WWMF continued to meet the applicable regulatory requirements in 2017.

OPG completed its transition to compliance with CNSC REGDOC-2.6.3, Aging Management at the WWMF in 2017.

##### Chemistry control

CNSC staff determined that OPG’s chemistry control program met or exceeded the applicable regulatory requirements for the WWMF in 2017.

CNSC staff reviewed the 2017 quarterly reports for the WWMF and concluded that the facility maintained acceptable performance related to chemistry. There were no chemistry-related incidents at the WWMF in 2017.

##### Periodic inspections and testing

This specific area does not apply to the WWMF because periodic inspection and testing requirements are addressed under the scope of aging management at the facility.

CNSC staff concluded that the Radiation protection SCA at the WWMF met the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “satisfactory” rating unchanged from the previous year.

##### Application of ALARA

CNSC staff determined that OPG continued to implement an effective and well-documented program, based on industry best practices, to keep doses to persons as low as reasonably achievable (ALARA) at the WWMF. In 2017, CNSC staff verified that OPG used ALARA initiatives, work planning, and dose monitoring and control to work toward the challenging ALARA targets established by OPG at the WWMF.

CNSC staff verified during 2017 that radiation exposures and doses to workers at the WWMF were below the regulatory dose limits and remained ALARA.

##### Worker dose control

CNSC staff confirmed that OPG continued to comply with the regulatory requirements to measure and record doses received by workers at the WWMF.

Routine compliance verification activities conducted in 2017 confirmed that performance in the area of worker dose control at the WWMF was effective. Radiation doses to workers were below the regulatory dose limits and action levels established in OPG’s radiation protection program.

CNSC staff observed that no adverse trends or safety-significant unplanned exposures resulted from the licensed activities at the WWMF in 2017.

The data for doses to workers at the WWMF is provided in section 2.7. The maximum dose received by a worker at the WWMF in 2017 was 0.6 mSv, which was 1.2 percent of the regulatory dose limit.

CNSC staff determined that OPG continued to implement a radiation protection program at the WWMF that satisfies the requirements of the Radiation Protection Regulations.

The oversight applied by OPG in implementing and improving this program was effective at protecting workers at the WWMF. OPG regularly measures the performance of its radiation protection program against industry-established objectives, goals and targets.

OPG’s action levels for the WMFs were revised in 2017 to ensure they were appropriate indicators of a possible loss of control of an element of OPG’s radiation protection program at the WWMF. CNSC staff reviewed the revised action levels and found them to be appropriate.

CNSC staff determined that OPG implemented radiological hazard controls that met the applicable regulatory requirements. These measures protected workers and ensured radioactive contamination was controlled within the site boundary for the WWMF.

There were no contamination control action level exceedances for surface contamination at the WWMF in 2017.

On March 10, 2017, OPG reported an event that occurred at the WWMF to CNSC staff regarding the absence of a radiation hazard posting pursuant to section 21(b) of the Radiation Protection Regulations. OPG stated that there was no environmental, health, safety or security implications for the facility or personnel as a result of this event. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

On November 8, 2017, OPG reported an event that occurred at the WWMF to CNSC staff regarding an unposted radiation hazard. Upon discovery of the unposted hazard a barrier was established and posted at the 25 μSv/hr [2.5mrem/hr]) boundary. OPG stated that there were no environmental, health, safety or security implications for the facility or personnel as a result of this event. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

##### Estimated dose to the public

The WWMF is located within the site boundary of the Bruce NGSs. In accordance with licence requirements, Bruce Power has its own programs in place to verify that radiation doses to members of the general public resulting from releases remain ALARA. As seen in section 2.7, figure 10, dose to the public associated with operational activities at the site for 2013 to 2017 was well below the regulatory annual dose limit of 1 mSv for members of the general public.

#### 3.5.8 Conventional health and safety

CNSC staff concluded that the conventional health and safety SCA at the WWMF exceeded the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “fully satisfactory” rating, unchanged from the previous year.

##### Performance

CNSC staff determined that OPG met or exceeded the applicable regulatory requirements at the WWMF with regard to conventional health and safety performance.

OPG continued to demonstrate its ability to keep workers safe from occupational injuries while conducting its licensed activities at the WWMF. Health and safety related incidents are reported by OPG on an ongoing basis, as applicable. No health and safety related incidents or lost-time injuries were reported at the WWMF by OPG to CNSC staff in 2017.

CNSC staff conducted inspections at the WWMF and recorded their findings on the safe practices and controls being employed by OPG to address conventional hazards. CNSC staff did not identify any areas of concern regarding conventional health and safety in 2017.

CNSC staff participated in pre-inspection health and safety briefings held with OPG staff and management. CNSC staff found that the health and safety briefings were satisfactory.

##### Practices

CNSC staff determined that OPG’s conventional health and safety practices met or exceeded the applicable regulatory requirements at the WWMF in 2017.

The conventional health and safety work practices and conditions at the WWMF continued to achieve a high degree of personnel safety. OPG personnel at all levels exhibited proactive attitudes toward anticipating work-related hazards and preventing unsafe conditions. There continued to be a working environment where safe work practices were encouraged. CNSC staff verified that OPG had appropriate procedures in place at the WWMF to ensure the health of persons is protected against hazardous materials.

CNSC staff observed safe work practices during site inspections at the WWMF. A positive indicator in this regard was the use of the job hazard analysis program, which specifies OPG’s commitment to conducting pre-inspection tours of jobs and job sites, listing emergency procedures for such jobs, identifying the minimum level of personal protective equipment required and listing the permits or work authorizations required before starting work.

##### Awareness

CNSC staff confirmed that OPG continued to meet or exceed the applicable regulatory requirements for awareness in 2017 at the WWMF. CNSC staff determined that OPG continued to maintain a safe working environment at the WWMF. CNSC staff had no significant observations at the WWMF in this specific area for 2017.

#### 3.5.9 Environmental protection

CNSC staff concluded that the environmental protection SCA at the WWMF met the performance objectives and applicable regulatory requirements, unchanged from the previous year.

##### Effluent and emissions control (releases)

The WWMF has its own facility-specific derived release limits (DRLs) and action levels for radiological airborne and liquid releases. CNSC staff observed how all airborne and waterborne radiological releases from the WWMF remained below the applicable regulatory limits and action levels in 2017. The releases are shown in figure 22 as percentages of the applicable DRLs. The actual values of releases and DRLs are provided in appendix I.

OPG submitted revised DRLs and environmental action levels (EALs) for WWMF to CNSC staff. The DRL revisions were based on Update No. 2 (November 2017) of CSA Group standard N288.1-14, Guidelines for calculating derived release limits for radioactive materials in airborne and liquid effluents for normal operation of nuclear facilities. At the end of 2017, CNSC staff were reviewing the revisions.

As of December 14, 2017, OPG was fully compliant with the requirements of CSA Group standard N288.3.4-13, Performance testing of nuclear air-cleaning systems at nuclear facilities for the WWMF.

##### Environmental management system

CNSC staff confirmed that in 2017, OPG continued to establish and implement a corporate-wide environmental management system (EMS) to assess environmental risks associated with its nuclear activities at the WWMF and to ensure these activities were conducted in a way that prevented or mitigated adverse environmental effects. The EMS meets the requirements of CNSC REGDOC-2.9.1, Environmental Principles, Assessments and Protection Measures, version 1.1 and is also registered to ISO standard 14001:2015 – Environmental management systems – Requirements with guidance for use References 8. As a result of registration, the EMS is subject to periodic independent third party audits and reviews to verify its sufficiency and to identify potential improvements.

##### Assessment and monitoring

CNSC staff reviewed and assessed the environmental monitoring data provided by OPG for the WWMF and concluded that the general public and the environment in the vicinity of the facility were protected. OPG met the applicable regulatory requirements for the WWMF in 2017.

OPG completed its groundwater monitoring network assessment of the WWMF and added 22 additional wells to its groundwater monitoring program. The assessment updated and confirmed the understanding of the site hydrogeology for the current site and for areas of potential expansion.

OPG completed a gap analysis in 2017 between the existing groundwater monitoring program and the requirements in CSA Group standard N288.7-15 Groundwater protection programs at Class I nuclear facilities and uranium mines and mills. OPG developed an implementation plan to comply with the standard by December 31, 2021. CNSC staff found the transition date to be acceptable.

##### Protection of the public

CNSC staff confirmed that the general public in the vicinity of the WWMF was protected and that there were no expected health impacts.

OPG made two relevant reports in 2017 to another regulatory body – the Ministry of the Environment and Climate Change (MOECC). In July 2017, OPG reported that the data acquisition and handling software was not normalizing the SO2 and NOx emissions to 11% oxygen. In December 2017, OPG reported that there was a minor NOx stack emission limit exceedance. CNSC staff concluded that the risks to the general public and the environment due to hazardous substances released to the environment from the WWMF was low. OPG reported that the concentration of NOx exceeded the MOECC 24-hour rolling average. OPG reported this incident to the MOECC, and developed an action plan to address the exceedance. Both items have been addressed and are closed.

Dose to the public is discussed in section 3.5.7.

##### Environmental risk assessment

CNSC staff determined that OPG continued to implement and maintain an effective environmental risk assessment (ERA) and management program at the WWMF in accordance with the applicable regulatory requirements.

In April 2016 OPG submitted an ERA to support its application for a 10-year licence that was presented to the Commission on April 12, 2017. CNSC staff completed a detailed technical review of the ERA against the clauses in CSA Group standard N288.6-12, Environmental risk assessments at Class I nuclear facilities and uranium mines and mills and concluded that some requirements were not met. OPG submitted an updated ERA in October of 2016. CNSC staff concluded that the ERA methodology was consistent with the applicable requirements. Overall, meaningful adverse ecological and human health effects due to releases to air and water from the WWMF were found to be unlikely. CNSC staff concluded that the revisions to the updated ERA were acceptable.

In May 2016, OPG submitted a predictive effects assessment (PEA) to support the licensing process for the construction of additional storage and processing buildings and to demonstrate that its provisions to protect the environment were adequate. CNSC staff found that the PEA provided an adequate evaluation of all potential risks to human health and the environment associated with the construction of additional storage and processing buildings during the next licence period. The results of the PEA review by CNSC staff indicate that meaningful human health or ecological effects attributable to the proposed construction activities were unlikely.

CNSC staff reviewed the PEA and the revised ERA and concluded that they complied with CSA Group standard N288.6.

#### 3.5.10 Emergency management and fire protection

CNSC staff concluded that the Emergency management and fire protection SCA at the WWMF met the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “satisfactory” rating, unchanged from the previous year.

OPG has contracted Bruce Power to provide comprehensive conventional emergency response capability for the WWMF at all times. This includes personnel and equipment for medical situations and events involving hazardous materials (HAZMAT), search and rescue, and fire response.

##### Conventional emergency preparedness and response

CNSC staff had no significant observations at the WWMF to report in this specific area for 2017.

##### Nuclear emergency preparedness and response

CNSC staff confirmed that OPG continued to support and maintain a comprehensive emergency preparedness and response capability at all times that met the applicable regulatory requirements at the WWMF. Additionally, CNSC staff confirmed that OPG continued to support offsite emergency management organizations and commitments.

OPG has a facility emergency program for the WWMF that includes radiation response emergency procedures. Training and exercises are conducted annually at the Bruce site to ensure all areas of the site, including the WWMF, have adequate emergency notification and response capability from Bruce Power Emergency Services. OPG performs periodic due diligence assessments on Bruce Power’s emergency response facilities, equipment, procedures and personnel to confirm the agreed services will continue to meet the requirements.

OPG had a transition plan in place to implement version 2 of CNSC REGDOC-2.10.1, Nuclear Emergency Preparedness and Response (2016) at the WWMF by December 31, 2018. CNSC staff found the transition date to be acceptable.

##### Fire emergency preparedness and response

Through regulatory oversight, CNSC staff confirmed that OPG continued to maintain a comprehensive fire response capability and a fire protection program that met the applicable regulatory requirements at the WWMF.

CNSC staff reviewed OPG’s submissions related to fire protection, including a fire response needs analysis for the WWMF, and concluded that they met the applicable regulatory requirements.

On September 25, 2017, OPG reported an event that occurred at the WWMF regarding loss of fire water to CNSC staff. OPG was notified by Bruce Power that a water main onsite had ruptured. A fire impairment plan was immediately put in place, including the restriction of hot work onsite. Fire water was restored approximately 12 hours after the fire water main ruptured. OPG stated that there were no environmental, health, safety or security implications for the facility or personnel as a result of this event, and that there was no effective dose received from this event. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

#### 3.5.11 Waste management

CNSC staff concluded that the waste management SCA at the WWMF met or exceeded the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “satisfactory” rating, unchanged from the previous year.

##### Waste characterization

CNSC staff confirmed that OPG’s waste characterization continued to meet the applicable regulatory requirements at the WWMF.

OPG continued to employ effective programs for the characterization of radioactive and hazardous wastes at the WWMF in 2017. CNSC staff had no significant observations at the WWMF to report in this specific area for 2017.

##### Waste minimization

CNSC staff determined that OPG’s programs for minimizing radioactive waste continued to meet the applicable regulatory requirements at the WWMF.

Minimal radioactive waste is generated from the waste management activities conducted at the WWMF. Nonetheless, OPG has set a goal to minimize the generation of radioactive waste due to operational activities.

In 2012 and 2013, OPG explored external opportunities for waste reprocessing at the WWMF. Pilot projects were completed to confirm opportunities for a reduction in volume of large metal components, such as heat exchangers, and to verify contents of stored non-processible waste and confirm opportunities for further reprocessing. In 2017, OPG continued to send some waste to a licensed external provider for processing.

In 2013, OPG implemented a “likely clean” program at the WWMF. The “likely clean” program allows for the separation at the source of waste that is likely not radioactive (i.e., “clean”), so as to minimize the generation of LLW at this facility. During routine compliance inspections in 2017, CNSC staff observed and confirmed OPG’s implementation of this program.

In 2014, OPG began a waste-sorting pilot project at the WWMF. Non-processible LLSB wastes, both stored and new, were opened and sorted into various streams. Incinerable and compactable materials were segregated for further processing at the WWMF. Metals were segregated, then either surveyed, decontaminated and free released, or if they could not be decontaminated, stored for future processing or interim storage. Since 2015, LLW has been sorted resulting in further volume reduction opportunities through incineration and compaction, and the ability to free-release metals. This program continued in 2017.

##### Waste management practices

Through regulatory oversight, CNSC staff determined that OPG’s waste management practices continued to meet the applicable regulatory requirements. OPG continued to employ effective radioactive and hazardous waste management practices at the WWMF during 2017. OPG uses waste management procedures to ensure that waste generated at the facility is separated properly, as noted by CNSC staff during inspections in 2017.

As of October 31, 2017, OPG had fully implemented the requirements of CSA Group standards N292.0-14, General principles for the management of radioactive waste and irradiated fuel, N292.2-13, Interim dry storage of irradiated fuel and N292.3-14, Management of low- and intermediate-level radioactive waste for the WWMF.

##### Decommissioning plans

The preliminary decommissioning plan (PDP) for the WWMF met or exceeded the applicable regulatory requirements in 2017.

In 2017, OPG revised the PDPs for all of its facilities for the period up to 2022. An immediate decommissioning strategy was selected for the decommissioning of the WWMF, once all low- and intermediate-level radioactive waste and used fuel is transferred to an appropriate repository. The Commission accepted the PDP and associated financial guarantee. The associated financial guarantee is discussed in section 2.15.

#### 3.5.12 Security

CNSC staff concluded that the security SCA at the WWMF met the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “satisfactory” rating, a downgrade from the previous year.

##### Facilities and equipment

CNSC staff determined that OPG continued to meet the applicable regulatory requirements for facilities and equipment at the WWMF. OPG continued to sustain its security equipment through lifecycle management at the WWMF. No significant equipment failures were reported in 2017. Additionally, OPG has processes in place to adequately prevent security events at the WWMF.

In 2017, OPG replaced screening equipment at the UFDSF. OPG added new security assessment devices to the protected area boundary and upgraded parts of the protected area barrier for additional delay, which improved security measures.

On February 8, 2017, OPG reported an event that occurred at the WWMF regarding security to CNSC staff. OPG stated that there were no environmental, health, safety or security implications for the facility or personnel as a result of this event. CNSC staff were satisfied with the corrective actions taken by the licensee and subsequently closed the event.

##### Response arrangements

CNSC staff determined that OPG continued to meet the applicable regulatory requirements for response arrangements at the WWMF.

In 2017, OPG updated security operating procedures for the WWMF and ensured that its contingency plans meet the design basis threat as approved by the CNSC. The response force is provided by Bruce Power.

CNSC staff had no significant observations to report in this specific area at the WWMF for 2017.

##### Security practices

CNSC staff determined that OPG continued to implement security practices at the WWMF that met the applicable regulatory requirements.

OPG had procedures in place to guide security personnel in all areas, although there were signs of non-adherence to these procedures. CNSC staff had no significant observations to report in this specific area at the WWMF for 2017.

##### Drills and exercises

CNSC staff determined that OPG’s exercise and drill program continued to meet the applicable regulatory requirements for the WWMF.

In accordance with the Nuclear Security Regulations, OPG is required to conduct a security drill once every 30 days at the WWMF to test the readiness of one or more of its physical protection systems and the readiness of its security personnel. These drill requirements apply to the Bruce Power nuclear response force, which provides the armed response component of the WWMF security program.

CNSC staff had no significant observations to report in this specific area at the WWMF for 2017.

#### 3.5.13 Safeguards and non-proliferation

CNSC staff concluded that OPG’s safeguards and non-proliferation SCA at the WWMF met the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “satisfactory” rating, unchanged from the previous year.

##### Nuclear material accountancy and control

CNSC staff confirmed that OPG’s accountancy and control of nuclear material at the WWMF continued to meet the applicable regulatory requirements in 2017.

##### Access and assistance to the IAEA

CNSC staff confirmed that the OPG continued to meet the applicable regulatory requirements for access and assistance at the WWMF. OPG granted adequate access and assistance to the International Atomic Energy Agency (IAEA) for safeguards activities, including inspections,  equipment maintenance and the routine application of seals at the WWMF, pursuant to the Canada–IAEA safeguards agreements and the facility’s licence conditions.

In 2017, the IAEA performed one physical inventory verification, one design information verification, seven unannounced inspections and one complementary access at the WWMF to verify the nuclear material inventory and ensure the absence of undeclared nuclear material and activities. OPG provided access and support to these inspections, and the IAEA informed the CNSC that the results of these inspections were satisfactory.

CNSC staff confirmed that OPG continued to meet the applicable regulatory requirements for operational and design information for the WWMF.

OPG submitted its annual operational program with quarterly updates for the WWMF to the CNSC on schedule. OPG submitted the annual update to the information pursuant to the IAEA Additional Protocol to the CNSC on schedule. The information provided met CNSC’s submission requirements.

##### Safeguards equipment, containment and surveillance

CNSC staff confirmed that OPG met the applicable regulatory requirements for safeguards equipment, containment and surveillance for the WWMF. CNSC staff confirmed that OPG supported IAEA equipment operation and maintenance activities at the WWMF, including routine maintenance of surveillance equipment, to ensure the effective implementation of safeguards measures at the facility.

#### 3.5.14 Packaging and transport

CNSC staff concluded that the packaging and transport SCA at the WWMF met the performance objectives and applicable regulatory requirements. As a result, the WWMF received a “satisfactory” rating unchanged from the previous year.

##### Packaging design and maintenance, packaging and transport, and registration for use

CNSC staff determined that OPG had a packaging and transport program at the WWMF that ensured compliance with the Packaging and Transport of Nuclear Substances Regulations, 2015 and the Transportation of Dangerous Goods Regulations.

For onsite movement of nuclear substances, OPG ensured a level of safety equivalent to that required for offsite transportation to protect the health and safety of workers, the general public and the environment.

CNSC staff had no significant observations at the WWMF to report in this specific area for 2017.

#### 3.5.15 Other matters of regulatory interest

##### Public information program

OPG continued communicating regularly about the WWMF to engage and inform residents and stakeholders.

CNSC staff determined that OPG met the applicable regulatory requirements related to public information and disclosure and provided sufficient information on the status of its facility through a variety of communication activities, including: information sessions, facility tours, participation in community events, newsletters, ongoing website updates and the use of social media.

##### Indigenous relations

CNSC staff observed that OPG had a dedicated Indigenous engagement program. In 2017, OPG continued its engagement with the Indigenous communities around the WWMF regarding its operations, and updated them on the proposed deep geologic repository (DGR) project. OPG held quarterly meetings separately with the Saugeen Ojibway Nation, the Métis Nation of Ontario (Georgian Bay Traditional Territory Consultation Committee, Region 7) and the Historic Saugeen Métis. A key event in 2017 was the April relicensing of the WWMF (which was approved) and featured the participation of the above communities as intervenors. Tours of the WWMF were conducted with Indigenous communities and OPG funded community events, summer camps and cultural activities through its corporate citizenship program.

### 3.6 Gentilly-2

The safety assessment for each SCA is facility-specific. General information relevant to the SCAs is provided in section 2. The CNSC regulatory documents and CSA Group standards that were identified as regulatory requirements for Gentilly-2, as of December 2017, are listed in appendix E.

### Overall safety assessment

The CNSC staff safety assessment of the Gentilly-2 facilities for 2017 resulted in the performance ratings shown in table 26. Based on the observations and the assessments of the SCAs, CNSC staff concluded that the Gentilly-2 facilities were maintained safely. The overall rating was “satisfactory”, unchanged from 2015, the last year Gentilly-2 was rated.

Table 26: Performance ratings for Gentilly-2, 2017
Safety and control area Rating
Management system SA
Human performance management SA
Operating performance SA
Safety analysis SA
Physical design SA
Fitness for service SA
Conventional health and safety SA
Environmental protection SA
Emergency management and fire protection SA
Waste management SA
Security SA
Safeguards and non-proliferation SA
Packaging and transport SA
Overall rating SA

Legend:

• FS – Fully Satisfactory
• SA – Satisfactory
• BE – Below Expectations
• UA – Unacceptable

#### 3.6.0 Introduction

Gentilly‑2 is located on the south shore of the St. Lawrence River in Bécancour, Quebec, about 15 kilometres east of Trois-Rivières. It is owned and operated by Hydro-Québec.

The CANDU reactor had a nominal capacity of 675 MWe (megawatts electrical). The Gentilly-2 reactor went into commercial operation in 1983, was shut down permanently on December 28, 2012 and was completely defueled by September 3, 2013. In 2015, Gentilly-2 was transitioned to a safe storage state, meaning that its fuel was stored in either the irradiated fuel bay (wet storage) or in CANSTOR units (dry storage).

##### Licensing

A Commission hearing was held on May 5, 2016 to hear Hydro-Québec’s application for a decommissioning and waste management licence References 22. On June 22, 2016, the Commission announced its decision to issue a power reactor decommissioning licence to Hydro-Québec for the Gentilly-2 facilities. The licence was valid from July 1, 2016 to June 30, 2026.

##### Licence conditions handbook

The Gentilly-2 licence conditions handbook (LCH) has not been amended since the licence was issued in 2016.

##### Fisheries Act authorization

Hydro-Québec completed a Fisheries Act self-assessment before its licence renewal in 2016. CNSC staff reviewed the self-assessment and concluded that a Fisheries Act authorization would not be required for Gentilly-2.

##### Event initial reports

No event initial reports pertaining to Gentilly-2 were submitted to the Commission for the period from January 1, 2017 to June 1, 2018.

##### Compliance program

The CNSC’s annual effort on the compliance program is tabulated in appendix G for Gentilly-2. The inspections at Gentilly-2 that were considered in the safety assessments in this regulatory oversight report are tabulated in appendix J.

#### 3.6.1 Management system

CNSC staff concluded that the management system SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

##### Management system

CNSC staff determined that Hydro-Québec’s management system at Gentilly-2 met the applicable regulatory requirements in 2017. Hydro-Québec completed the transition to the 2012 version of CSA Group standard N286-12, Management system requirements for nuclear facilities in 2016.

##### Organization

CNSC staff determined that Hydro-Québec had an adequately defined organizational structure and roles and responsibilities at Gentilly-2.

In 2017, CNSC staff inspected records management at Gentilly-2 and identified non-compliance of low safety significance regarding Hydro-Québec’s quality management manual. During this inspection, CNSC staff noted that the manual did not detail an interface between the Gentilly‑2 facilities at the site and the records repository located in Montréal. In order to establish dispositions to systematically contact personnel at the Gentilly-2 facilities for any events that impact the preservation of records, there must be an interface with the semi-active records repository located in Montréal.

Hydro-Québec addressed CNSC staff’s concern with Gentilly-2’s revised management system manual which takes into account staffing levels and the organizational structure. The organizational structure comprises two units: maintenance and technical support.

CNSC staff were satisfied with Hydro-Québec’s restructuring and will continue to monitor the organizational structure until the dry safe storage state is reached in 2020.

##### Change management

CNSC staff determined that Hydro-Québec had an adequate change management program that complied with the applicable regulatory requirements. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Safety culture

Hydro-Québec issued a human performance procedure in 2015 to reinforce its expectations for staff behaviour to foster a healthy safety culture. See additional details in the human performance program section below.

##### Configuration management

Hydro-Québec maintained the configuration of its structures, systems and components (SSCs) in compliance with its configuration management program and regulatory requirements.

In 2017, Hydro-Québec submitted a new revision to the program that was specific to the control of the equipment configuration. CNSC staff were satisfied with this revision.

##### Records management

CNSC staff determined that Hydro-Québec continued to maintain and implement a document control and records management system that met the applicable regulatory requirements.

As discussed above, in 2017, CNSC staff inspected records management at the Gentilly-2 facilities. CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements for records management, although there were minor points of non-compliance with Hydro-Québec’s documentation. Specifically, some low significance findings were identified concerning records management at the repository for semi-active records in Montréal. In 2018, CNSC staff will monitor the implementation of Hydro-Québec’s corrective action plan.

In 2017, Hydro-Québec submitted the plan for the completion of procedures for retiring systems from service. CNSC staff continued to monitor Hydro-Québec’s records management plan as the facilities transition to dry safe storage state.

##### Management of contractors

CNSC staff confirmed that Hydro-Québec continued to meet the applicable regulatory requirements for managing contractors. There were no significant observations at Gentilly-2 to report in this specific area for 2017.

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements for business continuity. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Problem identification and operating experience

CNSC staff determined that Hydro-Québec continued to meet the applicable regulatory requirements for problem identification and operating experience. There were no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Performance assessment, improvement and management review

CNSC staff confirmed that Hydro-Québec continued to meet the applicable regulatory requirements for performance assessment, improvement and management review. There were no significant observations at Gentilly-2 to report in this specific area for 2017.

#### 3.6.2 Human performance management

CNSC staff concluded that the human performance management SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

##### Human performance program

CNSC staff determined that the Hydro-Québec human performance program met the applicable regulatory requirements. As mentioned in the safety culture specific area, Hydro-Québec issued a human performance procedure in 2015 to reinforce the staff behaviour expected to maintain good safety culture and continuously reduce the frequency and severity of events. CNSC staff were satisfied with the plans proposed by Hydro-Québec and the actions taken to ensure that human performance remains adequate.

##### Personnel training

The implementation of Hydro-Québec’s new training program, developed in 2014, continued throughout 2017. This program was adapted to the Gentilly-2 facilities’ organizational structure and the site’s safe storage state activities. As part of the transition to the new organizational structure, Hydro-Québec confirmed that the required training for the new position of site responsible was being implemented.

Hydro-Québec submitted the training program for the position of site responsible in 2017; CNSC staff found it to be acceptable.

UPDATE: In early 2018, CNSC staff conducted an onsite follow-up verification in various areas related to training for the position of site responsible, the removal of the onsite fire brigade and the training of senior health physicists.

Also in 2017, Hydro-Québec submitted a gap analysis and transition plan for the implementation of CNSC REGDOC-2.2.2, Personnel Training. CNSC staff reviewed the submission and concluded that the processes and procedures put in place met the regulatory requirements for the systems approach to training.

Overall, CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements for personnel training.

##### Personnel certification

CNSC staff determined that Hydro-Québec’s personnel certification program at Gentilly-2 met the applicable regulatory requirements. Note that only the senior health physicist position at Gentilly-2 is certified. CNSC staff reviewed the staffing reports for certified personnel and the applications for initial certification and renewal of certification, and they confirmed that certified personnel at the Gentilly-2 facilities possessed the knowledge and skills required to perform their duties safely and competently.

##### Initial certification examinations and requalification tests

Given that the initial certification examination and requalification testing programs for certified health physicists working at the Gentilly-2 facilities are administered by CNSC staff, Hydro-Québec is not required to have an initial certification examination program or a requalification testing program.

##### Work organization and job design

Hydro-Québec’s organization continued to evolve in 2017. Hydro-Québec modified and reduced staffing at the Gentilly-2 facilities on the basis of reduced risk and volume of work by reworking procedures and staff capability, in keeping with a plan submitted to the CNSC.

The minimum shift complement at Gentilly-2 met the applicable regulatory requirements.

In 2017, one violation of minimum shift complement was reported to the CNSC for a member of the industrial fire brigade, with no impact to safety. Since December 2017, CNSC staff approved the removal of the industrial fire brigade from the minimum staff complement at Gentilly-2; at that time, an agreement was established between Hydro-Québec and the city of Bécancour for the Bécancour fire department to respond to fire alarms at the Gentilly-2 facilities. The minimum staff complement now comprises nuclear security officers who are present at all times and are responsible for ensuring the safety and security of the facility. In addition, the site responsible is required to be onsite during all maintenance activities, which are typically conducted from Monday to Thursday.

Surveillance of the facilities outside of business hours is achieved through an annunciation, communication and recall system that automatically triggers alarms to the site responsible who is on call.

In 2017, CNSC staff asked Hydro-Québec to continue to report activations of the recall system on a quarterly basis. CNSC staff reviewed Hydro-Québec’s submissions for 2017 and were satisfied with the details submitted. There have been no reported problems relating to the operation of the automated system since its commissioning. CNSC staff were satisfied with the system. While CNSC staff requested that Hydro-Québec maintain records of the information related to the events that resulted in the system activation, transmitting these event reports to the CNSC is no longer required, as of 2018.

##### Fitness for duty

CNSC staff confirmed that Hydro-Québec continued to meet the applicable regulatory requirements for fitness for duty at the Gentilly-2 facilities.

In late 2017, CNSC staff asked Hydro-Québec to submit an implementation plan for CNSC REGDOC-2.2.4 Fitness for Duty, Volume I: Managing Worker Fatigue and for CNSC REGDOC-2.2.4 Fitness for Duty, Volume II: Managing Alcohol and Drug Use.

For Fitness for Duty, Volume I: Managing Worker Fatigue, the only applicable workers are nuclear security workers, for Fitness for Duty, Volume II: Managing Alcohol and Drug Use, the only applicable workers are nuclear security officers and certified health physicists.

UPDATE: Hydro-Québec submitted the implementation plans with supporting gap analyses by the end of March 2018.

#### 3.6.3 Operating performance

CNSC staff concluded that the operating performance SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements for the conduct of licensed activities at Gentilly-2. Hydro-Québec continued to conduct its activities at Gentilly-2 in a safe and secure manner, with adequate regard for health, safety, security, radiation and environmental protection and international obligations.

In 2017, Hydro-Québec maintained the Gentilly-2 facilities within the bounds of its operating policies and principles and operational safety requirements.

##### Procedures

CNSC staff confirmed that the procedures for the Gentilly-2 facilities continued to meet the applicable regulatory requirements. Hydro-Québec had a defined process in place to ensure that procedures were developed and changes were managed in a consistent manner to support the safe decommissioning of the facilities.

##### Reporting and trending

In 2017, all scheduled reports were submitted to the CNSC in a timely manner and were adequate. CNSC staff determined that reporting and trending at the Gentilly-2 facilities met the applicable regulatory requirements and expectations in 2017.

##### Outage management performance

This specific area does not apply to Gentilly-2.

##### Safe operating envelope

CNSC staff determined that Gentilly-2 operated within the safe operating envelope and met the applicable regulatory requirements. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Severe accident management and recovery

CNSC staff confirmed that Hydro-Québec’s severe accident management and recovery programs continued to meet the applicable regulatory requirements in 2017. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Accident management and recovery

CNSC staff confirmed that Hydro-Québec’s accident management and recovery programs continued to meet the applicable regulatory requirements in 2017. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

#### 3.6.4 Safety analysis

CNSC staff concluded that the safety analysis SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

##### Deterministic safety analysis

The deterministic safety analysis predicted adequate safety margins and met the applicable regulatory requirements at Hydro-Québec.

Hydro-Québec continued its decommissioning activities to achieve the dry safe storage state; it expected to reach this state by the end of 2020. For the period between December 2019 and the dry safe storage state declaration, no major changes to the facility were expected. An update of the Hydro-Québec safety report is due for 2019, in keeping with the requirements of CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants. Hydro-Québec was discussing with CNSC staff the intent to formally request an extension to submit the updated revision of the safety report after reaching the dry safe storage state.

##### Probabilistic safety assessment

This specific area does not apply to Gentilly-2.

##### Criticality safety

This specific area does not apply to Gentilly-2.

##### Severe accident analysis

This specific area does not apply to Gentilly-2.

##### Management of safety issues (including R&D programs)

This specific area does not apply to Gentilly-2.

#### 3.6.5 Physical design

CNSC staff concluded that the physical design SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

##### Design governance
###### Pressure boundary design

Based on their compliance verification activities, CNSC staff were satisfied with the implementation of the pressure boundary program at Gentilly-2. In 2017, Hydro-Québec revised its pressure boundary program to better reflect the current state of the facilities. CNSC staff reviewed the revised program and were satisfied with the update.

##### Site characterization

CNSC staff confirmed that site characterization at Gentilly-2 continued to meet the applicable regulatory requirements in 2017. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Facility design

CNSC staff confirmed that facility design for Gentilly-2 continued to meet the applicable regulatory requirements in 2017. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Structure design

CNSC staff concluded that the structure design specific area continued to meet the applicable requirements. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### System design

CNSC staff concluded that system design for Gentilly-2 met the applicable regulatory requirements in 2017.

###### Electrical power system

Hydro-Québec maintained the electrical power and instrumentation and control systems at Gentilly-2 as required for the safe storage state of fuel stored in the irradiated fuel bay. Modifications were implemented to ensure the reliability of these systems.

Hydro-Québec did not plan to make other modifications to the electrical systems before reaching the dry safe storage state, when all spent fuel would be stored in CANSTOR modules.

###### Instrumentation and control

Hydro-Québec submitted a project summary for installing a new parameter-monitoring system for Gentilly-2, which resulted in the replacement of two control computers in 2016. CNSC staff were satisfied with the system and deemed it acceptable with respect to the present state of the Gentilly-2 facilities. CNSC staff will maintain regulatory oversight of this system up to the dormancy state for Gentilly-2.

##### Component design

CNSC staff confirmed that component design for Gentilly-2 continued to meet the applicable regulatory requirements in 2017. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

#### 3.6.6 Fitness for service

CNSC staff concluded that the fitness for service SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

##### Equipment fitness for service/equipment performance

CNSC staff confirmed that overall equipment fitness for service and performance at Gentilly-2 continued to meet the applicable regulatory requirements in 2017. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Maintenance

CNSC staff confirmed that Hydro-Québec continued to meet the performance objectives and applicable regulatory requirements for maintenance. CNSC staff were satisfied with Hydro-Québec’s performance in this specific area.

##### Structural integrity

CNSC staff confirmed that structural integrity at Gentilly-2 continued to meet the applicable regulatory requirements in 2017. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Aging management

CNSC staff concluded that Hydro-Québec’s integrated aging management program continued to meet the applicable regulatory requirements at Gentilly-2. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Chemistry control

CNSC staff confirmed that Hydro-Québec’s chemistry control continued to meet the applicable regulatory requirements at Gentilly-2. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Periodic inspections and testing

CNSC staff determined that Hydro-Québec’s periodic inspection (and aging management) programs had been revised to reflect the current state at Gentilly-2 and that the changes to these programs were in effect according to CSA Group standards N291-08, Requirements for safety-related structures for CANDU nuclear power plants and N286-12, Management system requirements for nuclear facilities and CNSC REGDOCs 2.6.3, Aging Management and 2.6.2, Maintenance Programs for Nuclear Power Plants. CNSC staff were satisfied with the modifications – which were commensurate with the operational and radiological risk levels – made to these programs.

CNSC staff concluded that the radiation protection SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

##### Application of ALARA

In 2017, Hydro-Québec submitted its ALARA plan regarding the final phase (Phase III) of draining resins from the storage tank. The two first campaigns for the transfer of resins in the summer and fall of 2013 and 2014 were carried out successfully and will serve as operational experience for the third campaign. CNSC staff were satisfied with the plan and concluded that Hydro-Québec met the applicable regulatory requirements in 2017.

##### Worker dose control

CNSC staff determined that Hydro-Québec continued to comply with the applicable regulatory requirements to measure and record doses received by workers at Gentilly-2.

Routine compliance verification activities conducted in 2017 confirmed that performance in the area of worker dose control at Gentilly-2 was effective. Radiation doses to worker were below the regulatory dose limits and action levels established in the Hydro-Québec radiation protection program. The data for doses to workers at Gentilly-2 in 2017 are provided in section 2.7. The maximum dose received by a worker in 2017 was 1.16 mSv, which was approximately 2.3% of the regulatory dose limit.

CNSC staff confirmed that Hydro-Québec continued to implement a radiation protection program at Gentilly-2 that met the requirements of the Radiation Protection Regulations. CNSC staff were satisfied with Hydro-Québec’s performance in this specific area.

CNSC staff determined that Hydro-Québec continued to implement radiological hazard controls that met the applicable regulatory requirements. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Estimated dose to the public

CNSC staff determined that Hydro-Québec continued to ensure the protection of the general public in accordance with the Radiation Protection Regulations. The reported estimated dose to members of the general public attributed to Gentilly-2 activities was 0.007 mSv, well below the annual dose limit of 1 mSv (see section 2.7).

The Gentilly-2 value for 2017 was higher than the values in previous years for two reasons. First, Hydro-Québec changed its approach to the calculations in 2017 making it possible to consider the actual radioactivity measurements of aquatic fauna. This resulted in a change in how the most exposed member of a critical group was identified (a fisherman fishing near the discharge) and it was also associated with a change in the DRLs. Second, variations in radionuclide releases and their dispersion into the environment as a result of operations leading to safe storage can also explain the higher estimated dose for 2017.

#### 3.6.8 Conventional health and safety

CNSC staff concluded that the conventional health and safety SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

##### Performance

CNSC staff determined that Hydro-Québec met the applicable requirements at Gentilly-2 regarding conventional health and safety performance.

According to the data submitted by Hydro-Québec, the number of lost days rose from 0 in 2016 to 14 in 2017, while the number of medically-treated injuries and lost-time injuries increased from 0 in 2016 to 2 in 2017, for 119,385 person-hours worked.

##### Practices

At Gentilly-2, Hydro-Québec`s conventional health and safety practices met the applicable regulatory requirements. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Awareness

CNSC staff concluded that Hydro-Québec met or exceeded the applicable regulatory requirements for awareness in 2017 at Gentily-2. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

#### 3.6.9 Environmental protection

CNSC staff concluded that the environmental protection SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

##### Effluent and emissions control (releases)

CNSC staff reviewed the reported airborne and waterborne radiological releases to the environment from the Gentilly-2 facilities and confirmed that the releases remained below regulatory limits and action levels in 2017. Figure 23 presents the airborne and waterborne radiological releases from the Gentilly-2 facilities in 2017 as percentages of the applicable derived release limits (DRLs). The actual values of releases and DRLs are provided in appendix I.

##### Environmental management system

Hydro-Québec has established and implemented an environmental management program to assess environmental risks associated with its decommissioning activities and to ensure these activities are conducted in a way that prevents or mitigates adverse environmental effects. The program met the applicable regulatory requirements.

The environmental management system at the Gentilly-2 facilities detailed in the environmental protection program document, was updated in 2017 by Hydro-Québec. According to Hydro-Québec, this update was the final action to complete in order to be fully compliant with CNSC REGDOC-2.9.1, Environmental Protection Policies, Programs and Procedures. CNSC staff were reviewing the update to ensure that the implementation of this REGDOC was complete and acceptable.

##### Assessment and monitoring

CNSC staff reviewed and assessed the environmental monitoring data and concluded that the general public and the environment in the vicinity of Gentilly-2 were protected. Hydro-Québec met the applicable regulatory requirements for 2017.

In 2014, Hydro-Québec removed the surveillance of thermal discharges to fish from the environmental monitoring program. This was justified by the achievement of wet safe storage with all spent fuel stored in pools, the decrease of intake water and the decrease in thermal discharge.

Hydro-Québec’s update of its environmental protection program document in 2017 also addressed other changes to environmental monitoring activities that reflected the state of the Gentilly-2 facilities.

##### Protection of the public

No hazardous substances released from Gentilly-2 exceeded applicable regulatory limits.

Dose to the public is discussed in section 3.6.7.

##### Environmental risk assessment

CNSC staff determined that Hydro-Québec continued to implement and maintain an effective environmental risk assessment and management program at Gentilly-2 facilities in accordance with the applicable regulatory requirements.

With the shutdown of the reactor, the quantity of water pumped at the intake decreased significantly, as did the predicted impingement and entrainment of aquatic biota. Therefore, very little heat was expected in the discharge channel; the predicted thermal impact to aquatic biota was minimal. Similarly, the predicted impacts on wetland habitats and terrestrial habitats were  minimal with the shutdown of the reactor. Thus, CNSC staff concluded that the environmental risk following decommissioning would be minimal, and they expect Hydro-Québec to confirm this conclusion through continued environmental monitoring.

#### 3.6.10 Emergency management and fire protection

CNSC staff concluded that the emergency management and fire protection SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

The achievement of the wet safe storage state and the progression toward dry safe storage state resulted in a major decrease in radiological risks associated with the site.

As a result of the reduction in risk, in 2016, the province of Quebec abolished the external (offsite) nuclear emergency response plan. However, provisions remained in place to address radiological and other emergencies through Quebec’s broader emergency plan, as described in section 2.10.

##### Conventional emergency preparedness and response

Hazards at the Gentilly-2 facilities had been greatly reduced, thereby eliminating the need for a full-time industrial fire brigade with HAZMAT capability onsite. The memorandum of understanding (MOU) with the city of Bécancour was revised in fall 2017 to provide emergency response services. Experienced Gentilly-2 operations staff remain employed and available on-call at all times to assist and respond to conventional hazards, if necessary.

CNSC staff concluded that Gentilly-2’s conventional emergency preparedness and response met the applicable regulatory requirements.

##### Nuclear emergency preparedness and response

CNSC staff concluded that Hydro-Québec continued to maintain and support an emergency preparedness and response capability in 2017 that met all the applicable regulatory requirements, through the MOU signed with the Municipality of Bécancour in fall 2017.

CNSC staff were satisfied with Hydro-Québec’s relocation of the onsite emergency operations centre in 2017 and its revised emergency organization and response capability. Hydro-Québec revised its onsite nuclear emergency plan for Gentilly-2 in December 2017.

##### Fire emergency preparedness and response

CNSC staff confirmed that Hydro-Québec continued to maintain a fire response capability and fire protection program that met the applicable regulatory requirements.

CNSC staff accepted Hydro-Québec’s request to remove the industrial fire brigade as of December 22, 2017 once Hydro-Québec had adjusted its milestones to integrate the CNSC’s expectations. The fire emergency response is now provided by surrounding municipalities. As stated previously, an MOU was signed between Hydro-Québec and the municipalities to support emergency response for the site.

CNSC staff accepted Hydro-Québec’s request to cancel the industrial fire brigade audit, initially scheduled for December 2017, as it was no longer pertinent to the site’s status. Nonetheless, Hydro-Québec planned to complete an audit on fire protection before the end of 2019.

CNSC staff reviewed the changes in site response to emergencies and concluded that Hydro-Québec continued to ensure adequate emergency response services for the site.

#### 3.6.11 Waste management

CNSC staff concluded that the waste management SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

##### Waste characterization

CNSC staff confirmed that Hydro-Québec's waste characterization continued to meet the applicable regulatory requirements. Hydro-Québec continued to employ effective programs for the characterization of radioactive and hazardous wastes in 2017.

##### Waste minimization

CNSC staff determined that Hydro-Québec’s waste management programs for minimizing radioactive waste met the applicable regulatory requirements at Gentilly-2. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Waste management practices

CNSC staff determined that Hydro-Québec’s waste management practices met the applicable regulatory requirements.

CNSC staff were satisfied with the information provided by Hydro-Québec concerning the implementation plan for CSA Group standard N292.2-13, Interim dry storage of irradiated fuel, with a firm deadline for completion of June 2018.

##### Decommissioning plans

The preliminary decommissioning plan for Gentilly-2 met the applicable regulatory requirements in 2017. The associated financial guarantee is discussed in section 3.6.15.

#### 3.6.12 Security

CNSC staff concluded that the security SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

The Gentilly-2 facilities remain a high security site, as defined in the Nuclear Security Regulations. Hydro-Québec is therefore required to meet the requirements of the regulations until decommissioning is completed, at which time CNSC will assess the licensee’s submission for a change in security at the site.

Hydro-Québec had qualified nuclear security officers and a satisfactory security program.

##### Facilities and equipment

CNSC staff determined that Hydro-Québec met the applicable regulatory requirements for facilities and equipment. Hydro-Québec provided adequate infrastructure, physical delay barriers, access control and identification, procedures, systems, devices and security personnel to meet its security program requirements. In addition, Hydro-Québec has a corrective maintenance program in place for critical security systems and devices at the Gentilly-2 site. Gentilly-2 protected areas were equipped with intrusion detection systems.

Gentilly-2 waste facilities use CANSTOR units – a Canadian design – to store spent (used) fuel. The spent fuel was stored in the irradiated fuel bay in the main station inside the protected area. In combination with physical barriers in place along the protected area perimeters, CNSC confirmed that there was sufficient delay time for response forces to make intervene effectively in the event of an attempted theft or sabotage of nuclear material at these locations.

CNSC staff conducted a field inspection in 2017 and confirmed the effectiveness of the security facilities and equipment at the Gentilly-2 facilities. Hydro-Québec resolved the areas for improvement as identified by CNSC staff in a timely manner.

One outstanding area – confirming the adequacy of the marine barrier – was resolved in spring 2018.

###### Cyber security

Hydro-Québec maintains a cyber security program at the Gentilly-2 facilities. Throughout 2017, Hydro-Québec continued to implement CSA Group standard N290.7, Cyber security. No cyber security events were reported in 2017. CNSC staff concluded that the program complied with the applicable regulatory requirements.

UPDATE: In June 2018, CNSC received Hydro-Québec’s final submission on the completed implementation of CSA Group N290.7.

##### Response arrangements

CNSC staff determined that Hydro-Québec met the applicable regulatory requirements for response arrangements at Gentilly-2.

Hydro-Québec engaged trained and suitably-equipped nuclear security officers for its facility. In addition, Hydro-Québec established cooperative response arrangements with the Sûreté du Québec in written memorandums of understanding, should additional response services be needed. The concrete storage containers for radioactive waste are significantly robust with adequate delay to allow an immediate security response and assistance from offsite response to prevent sabotage and theft. Gentilly-2 response arrangements exceeded requirements, as nuclear security officers were trained to intervene while equipped with primary and secondary weapons and they were authorized by the province of Quebec as peace officers for the Gentilly-2 facilities. Offsite response consists of external police tactical response officers from the Sûreté du Québec.

##### Security practices

CNSC staff determined that Hydro-Québec met the applicable regulatory requirements for response arrangements at Gentilly-2. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Drills and exercises

CNSC staff determined that Hydro-Québec’s exercise and drill program met the applicable regulatory requirements.

Under the Nuclear Security Regulations, Gentilly-2 is required to conduct a security drill once every 30 days to test the readiness of one or more of its physical protection systems and the readiness of its security personnel.

CNSC staff found that there were no safety-significant issues in this specific area.

#### 3.6.13 Safeguards and non-proliferation

CNSC staff concluded that the safeguards and non-proliferation SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

##### Nuclear material accountancy and control

CNSC staff concluded that Hydro-Québec’s accountancy and control of nuclear material at Gentilly-2 complied with the applicable regulatory requirements in 2017. CNSC staff had no significant observations at Gentilly-2 to report in this specific area for 2017.

##### Access and assistance to the IAEA

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements for access and assistance to the International Atomic Energy Agency (IAEA). Hydro-Québec granted adequate access and assistance to the IAEA for safeguards activities, including the maintenance of equipment and the routine application of seals at Gentilly-2.

In 2017, the IAEA performed three unannounced inspections at Gentilly-2. The IAEA did not perform a physical inventory verification at Gentilly-2 in 2017.

CNSC staff confirmed that Hydro-Québec met the applicable regulatory requirements for operational and design information for Gentilly-2.

Hydro-Québec submitted its annual operational program with quarterly updates for Gentilly-2, as well as the annual updated information pursuant to the IAEA Additional Protocol, to the CNSC in a timely manner. The information provided met the CNSC’s submission requirements.

##### Safeguards equipment, containment and surveillance

CNSC staff confirmed that Hydro-Québec met the applicable regulatory requirements for safeguards equipment, containment and surveillance. Hydro-Québec supported IAEA equipment operation and maintenance activities at Gentilly-2, including the maintenance and installation of surveillance equipment, to ensure the effective implementation of safeguards measures at the facilities.

#### 3.6.14 Packaging and transport

CNSC staff concluded that the packaging and transport SCA at Gentilly-2 met the performance objectives and applicable regulatory requirements. As a result, the facilities received a “satisfactory” rating.

The transport of nuclear substances to and from the facility was conducted in a safe manner.

For onsite movement of nuclear substances, Hydro-Québec ensured a level of safety equivalent to that required for offsite transportation to protect the health and safety of workers, the general public and the environment.

##### Packaging design and maintenance, packaging and transport, and registration for use

CNSC staff determined that Hydro-Québec had a packaging and transport program at Gentilly-2 that ensures compliance with the Packaging and Transport of Nuclear Substances Regulations, 2015 and the Transportation of Dangerous Goods Regulations.

No packaging and transport events were reported in 2017.

#### 3.6.15 Other matters of regulatory interest

##### Public information program

As stated in condition G.6 of the nuclear power reactor decommissioning licence for Gentilly-2, Hydro-Québec needs to submit an annual report that summarizes all developments and events that have occurred at the Gentilly-2 facilities. In 2017, CNSC staff completed the review of the 2016 report and concluded that Hydro-Québec met all regulatory requirements related to the public information program.

UPDATE: In May 2018, Hydro-Québec submitted the 2017 report. CNSC staff were reviewing this submission.

##### Indigenous relations

Hydro-Québec’s Indigenous engagement program is included in its public information program. As part of that program, Hydro-Québec submits a paper copy of its environmental monitoring report for Gentilly-2 to the Grand Conseil de la Nation Waban-Aki, the Conseil des Abénakis d'Odanak and the Conseil des Abénakis de Wôlinak annually.

##### Financial guarantees

On August 25, 2017, the Commission accepted Hydro-Québec’s total financial guarantee for the future decommissioning of the Gentilly-2 facilities References 23. As of that date, the value of the financial guarantee was $835 million, which exceeded the required value of$808 million.

## 4 Summary and conclusions

The CNSC conducted numerous activities related to licensing and compliance in 2017. Licensing activities included licence renewals for NPPs and WMFs. Licensees were conducting PSRs to support long-term operation and implementing the results. CNSC staff also conducted numerous compliance activities in 2017, including inspections, desktop reviews, and surveillance and monitoring. The CNSC followed up on these activities as necessary and continues to monitor licensee corrective actions that were incomplete at the end of 2017.

The licensing and compliance activities were conducted in the context of robust regulatory requirements. The requirements include CNSC regulatory documents and CSA Group standards, which continued to evolve in 2017 as new documents and new versions were published. NPP and WMF licensees were in the process of implementing various new requirements in 2017, and CNSC staff were satisfied with the overall progress.

CNSC staff concluded that the NPPs and WMFs discussed in this report operated safely in 2017.  This conclusion was based on general observations as well as detailed staff assessments for each facility in the context of the 14 CNSC SCAs.

General observations include the following:

• No events above Level 0 on the International Nuclear and Radiological Event Scale were reported to the IAEA. For all events, licensees followed approved procedures and took appropriate corrective action.
• NPPs and WMFs operated within the bounds of their operating policies and principles.
• There were no serious process failures at the NPPs. The number of unplanned transients and trips in the reactors was low and acceptable to CNSC staff. All unplanned transients in the reactors were properly controlled and adequately managed.
• Radiation doses to the general public were well below the regulatory limits.
• Radiation doses to workers at the NPPs and WMFs were below the regulatory limits. The annual average effective radiation dose to workers at NPPs and WMFs remained low in 2017. The small increase (3% over 2016 figures) was primarily attributed to refurbishment activity at the DNGS and was not considered significant.
• The frequency and severity of non-radiological injuries to workers were very low.
• No radiological releases into the environment from the NPPs and WMFs exceeded the regulatory limits.
• Licensees met the applicable requirements related to Canada’s international obligations; safeguards inspection results were acceptable to the IAEA.

The detailed assessments of each SCA in this regulatory oversight report were based on the systematic consideration of findings from inspections, desktop reviews, surveillance and monitoring, and other compliance verification activities against relevant requirements, expectations and performance objectives. The ratings that summarize the results of those assessments are provided in tables 27 and 28. All NPPs and WMFs in Canada received SCA ratings and overall ratings of either “fully satisfactory” or “satisfactory” in 2017.

Table 27: Safety performance ratings for Canadian NPPs in 2017
Safety and control area DNGS PNGS Point Lepreau Bruce A Bruce B Gentilly-2
Management system SA SA SA SA SA SA
Human performance management SA SA SA SA SA SA
Operating performance FS FS SA FS FS SA
Safety analysis FS FS FS FS FS SA
Physical design SA SA SA SA SA SA
Fitness for service SA SA SA SA SA SA
Radiation protection SA SA SA FS FS SA
Conventional health and safety FS FS FS FS SA SA
Environmental protection SA SA SA SA SA SA
Emergency management and fire protection SA SA SA SA SA SA
Waste management FS FS SA FS FS SA
Security SA SA SA SA SA SA
Safeguards and non-proliferation SA SA SA SA SA SA
Packaging and transport SA SA SA SA SA SA
Overall rating FS FS SA FS SA SA
Table 28: Safety performance ratings for Canadian WMFs in 2017
Safety and control area DWMF PWMF WWMF
Management system SA SA SA
Human performance management SA SA SA
Operating performance FS FS FS
Safety analysis FS FS FS
Physical design SA SA SA
Fitness for service SA SA SA
Conventional health and safety FS FS FS
Environmental protection SA SA SA
Emergency management and fire protection SA SA SA
Waste management SA SA SA
Security SA SA SA
Safeguards and non-proliferation SA SA SA
Packaging and transport SA SA SA
Overall rating SA SA SA

Legend:

• FS – Fully Satisfactory
• SA – Satisfactory
• BE – Below Expectations
• UA – Unacceptable

## Acronyms and abbreviations

AF
accident frequency
ALARA
as low as reasonably achievable
ASR
accident severity rate
CAA
composite analytical approach
CANDU
CLMF
Central Laundry and Maintenance Facility
CMD
Commission member document
CNL
CNSC
COG
CANDU Owners Group (Inc.)
CSA
Canadian Standards Association (as referenced in titles of standards; the association itself is now known as CSA Group)
CSI
CANDU safety issue
CVC
compliance verification criteria
CVP
compliance verification program
DFO
DNGS
Darlington Nuclear Generating Station
DWMF
Darlington Waste Management Facility
DRL
derived release limit
EA
environmental assessment
EIR
event initial reports
EME
emergency mitigating equipment
GSS
guaranteed shutdown state
HLW
high-level waste
HT
elemental tritium
HTO
tritium oxide
IAEA
International Atomic Energy Agency
IIP
integrated implementation plan
ILW
intermediate-level waste
IPR
integrated plant rating
ISAR
industrial safety accident rate
IST
industry standard toolset
JRP
Joint Review Panel
KI
potassium iodide
LBLOCA
large-break loss-of-coolant accident
LCH
licence conditions handbook
LCMP
lifecycle management program
LLOCA
large loss-of-coolant accident
LLW
low-level waste
LOCA
loss-of-coolant accident
LRF
large-release frequency
LTI
lost-time injury
MSC
minimum shift complement
MWe
megawatts electrical
NB Power
New Brunswick Power Corporation
NEA
Nuclear Energy Agency
NPP
nuclear power plant
NSCA
Nuclear Safety and Control Act
OPEX
operating experience
OPG
Ontario Power Generation Inc.
PIP
periodic inspection program
PLNGS
Point Lepreau Nuclear Generating Station
PNERP
Provincial Nuclear Emergency Response Plan
PNGS
Pickering Nuclear Generating Station
PPS
Provincial Policy Statement
PROL
nuclear power reactor operating licence
PRSL
power reactor site preparation licence
PSA
probabilistic safety assessment
PSR
periodic safety review
PWMF
Pickering Waste Management Facility
R&D
research and development
RD
regulatory document
RD/GD
regulatory document/guidance document
REGDOC
regulatory document
RWOS-1
SAMG
severe accident management guideline
SAT
systematic approach to training
SCA
safety and control area
SIO
station improvement opportunity
SOE
safe operating envelope
SRWMF
SSC
structures, systems and components
WANO
World Association of Nuclear Operators
WMF
Waste Management Facility
WWMF
Western Waste Management Facility

## Glossary

For definitions of terms used in this document, see CNSC REGDOC-3.6, Glossary of CNSC Terminology which contains terms and definitions used in the Nuclear Safety and Control Act and its associated regulations and in CNSC regulatory documents and other publications.

## Appendix A: Definitions of CNSC safety and control areas

The CNSC evaluates how well licensees meet regulatory requirements and CNSC expectations for the performance of programs in 14 safety and control areas (SCAs).

These SCAs are further divided into 69 specific areas that define the key components of the SCA. The SCAs and specific areas used in the CNSC’s safety performance evaluation for 2017 are given in table A.1.

Table A.1: SCAs and specific areas for assessing licensee safety performance
SCA Specific area
Management system
• Management system
• Organization
• Change management
• Safety culture
• Configuration management
• Records management
• Management of contractors
• Performance assessment, improvement and management review
• Problem identification and operating experience
Human performance management
• Human performance program
• Personnel training
• Personnel certification
• Initial certification examinations and requalification tests
• Work organization and job design
• Fitness for duty
Operating performance
• Procedures
• Reporting and trending
• Outage management performance
• Safe operating envelope
• Severe accident management and recovery
• Accident management and recovery
Safety analysis
• Deterministic safety analysis
• Probabilistic safety assessment
• Criticality safety
• Severe accident analysis
• Management of safety issues (including R&D programs)
Physical design
• Design governance
• Site characterization
• Facility design
• Structure design
• System design
• Component design
Fitness for service
• Equipment fitness for service/equipment performance
• Maintenance
• Structural integrity
• Aging management
• Chemistry control
• Periodic inspection and testing
• Application of as low as reasonably achievable (ALARA)
• Worker dose control
• Estimated dose to public
Conventional health and safety
• Performance
• Practices
• Awareness
Environmental protection
• Effluent and emissions control (releases)
• Environmental management system
• Assessment and monitoring
• Protection of the public
• Environmental risk assessment
Emergency management and fire protection
• Conventional emergency preparedness and response
• Nuclear emergency preparedness and response
• Fire emergency preparedness and response
Waste management
• Waste characterization
• Waste minimization
• Waste management practices
• Decommissioning plans
Security
• Facilities and equipment
• Response arrangements
• Security practices
• Drills and exercises
Safeguards and non-proliferation
• Nuclear material accountancy and control
• Access and assistance to the International Atomic Energy Agency
• Safeguards equipment, containment and surveillance
Packaging and transport
• Package design and maintenance
• Packaging and transport
• Registration for use
Other matters of regulatory interest
• Public information program
• Indigenous relations
• Nuclear liability insurance
• Financial guarantees

### 1. Management system

This SCA covers the framework that establishes the processes and programs required to ensure that an organization achieves its safety objectives, continuously monitors its performance against these objectives and fosters a healthy safety culture.

Performance objective

There is an effective management system that addresses all requirements and related objectives, and enables the licensee to continuously monitor and manage performance against those objectives and maintain a healthy safety culture.

### 2. Human performance management

This SCA covers activities that enable effective human performance developing and implementing processes that ensure licensees have sufficient personnel in all relevant job areas (i.e., people with the necessary knowledge, skills, procedures and tools to carry out their duties safely).

Performance objective

There is a sufficient number of workers, and human performance is managed so that all workers are capable, competent, qualified and supported to carry out their work tasks safely.

### 3. Operating performance

This SCA includes an overall review of both licensed activities and activities that enable effective performance.

Performance objective

Plant operation is safe and secure, with adequate regard for health, safety, security, radiation and environmental protection, and international obligations.

### 4. Safety analysis

This SCA involves maintaining the safety analyses that support the overall safety case for a facility. Safety analysis involves the systematic evaluation of potential hazards associated with the conduct of a proposed activity or facility. It considers the effectiveness of preventive measures as well as strategies for reducing the effects of these hazards. For nuclear power plants (NPPs), safety analysis is primarily deterministic in demonstrating the effectiveness of implementing the fundamental safety functions of “control, cool and contain” through a defence-in-depth strategy. To identify challenges to physical barriers, risk contributors are considered using probabilistic safety assessment. However, appropriate safety margins should be applied to address the uncertainties and limitations of safety analysis approaches.

Performance objective

Updates to safety analyses effectively incorporate feedback from various sources to continually demonstrate the ability to adequately control power, cool the fuel and contain or limit any releases from the plant.

### 5. Physical design

This SCA relates to activities that affect the ability of structures, systems and components (SSCs) to meet and maintain their design basis, taking into account new information as it arises and changes in the external environment.

Performance objective

Structures, systems and components that are important to safety and security continue to meet their design basis.

### 6. Fitness for service

This SCA covers activities that affect the physical condition of SSCs to ensure that they remain effective over time. This includes programs that ensure that all equipment is available to perform its intended design function when needed.

Performance objective

SSCs – the performance of which may affect safety or security – remain available, reliable, effective and consistent with design, analysis and quality control measures.

This SCA covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations. This program must ensure surface contamination levels and radiation doses received by individuals are monitored, controlled and maintained as low as reasonably achievable (ALARA).

Performance objective

The health and safety of persons are protected through the implementation of a radiation protection program that ensures that radiation doses are kept below regulatory dose limits and are optimized and maintained ALARA.

### 8. Conventional health and safety

This SCA covers the implementation of a program to manage workplace safety hazards and protect personnel and equipment.

Performance objective

Conventional health and safety work practices and conditions achieve a high degree of personnel safety.

### 9. Environmental protection

This SCA covers programs that identify, control and monitor all releases of radioactive and hazardous substances and the effects on the environment resulting from facilities or licensed activities.

Performance objective

The licensee takes all reasonable precautions to protect the environment and the health and safety of persons. This includes identifying, controlling and monitoring the release of nuclear and hazardous substances into the environment.

### 10. Emergency management and fire protection

This SCA covers emergency plans and preparedness programs for emergencies and non-routine conditions (including results of participation in exercises).

Performance objective

Emergency preparedness measures and fire protection response capabilities are in place to prevent nuclear and hazardous substance releases and mitigate their effects both onsite and offsite and prevent fire hazards in order to protect workers, the public and the environment.

### 11. Waste management

This SCA covers a facility’s internal waste-related programs up to the point where the waste is removed and transferred to a separate waste management facility. This SCA also covers planning for decommissioning.

Performance objective

A facility- and waste stream-specific waste management program is fully developed, implemented and audited to control and minimize the volume of nuclear waste generated by the licensed activity. Waste management is included as a key component of the licensee’s corporate and safety culture. A decommissioning plan is maintained.

### 12. Security

This SCA covers programs required to implement and support the security requirements stipulated in the regulations, licence and orders, as well as expectations for the facility or activity.

Performance objective

The loss, theft or sabotage of nuclear material or sabotage of the licensed facility is prevented.

### 13. Safeguards and non-proliferation

This SCA covers the programs and activities required of a licensee to successfully implement the obligations arising from the Canada/International Atomic Energy Agency (IAEA) safeguards agreements and the Treaty on the Non-Proliferation of Nuclear Weapons.

Performance objective

The licensee conforms with measures required to meet Canada’s international safeguards obligations through the:

• timely provision of accurate reports and information
• provision of access and assistance to IAEA inspectors for verification activities
• submission of annual operational information and accurate design information on plant structures, processes and procedures
• development and satisfactory implementation of appropriate facility safeguards procedures
• demonstration of capability, as confirmed through CNSC onsite evaluations, of meeting all requirements in support of physical inventory verifications of nuclear material by the IAEA

### 14. Packaging and transport

This SCA covers the programs for the safe packaging and transport of nuclear substances to and from the licensed facility.

Performance objective

The packaging and transport of nuclear substances are conducted in a safe manner.

## Appendix B: Darlington new build

On August 17, 2012, a Commission panel announced its decision to issue a nuclear power reactor site preparation licence (PRSL) to OPG for the new nuclear project at the Darlington site.

Under the Canadian Environmental Assessment Act, an environmental assessment of the project is required prior to any licensing decisions for a PRSL. A joint review panel (JRP) carried out this assessment in 2011. The assessment and PRSL were challenged through an application for judicial review before the Federal Court of Canada and associated appeals.

Ultimately, the decision was upheld; see References 1 for details. The PRSL is for a period of 10 years,   from August 17, 2012 to August 17, 2022.

As required in the PRSL, work activities between 2015 and 2017 were related to the JRP’s recommendations. Specifically, OPG carried out the following activities, which were monitored by CNSC:

• bank swallow monitoring and mitigation
• support for CNSC activities to engage stakeholders in developing a policy for land use around nuclear generating stations
• development of a methodology to help the siting of intake and diffuser structures in Lake Ontario

### Bank swallow monitoring and mitigation

The construction and operation of a new NPP at the Darlington site will require the removal of natural bluffs to a certain extent along the northern shoreline of Lake Ontario. These bluffs are known to provide habitats for the bank swallow that could be lost in the development of a new NPP. The JRP recommended that artificial bank swallow nest habitats be constructed to keep the population as close to the original bluff site as possible.

To address the JRP’s recommendations, surveys of bank swallow burrows at the Darlington site and surrounding area have been conducted since 2008 to understand the changes in the population of bank swallows in the natural bluffs at the Darlington site and vicinity over time.

In February 2018, CNSC staff received and reviewed the results of OPG’s 2017 bank swallow program. The lowest number of burrows was recorded in 2017 since the initiation of the monitoring surveys. These results were at least partly attributed to the atypical conditions in 2017. Given the ephemeral nature of the bank swallow habitat, annual variations in the number of burrows observed are not unexpected.

The bank swallow program report also indicated that no bank swallow nesting was observed from 2012 to 2017 within the earthen embankment/mound artificial nesting habitat structure. As part of the mitigation strategies, given the lack of (or minimal) nesting in the artificial mound over the survey period, OPG elected to design a new nesting structure, which will be tested once complete.

### Land use planning

Taking into consideration the lessons learned from the Fukushima Daiichi accident, the JRP was of the opinion that residential areas should not be located within three kilometres of a nuclear site. Appropriate steps had to be taken to evaluate and define buffer zones around nuclear facilities. Given this, the JRP made recommendations to the CNSC, the Government of Ontario and the Municipality of Clarington regarding land use planning.

Specifically, the JRP’s recommendations were in relation to:

• policy development for land use around nuclear generating stations
• provincial prevention of sensitive land uses within three kilometres of the site boundary
• municipal prevention of sensitive land uses within three kilometres of the site boundary
• management of development in the vicinity of the project site to ensure capacity for evacuation

Significant efforts have been made by various levels of government in response to the JRP’s recommendations on land use planning. In 2013, as part of its activities to address the JRP’s recommendations, the CNSC hosted a land-use planning workshop for OPG staff and municipal, regional and provincial stakeholders. The CNSC continues to monitor recommendations stemming from this workshop.

The key activities and progress to date are as follows.

• The Government of Ontario released its revised 2014 provincial policy statement, including a new policy on land use compatibility. It was further supported by definitions of “sensitive land uses” and “major facilities” that include energy-generating facilities such as NPPs.
• The Region of Durham committed to updating its official plan to align it with the provincial policy statement. The municipal comprehensive review was initiated in June 2018, and this process is expected to be complete by 2022.
• The Municipality of Clarington revised its official plan on November 1, 2016. It included municipal policies to align with the 2014 provincial policy statement on land use planning. CNSC staff continued to monitor, with OPG and the Municipality of Clarington, the implementation of the revised official plan to ensure that the intent of the JRP’s recommendations were met.

### Methodology for determining potential location for intake and diffuser structure in Lake Ontario

In preparation for building the cooling structure of a new NPP, OPG was evaluating the potential impact of the future cooling intake and outtake on Lake Ontario. In 2016, OPG prepared sampling methodology for a field collection program on different fish species to assist in siting the new intake and diffuser. The sampling methodology report was submitted in 2017. The CNSC, in cooperation with Environment and Climate Change Canada and Fisheries and Oceans Canada, reviewed this report and accepted the methodology.

### Work activities anticipated in 2018

OPG anticipates the following work activities in 2018:

• the implementation of aquatic sampling to support decision making related to the siting of intake and diffuser
• continued monitoring of the natural habitat of bank swallows along the lakeshore on the Darlington site and surrounding area, and finalized design and construction of a fixed-face earthen embankment
• continued monitoring of the provincial policy statement implementation at the regional and municipal level regarding land use planning
• OPG’s presentation of a mid-term report to the Commission on the activities undertaken in the first five years of the PRSL

## Appendix C: Rating definitions and methodology

### Definitions

The performance ratings used in this report are defined as follows:

Fully satisfactory (FS)

The safety and control measures implemented by the licensee are highly effective. In addition, compliance with regulatory requirements is fully satisfactory, and compliance within the safety and control area (SCA) or specific area exceeds requirements and CNSC expectations. Overall, compliance is stable or improving, and any problems or issues that arise are promptly addressed.

Satisfactory (SA)

The safety and control measures implemented by the licensee are sufficiently effective. In addition, compliance with regulatory requirements is satisfactory. Compliance within the SCA meets requirements and CNSC expectations. Any deviation is minor and any issues are considered to pose a low risk to the achievement of regulatory objectives and CNSC expectations. Appropriate improvements are planned.

Below expectations (BE)

The safety and control measures implemented by the licensee are marginally ineffective. In addition, compliance with regulatory requirements falls below expectations. Compliance within the SCA deviates from requirements or CNSC expectations to the extent that there is a moderate risk of ultimate failure to comply. Improvements are required to address identified weaknesses. The licensee is taking appropriate corrective action.

Unacceptable (UA)

The safety and control measures implemented by the licensee are significantly ineffective. In addition, compliance with regulatory requirements is unacceptable and is seriously compromised. Compliance within the SCA is significantly below requirements or CNSC expectations, or there is evidence of overall non-compliance. Without corrective action, there is a high probability that the deficiencies will lead to unreasonable risk. Issues are not being addressed effectively, no appropriate corrective measures have been taken and no alternative plan of action has been provided. Immediate action is required.

### Rating methodology

The methodology for rating licensees relies on multiple sources of input and involves both the judgment of CNSC staff and a systematic computational roll-up of results. The methodology involves ratings at three distinct levels:

• specific areas
• SCAs
• overall rating

The methodology is illustrated in figure C.1. To simplify the illustration, only four specific areas and two SCAs are shown.

Steps shown, from top to bottom in figure C.1, are as follows.

#### Step 1: Identify the findings

Findings are identified for each specific area using information from a variety of sources, including CNSC staff compliance verification inspections and desktop reviews. Each finding is assigned to the most applicable specific area under an SCA.

#### Step 2: Assess the findings

CNSC staff evaluate the safety significance of each finding and assign the appropriate category: high, medium, low, negligible or compliant. The significance depends on the degree to which a specific area’s effectiveness is negatively affected, and it is determined in the context of the verification criteria for the inspection or desktop review that generated the finding. The five categories of safety significance are:

High
Licensee’s measures are absent, completely inadequate or ineffective for meeting expectations or the intent of CNSC requirements and compliance expectations.
Medium
Performance significantly deviates from expectations or from the intent or objectives of CNSC requirements and compliance expectations.
Low
Performance deviates from expectations or from the intent or objectives of CNSC requirements and compliance expectations.
Negligible
Performance insignificantly deviates from expectations or objectives of CNSC requirements and compliance expectations.
Compliant
Performance meets applicable CNSC requirements and compliance expectations.

#### Step 3: Rate the specific area

CNSC staff consider the safety significance of all relevant findings and assess the overall effectiveness of the safety and control measures for the specific area. The assessment is in the context of the performance objective for the relevant SCA; the result is a performance rating of FS, SA, BE or UA for each specific area.

CNSC staff then convert the performance rating to a numerical value between one and ten using the grid in table C.1; staff choose an appropriate value in increments of 0.1 within the range shown in the second column. In determining the numerical value, CNSC staff consider information in addition to the relevant findings, such as observations from staff surveillance and monitoring, the licensee’s improvement initiatives and R&D effort relevant to the specific area.

Table C.1: Numerical ranges for rating categories
Rating Specific area value SCA range
UA 0.0 – 3.9 0.00 – 3.99
BE 4.0 – 5.9 4.00 – 5.99
SA 6.0 – 7.9 6.00 – 7.99
FS 8.0 – 10.0 8.00 – 10.00

#### Step 4: Rate the SCA

Individual specific area values are averaged to determine the overall SCA value, which is then converted to an SCA rating using the ranges shown in the second column of table C.1.

#### Step 5: Determine the overall rating

CNSC staff determine the overall rating for the facility by considering all SCA ratings and judging overall achievement of the performance objectives of all SCAs and the broad safety objectives for the facility.

#### Example

##### Steps 1 and 2: Identify and assess the findings

This example is for DNGS. For 2017, CNSC inspectors and specialists made 361 findings for DNGS from compliance verification activities, assigned them to SCAs and specific areas, and determined their safety significance. The findings included 40 findings of low safety significance, 43 findings of negligible safety significance and 278 findings of compliance (no medium- or high-significance findings).

##### Step 3: Rate the specific area

The example SCA is conventional health and safety, for which a total of 34 findings were made for DNGS, distributed across the three specific areas. Of these findings, 22 were findings of compliance, nine were of negligible safety significance and three were of low safety significance. Based on the findings, the CNSC specialists assessed the specific areas as “fully satisfactory” or “satisfactory”, as shown in table C.2. The specialists then determined the numerical value for each specific area rating, considering not only the findings but also information from regulatory surveillance and monitoring during 2017. The values chosen are also shown in table C.2.

Table C.2: Example SCA rating – Conventional health and safety
Specific Area Number of findings by safety significance Specific area rating SCA rating
Compliant Negligible Low Medium High Category Value
Performance 0 0 0 0 0 FS 9.5
Practices 5 2 0 0 0 SA 7.0
Awareness 17 7 3 0 0 SA 7.5
Total 22 9 3     Average 8.00 FS
##### Step 4: Rate the SCA

As indicated in table C.2, the numerical ratings for the specific areas were averaged to determine the numerical SCA rating (8.00) which was then converted to a rating category (i.e., fully satisfactory) using the rating grid (third column in table C.1).

##### Step 5: Determine the overall rating

CNSC staff determined the overall rating for DNGS by considering both the SCA ratings (repeated in table C.3) and subjectively assessing the overall safety of the NPP, as compared to 2016 (and as compared to other Canadian NPPs). CNSC staff determined that overall, the DNGS’s safety performance warranted a “fully satisfactory” rating for 2017.

Table C.3: SCA ratings for the DNGS
SCA Rating
Management system SA
Human performance management SA
Operating performance FS
Safety analysis FS
Physical design SA
Fitness for service SA
Conventional health and safety FS
Environmental protection SA
Emergency management and fire protection SA
Waste management FS
Security SA
Safeguards and non-proliferation SA
Packaging and transport SA

### SCA ratings from 2016

Table C.4 presents the SCA ratings for 2016 for the NPPs. Most are taken from reference References 1, but the ratings for Gentilly-2 are from the licence renewal in 2015.

Table C.4: 2016 SCA ratings for NPPs
Safety and control area Bruce A Bruce B DNGS PNGS Point Lepreau Gentilly-2
Management system SA SA SA SA SA SA
Human performance management SA SA SA SA SA SA
Operating performance FS FS FS FS SA SA
Safety analysis FS FS FS FS FS SA
Physical design SA SA SA SA SA SA
Fitness for service SA SA SA SA SA SA
Radiation protection FS FS FS SA SA SA
Conventional health and safety FS SA SA FS FS SA
Environmental protection SA SA SA SA SA SA
Emergency management and fire protection SA SA SA SA SA SA
Waste management FS FS FS FS SA SA
Security SA SA SA SA SA SA
Safeguards and non-proliferation SA SA SA SA SA SA
Packaging and transport SA SA SA SA SA SA
Integrated plant rating FS SA FS FS SA SA

Table C.5 presents the ratings for the WMFs for 2016. The 2016 SCA ratings for PWMF and WWMF were provided during their licence renewal proceedings in 2017. The 2016 SCA ratings for DWMF were compiled “retroactively” in preparing this regulatory oversight report. For each WMF, the overall rating for 2016 was also determined retroactively using a similar approach to the one used for NPPs.

Table C.5: 2016 SCA Ratings for WMFs
Safety and control area DWMF PWMF WWMF
Management system SA SA SA
Human performance management SA SA SA
Operating performance FS FS FS
Safety analysis FS FS FS
Physical design SA SA SA
Fitness for service SA SA SA
Conventional health and safety FS FS FS
Environmental protection SA SA SA
Emergency management and fire protection SA SA SA
Waste management SA SA SA
Security SA FS FS
Safeguards and non-proliferation SA SA SA
Packaging and transport SA SA SA
Overall rating SA SA SA

## Appendix D: Research and development efforts in support of NPP regulation

This appendix provides information on research and development (R&D) activities to enhance the safety of NPP operations, as well as information on safety issues that drive the R&D activities and which are the subject of the CNSC’s regulatory oversight for NPPs. The R&D activities are conducted by NPP licensees and their industry partners, as well as the CNSC.

### Industry R&D activities

The CANDU Owners Group (COG) R&D program and the Industry Standard Toolset (IST) program were established to support the safe, reliable and efficient operation of CANDU reactors. They are managed under five technical areas:

• Fuel channels
• Safety and licensing
• Health, safety and the environment
• Chemistry, materials and components
• IST

The R&D and IST programs are sponsored by three Canadian utilities (Bruce Power, OPG and NB Power), the Romanian Societatea Nationala Nuclear Electrica and Canadian Nuclear Laboratories. In 2016–17, Korea Hydro and Nuclear Power Company sponsored the safety and licensing technical area and the IST program. In 2017, the CNSC reviewed submissions on the work plans, analysis methodology and results for these ongoing programs.

Bruce Power and OPG also continued a joint COG R&D initiative, the fuel channel life-management project, which aims to develop the engineering methodologies and analytical tools necessary to continue demonstrating the fitness for service of fuel channels.

### CNSC R&D activities

The CNSC manages an active extramural research program that focuses on regulatory issues and SCAs. The program also contributes to many international programs relevant to NPP safety. Examples of research activities that were active in 2017 and that are relevant to NPPs are given below. When the research activities are completed, the final reports are posted on the CNSC’s scientific and technical information web page.

### Fitness for service

#### Analysis of degradation mechanisms of cable insulation due to aging in a decommissioned NPP

Understanding the degradation of cables due to aging and exposure to harsh environmental conditions is an important part of ensuring the fitness for service of an NPP. With the cooperation of Hydro-Québec, cables from the permanently shut down reactor at Gentilly-2 were being recovered. These cables will be subject to laboratory analysis to assess their degree of degradation. The results will be used to validate the codes, standards and accelerated test procedures that are currently in use.

#### Statistical modeling of aging effects in failure rates of piping components

The CNSC is sponsoring the development of a generic guidance document that will outline the methods and techniques to determine statistical operability in events involving degradation or failure involving metallic (e.g., carbon steel) passive components.

#### Investigation of consequences of concrete alkali-aggregate reaction on existing nuclear structures

As NPPs age and life extension is considered, it is important to understand the effect of potential degradation mechanisms for existing civil structures. Specifically, this project explores the effect that concrete alkali-aggregate reactions have on existing nuclear structures.

#### Development of testing standards to test pressure tube material properties

Fracture toughness measurements of irradiated zirconium-niobium (Zr-2.5Nb) are important to ensure leak-before-break of pressure tubes. The objective of this project is to standardize small-scale fracture toughness testing procedures for irradiated Zr-2.5Nb pressure tubes used in Canadian NPPs. This information will assist the CNSC in independently verifying fitness-for-service assessments of pressure tubes.

#### An experimental study of the effects of flat bar supports on streamwise fluidelastic instability in nuclear steam generators

CANDU utilities are in the process of replacing aging steam generators. The replacement steam generators differ from the original, already-licensed steam generators. The purpose of this project is to better understand flow-induced vibration in steam generator tubes. The research will result in a guide for the regulatory assessment of the design and operation of replacement steam generators for CANDU reactors.

### Safety analysis

#### Analysis of severe irradiated fuel bay accident PKPIRT package

An expert panel was formed to gather the information required to establish a code for modeling potential severe accidents in a CANDU irradiated fuel bay. The panel delivered the phenomena and key parameters identification and ranking table (PKPIRT) and made recommendations to the CNSC on how to implement the code.

#### Hydrogen/CO combustion and passive autocatalytic recombiner (PAR) behaviour

Studies are needed to determine PAR capacity to oxidize CO under postulated accident conditions. The large-scale, vented combustion test facility at Whiteshell underwent modifications to allow testing that uses H2-CO mixtures. The results of the planned experiments will help CNSC to regulate severe accident management.

#### Studies of molten metal solidification in internal pipe flows

This research project aims to analytically and experimentally study molten metal solidification in internal pipe flows to gain insights into corium behaviour for various flow cross-section geometries. This study will enhance the understanding of the flow of melted material, and its results are expected to help CNSC staff understand the impact of vessel penetrations on in-vessel retention (IVR) and provide a better technical basis for the evaluation of the licensees’ strategy for severe accident management.

#### Integrated framework for propagation of uncertainties

The CNSC initiated a study to investigate the feasibility of developing a first-of-its-kind integrated framework for uncertainty characterization, with primary application to CANDU neutronics calculations. This study has been undertaken with the aim of enhancing the CNSC’s capability to independently verify safety cases that use more realistic methodologies, in particular those that rely on complex analytical simulations that couple computational procedures for 3D-neutronics and thermal-hydraulics.

### CANDU safety issues

Table D.1 provides the definitions of the three categories of CANDU safety issues (CSIs).

Table D.1: Categories of CSI safety significance
Category Meaning
2 The issue is a concern in Canada. However, the licensees have appropriate control measures in place to address the issue and to maintain safety margins.
3 The issue is a concern in Canada. Measures are in place to maintain safety margins, but further experiments and/or analyses are required to improve knowledge and understanding of the issue, and to confirm the adequacy of the measures.

Table D.2 lists the remaining category 3 CSIs for NPPs that are relevant to large-break loss-of-coolant accidents (LBLOCA)

Table D.2: Details of Category 3 LBLOCA CANDU safety issues open during 2017
CSI Title Brief description
AA9 Analysis for void reactivity coefficient The LBLOCA design-basis event is one of the most difficult accidents to analyze for a CANDU reactor, because many aspects of reactor behaviour under accident conditions are subject to uncertainties.
PF9 Fuel behaviour in high-temperature transients
PF10 Fuel behaviour in power-pulse transients
Table D.3: Details of the Category 3 non-LBLOCA CSIs open during 2017
CSI Title Brief description
IH6 Systematic assessment of high-energy line-break effects Dynamic effects high-energy line breaks (e.g., pipe whip, jet impingement) can cause consequential failure of SSCs and impair defence in depth.

## Appendix E: List of regulatory requirements at the end of 2017

Table E.1 lists published CNSC regulatory documents and CSA Group standards that contain compliance verification criteria used by CNSC staff for the SCAs covered in this regulatory oversight report. The information was compiled from the various facility license conditions handbooks (LCHs) as they existed in December 2017; the PWMF did not have an LCH at that time, but the draft LCH for the licence renewal was used. The main body of this report may include more up-to-date information on the implementation of some of these documents, as well as more recently published documents that were not reflected as compliance verification criteria in LCHs in December 2017.

Legend

A check mark indicates that the publication was included as compliance verification criteria for the facility at the end of 2017.

A dash indicates that the publication was not included as compliance verification criteria.

A date indicates the year in which the licensee indicated it planned to fully implement the requirements in the publication.

Table E.1: Publications used as compliance verification criteria
Source Number Title Year SCA Bruce DNGS DWMF PNGS PWMF PLNGS Gentilly-2 WWMF
CSA N286 Management system requirements for nuclear power plants 2005 1 - - - - - -
CSA N286 Management system requirements for nuclear facilities 2012 1 -
CNSC REGDOC-2.2.2 Personnel Training 2014 2 - -
CNSC RD-204 Certification of Persons Working at Nuclear Power Plants 2008 2 - - -
CNSC EG1* Requirements and Guidelines for Written and Oral Certification Examinations for Shift Personnel at Nuclear Power Plants 2005 2 - - -
CNSC EG2* Requirements and Guidelines for Simulator-Based Certification Examinations for Shift Personnel at Nuclear Power Plants 2004 2 - - -
CNSC * Requirements for the Requalification Testing of Certified Shift Personnel at Nuclear Power Plants 2009 2 - - -
CNSC RD-363 Nuclear Security Officer Medical, Physical and Psychological Fitness 2008 2
CNSC REGDOC-2.2.4 Fitness for Duty Volume I: Managing Worker Fatigue 2017 2 - 2019 2019 2019 2019 2022 - 2019
CNSC REGDOC-2.2.4 Fitness for Duty Volume II: Managing Alcohol and Drug 2017 2 - 2019 2019 2019 2019 - - -
CNSC REGDOC-2.3.3 Periodic Safety Reviews 2015 3 - - - - - -
CNSC REGDOC-3.1.1 Reporting Requirements for Nuclear Power Plants 2014 3 - - - - -
CNSC REGDOC-3.1.1 Reporting Requirements for Nuclear Power Plants, version 2 2016 3 - - - - - -
CSA N290.15 Requirements for the safe operating envelope of nuclear power plants 2010 3 - - - -
CNSC REGDOC-2.3.2 Accident Management: Severe Accident Management Programs for Nuclear Reactors 2013 - - - - - - -
CSA N290.11 Requirements for reactor heat removal capability during outage of nuclear power plants 2013 3 - - - - - - -
CSA N286.7 Quality Assurance of Analytical, Scientific and Design Computer Programs for Nuclear Power Plants 1999 4 - - - -
CSA N286.7 Quality Assurance of Analytical, Scientific and Design Computer Programs for Nuclear Power Plants 2016 4 - - - - - - -
CNSC REGDOC-2.4.1 Deterministic Safety Analysis 2014 4 - TBC - -
CNSC REGDOC-2.4.2 Probabilistic Safety Assessment (PSA) for Nuclear Power Plants 2014 4 2019 2020 - TBC - - -
CNSC RD-327 Nuclear Criticality Safety 2010 4 - - - - - - -
CSA N289.1 General requirements for seismic design and qualification of CANDU nuclear power plants 2008 5 - - - - - -
CSA N290.13 Environmental Qualification of Equipment for CANDU Nuclear Power Plants 2005 5 - - - -
CSA N285.0 General requirements for pressure-retaining systems and components in CANDU nuclear power plants 2008 5 - - -
CSA N285.0 General requirements for pressure-retaining systems and components in CANDU nuclear power plants (including updates 1 and 2) 2012 5 - - - -
CSA N290.12 Human factors in design for nculear power plants 2014 5 - - - - - - -
CSA N290.0 General requirements for safety systems of nuclear power plants 2011 5 - - - - - - -
CSA N291 Requirements for safety related structures for CANDU nuclear power plants 2008 5 - - - - -
CSNC RD/GD-98 Reliability Programs for Nuclear Power Plants 2012 6 - - - -
CNSC RD/GD-210 Maintenance Programs for Nuclear Power Plants 2012 6 - - - -
CSA N285.4 Periodic inspection of CANDU nuclear power plant components 2005 6 - - - - -
CSA N285.4 Periodic inspection of CANDU nuclear power plant components 2009 6 - - - - -
CSA N285.5 Periodic inspection of CANDU nuclear power plant containment components 2008 6 - - - -
CSA N287.7 In-service examination and testing requirements for concrete containment structures for CANDU nuclear power plants 2008 6 - - - -
CSA N285.8 Technical requirements for in-service evaluation of zirconium alloy pressure tubes in CANDU reactors 2010 6 - - - - - - -
CSA N285.8 Technical requirements for in-service evaluation of zirconium alloy pressure tubes in CANDU reactors 2005 6 - - - - - - -
CNSC RD-334 Aging Management for Nuclear Power Plants 2010 6 - - - - -
CNSC REGDOC-2.6.3 Aging Management 2014 6 - - -
CSA N288.1 Guidelines for calculating derived release limits for radioactive material in airbourne and liquid effluents for normal operation of nuclear facilities (include update 1) 2008 9 -
CSA N288.1 Guidelines for calculating derived release limits for radioactive material in airbourne and liquid effluents for normal operation of nuclear facilities 2014 9 2020 - - - - - - TBD
CSA N288.3.4 Performance testing of nuclear air-cleaning systems at nuclear facilities 2013 9 - - - - -
CNSC S-296 Environmental Protection, Policies, Programs and Procedures at Class I Nuclear Facilities and Uranium Mines and Mills 2006 9 - - - - - - -
CNSC REGDOC-2.9.1 Environmental Policies, Programs and Procedures 2013 9 2018 - - -
CNSC REGDOC-2.9.1 Environmental Principles, Assessments and Protection Measures, version 1.1 2017 9 - - - - - -
CSA N288.4 Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills 2010 9 2018 - TBD
CSA N288.5 Effluent monitoring programs at Class I nuclear facilities and uranium mines and mills 2011 9 2018 - - -
CSA N288.6 Environmental risk assessments at Class I nuclear facilities and uranium mines and mills 2012 9 2018 - - - -
CNSC RD-353 Testing and Implementation of Emergency Measures 2008 10 - - -
CNSC REGDOC-2.10.1 Nuclear Emergency Preparedness and Response 2014 10 2008 - - 2018 - 2018
CSA N293 Fire protection for nuclear power plants 2007 10 - - - - - - -
CSA N293 Fire protection for nuclear power plants 2012 10 - - -
CSA N393 Fire protection for facilities that process, handle, or store nuclear substances 2013 10 - - - - -
CSA N292.0 General principles for the management of radioactive waste and irradiated fuel 2014 11 - - - - -
CSA N292.2 Interim dry storage of irradiated fuel 2007 11 - - - -
CSA N292.2 Interim dry storage of irradiated fuel 2013 11 - - - - - - -
CSA N292.3 Management of low- and intermediate-level radioactive waste 2008 11 -
CSA N292.3 Management of low- and intermediate-level radioactive waste 2014 11 - - - - - -
CSA N294 Decommissioning of facilities containing nuclear substances 2009 11 -
CSA N290.7 Cyber Security 2014 12 2020 - 2019 - 2019 -
CNSC RD-321 Criteria for Physical Protection Systems and Devices at High-Security Sites 2010 12
CNSC RD-361 Criteria for Explosive Substance Detection, X-ray Imaging and Metal Detection at High Security Sites 2010 12
CNSC REGDOC-2.12.1 High-Security Sites: Nuclear Response Force 2013 12 - - - -
CNSC REGDOC-2.12.2 Site Access Security Clearance 2013 12
CNSC REGDOC-2.12.3 Security of Nuclear Substances - Sealed Sources 2013 12 - - - - -
CNSC RD-336 Accounting and Reporting of Nuclear Material 2010 13
CNSC RD/GD-99.3 Public Information and Disclosure 2012 15

*CNSC staff documents (not published as regulatory documents)

## Appendix F: Revisions to licence conditions handbooks

The tables in this appendix outline significant revisions to the licence conditions handbooks (LCHs) for the NPPs and WMFs from January 1, 2017 to April 30, 2018.

### DNGS

CNSC staff made administrative changes to the LCH-PR-13.00/2025-R001 on February 13, 2018:

• CSA Group Standard N294-09, Decommissioning of facilities containing nuclear substances
• updated financial guarantee
• revised minimum shift complement to reflect defueled status of Unit 2
• aligned with other power reactor LCH’s for consistency
• updated text to reflect completion of implementation plans, referred to new CNSC regulatory documents and introduced new compliance verification criteria from the guidance section
• corrected previous erroneous omission of elemental tritium in the derived release limits table
• added implementation of cyber security requirements
• updated requirements for safeguards reporting

### PNGS

CNSC staff made technical and administrative changes to the LCH on July 1, 2017:

• updated CVC to reflect new Nuclear Liability and Compensation Act
• removed requirement for licensee to notify CNSC when insurance policy is changed
• updated reference to WN document
• updated CVC with OPG implementation plan for REGDOC-2.2.4
• updated MSC table – removed stock keeper role
• updated CVC to reflect
• CSNC approval to defer Unit 8 reactor building leakage rate test
• CNSC acceptance of OPG compliance plan for N285.8-15
• updated CVC to reflect latest submission of PDP
• updated CVC to reflect OPG compliance with REGDOC-2.12.3
• revised preamble and CVC to reflect the end of commercial operation date of December 31, 2024, and revised CNSC expectations
• added new licence condition and LCH section for PROL amendment authorizing the import/export of contaminated laundry

### Point Lepreau

CNSC staff made no changes to the LCH-PR-17.00/2022-R000 following the PROL renewal.

Bruce A and B

CNSC staff made technical and administrative changes to the LCH-BNGS-R002 on February 1, 2017:

• Section 4.1: The implementation strategy for transitioning to CNSC REGDOC-2.4.2, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants was updated, and the target date for full compliance to REGDOC-2.4.2 was set as June 30, 2019.
• Section 6.1: The expected dates for compliance with CNSC REGDOC-2.6.3, Fitness for Service: Aging Management for remaining lifecycle management plans were set for feeders and steam generators by April 2017 and for fuel channels by June 2017.
• Part I (several sections and appendices): Minor editorial changes were made throughout the LCH.
• Section 12.1: CNSC staff added CSA Group standard, N290.7-14, Cyber security for nuclear power plants and small reactor facilities as compliance verification criteria and the date for Bruce Power’s transition (December 31, 2020).

CNSC staff also made technical and administrative changes to the LCH-BNGS-R003 on July 1, 2017:

• Section G.1, G.2: CNSC staff added text to incorporate the supporting activities at the Central Maintenance and Laundry Facilities.
• Sections 4.1. CNSC staff added text to the implementation strategy for CNSC REGDOC-2.4.1, Deterministic Safety Analysis, indicating that Bruce Power, along with industry partners, had developed a set of derived acceptance criteria for slow events.
• Section 5.2: CNSC staff removed CSA Group standard N285.6, Material standards for reactor components for CANDU nuclear power plants, since the reference to CSA Group standard N285.0-12, General requirements for pressure-retaining systems and components in CANDU nuclear power plants had sufficient references to cover N285.6.
• Section 6.1: Administrative and editorial changes.
• Section 7.1: Added action levels for Central Maintenance and Laundry Facility (CMLF) to the table. Specifically, the following additions were made: Unplanned External Exposure: 250µSv (25 mrem) or more above planned dose. Made other editorial changes.
• Sections 9.1, 9.2: CMLF derived release limits were added to the table. Editorial changes.
• Section 10.2: Editorial changes.
• Appendices C and D: Added CNSC REGDOC-2.3.2, Accident Management, CSA Group and COG documents

### Gentilly-2

CNSC staff have made no changes to the MCP-GENTILLY-2- R000 since July 1, 2016.

### DWMF

CNSC staff made no changes to the LCH-W4-355.01/2023 in 2017.

### PWMF

CNSC staff made no changes to the LCH-W4-350.00/2028 in 2017.

### WWMF

CNSC staff made no changes to the LCH-W4-314.00/2027 in 2017.

## Appendix G: Five-year trends in compliance activities

In the following tables, “other compliance activities” includes verification activities such as surveillance, monitoring and reviews of licensee-submitted documents and reports (other than event reports).

### DNGS

Table G.1: Five-year trend in compliance activities for DNGS
Compliance activities effort (person-days) 2013 2014 2015 2016 2017
Inspections 1,275 1,226 1,079 1,422 1,422
Event reviews 180 214 128 114 120
Other compliance activities 2,338 2,290 2,141 1,947 2,160
Total effort 3,793 3,730 3,348 3,483 3,702

### PNGS

Table G.2: Five-year trend in compliance activities for PNGS
Compliance activities effort (person-days) 2013 2014 2015 2016 2017
Inspections 1,643 1,460 1,460 1,156 1,764
Event reviews 286 228 132 118 130
Other compliance activities 2,702 3,245 3,453 3,659 2,603
Total effort 4,630 4,933 5,045 4,933 4,497

### Point Lepreau

Table G.3: Five-year trend in compliance activities for Point Lepreau
Compliance activities effort (person-days) 2013 2014 2015 2016 2017
Inspections 1,520 1,079 1,030 785 981
Event reviews 82 80 58 72 70
Other compliance activities 1,435 1,402 1,874 2,136 1,466
Total effort 3,037 2,561 2,962 2,993 2,517

### Bruce A and B

Table G.4: Five-year trend in compliance activities for Bruce A and B
Compliance activities effort (person-days) 2013 2014 2015 2016 2017
Inspections 1,540 1,520 1,030 1,226 1,716
Event reviews 234 250 198 192 184
Other compliance activities 3,297 3,597 3,899 3,632 2,971
Total effort 5,071 5,367 5,127 5,050 4,871

### Gentilly-2

Table G.5: Five-year trend in compliance activities for Gentilly-2
Compliance activities effort (person-days) 2013 2014 2015 2016 2017
Inspections 882 490 147 147 98
Event reviews 18 30 4 6 8
Other compliance activities 706 301 416 232 139
Total effort 1,606 821 567 385 245

### All NPPs

Table G.6: Five-year trend in compliance activities for Canadian NPPs
Compliance activities effort (person-days) 2013 2014 2015 2016 2017
Inspections 6,860 5,775 4,746 4,736 5,981
Event reviews 814 802 520 502 512
Other compliance activities 10,463 10,833 11,783 11,606 9,339
Total effort 18,137 17,410 17,049 16,844 15,832

### DWMF

Table G.7: Five-year trend in compliance activities for the DWMF
Compliance activities effort (person-days) 2013 2014 2015 2016 2017
Number of inspections 1 4 5 6 3
Licensing activities 7 10 44 21 75
Compliance activities 96 152 184 136 161
Total effort 103 162 228 157 236

### PWMF

Table G.8: Five-year trend in compliance activities for the PWMF
Compliance activities effort (number of inspections or person-days) 2013 2014 2015 2016 2017
Number of inspections 2 3 2 4 3
Licensing activities 16 12 7 71 209
Compliance activities 85 116 143 128 94
Total effort 101 128 150 198 303

### WWMF

Table G.9: Five-year trend in compliance activities for the WWMF
Compliance activities effort (number of inspections or person-days) 2013 2014 2015 2016 2017
Number of inspections 3 4 3 6 3
Licensing activities 6 57 17 182 258
Compliance activities 203 216 197 237 227
Total effort 209 273 214 419 485

### All WMFs

Table G.10: Five-year trend in compliance activities for Canadian WMFs
Compliance activities effort (number of inspections or person-days) 2013 2014 2015 2016 2017
Number of inspections 6 11 10 16 9
Licensing activities 29 79 68 274 542
Compliance activities 384 484 524 501 482
Total effort (person-days) 413 563 592 774 1,024

## Appendix H: Current and predicted status of key parameters and models in operating reactors with older pressure tubes

In the following, the key parameter is the concentration of equivalent hydrogen (Heq conc.), which is measured in parts per million (ppm).

Unit Status as of January 1, 2018 Future situation
Effective full power hours (EFPH) Heq Conc., ppm (inlet/outlet) Existing fracture toughness model valid? Key target (date) Anticipated effective full power hours EFPH Predicted Heq conc., ppm (inlet/outlet) Existing fracture toughness model valid?
Darlington Unit 1 ˜196,000 48 / 59 Yes Refurbishment begins Jun. 2021 ˜224,000 48 / 71 Yes
Darlington Unit 2 Refurbishment started, October 2016 n/a (fuel channels replaced during refurbishment)
Darlington Unit 3 ˜193,000 44 / 82 Yes

Refurbishment begins

Feb. 2020

˜210,000 67 / 108 Yes
Darlington Unit 4 ˜188,000 45 / 50 Yes

Refurbishment begins

Jan. 2023

˜230,000 45 / 72 Yes
Unit Status as of January 1, 2018 Future situation
Effective full power hours (EFPH) Heq Conc., ppm (inlet/outlet) Existing fracture toughness model valid? Key target (date) Anticipated effective full power hours EFPH Predicted Heq conc., ppm (inlet/outlet) Existing fracture toughness model valid?
Pickering Unit 1 134,825 29 / 34 Yes

End of service

Dec. 31 2024

192,000 36 / 84 Yes
Pickering Unit 4 107,980 22 / 25 Yes As above 167,500 34 / 64 Yes
Pickering Unit 5 229,800 43 / 58 Yes As above 287,500 49 / 97 Yes
Pickering Unit 6 234,850 36 / 56 Yes As above 295,000 48 / 90 Yes
Pickering Unit 7 228,750 38 / 55 Yes As above 287,000 48 / 91 Yes
Pickering Unit 8 216,650 35 / 51 Yes As above 274,000 48 / 86 Yes
Unit Status as of January 1, 2018 Future situation
Effective full power hours (EFPH) Heq Conc., ppm (inlet/outlet) Existing fracture toughness model valid? Key target (date) Anticipated effective full power hours EFPH Predicted Heq conc., ppm (inlet/outlet) Existing fracture toughness model valid?
Bruce Unit 1 35,877 17 / 13 Yes n/a (fuel channels replaced before Sept. 2012 return-to-service)
Bruce Unit 2 ˜36,200 No data available n/a (fuel channels replaced before Aug. 2012 return-to-service)
Bruce Unit 3 210,042 50 / 93 Yes

MCR begins

2023

˜245,000 52 / 102 Yes
Bruce Unit 4 204,451 40 / 90 Yes

MCR begins

2025

˜255,000 42 / 104 Yes
Bruce Unit 5 232,130 40 / 111 Yes

MCR begins

2026

˜300,000 45 / 151

Prerequisite:

existing fracture toughness model must be validated for Heq levels

above 120 ppm

Bruce Unit 6 227,844 40 / 112 Yes

MCR begins

2020

˜245,000 44 / 121 As above
Bruce Unit 7 224,310 40 / 92 Yes

MCR begins

2028

˜300,000 45 / 147 As above
Bruce Unit 8 211,781 44 / 69 Yes

MCR begins

2030

˜300,000 52 / 139 As above

## Appendix I: Derived release limits and radiological releases to the environment

### Derived release limits

Derived release limits (DRLs), which are uniquely calculated for each site, are rates of release that could, if exceeded, expose an individual of the most highly exposed group to a committed dose equal to the regulatory annual dose limit of 1 mSv/year. The licensees calculate DRLs using CSA Group standard N288.1-08, Guidelines for calculating derived release limits for radioactive materials in airborne and liquid effluents for normal operation of nuclear facilities. However, Hydro Quebec updated the DRLs for Gentilly-2 to the 2014 version of this standard in 2017.

While it is possible to calculate a specific DRL for each radionuclide, it may not be practical or necessary to monitor each of these separately. In such cases, emitted radionuclides may be organized into groups that are selected on the basis of factors such as physico-chemical properties and method of monitoring. DRLs can then be established for the radionuclide group applying a number of simplifying and conservative (i.e., protective) assumptions, such as assuming that the group is composed entirely of the most restrictive radionuclide representative of the group. The most restrictive radionuclide can differ for different nuclear facilities depending on releases, local conditions and the choice of the representative exposed person. Emission monitoring may then be carried out by a non-radionuclide-specific method for the group rather than for specific radionuclides. The most common DRL groupings for airborne releases are noble gases, radio-iodines, particulate beta/gamma and particulate alpha, with those for liquid releases being beta/gamma emitters and alpha.

Licensees are required to demonstrate that their releases are not only below their respective DRLs but that the sum of their release is below 1mSv/year, the regulatory dose limit for the general public. To ensure these limits are respected, licensees also are required to develop action levels significantly below their DRLs as a means of detecting elevated releases that merit follow-up investigations and actions to ensure releases are adequately controlled. For NPPs, the action levels are applied to weekly and monthly monitoring results for emissions to atmosphere and for effluent to surface waters, respectively.

### Total annual release of relevant radionuclides to the environment

Tables I.1 to I.15 provide the annual load of key radionuclides directly released to atmosphere or to surface waters from licensed facilities along with the relevant DRL. The selected reporting period encompasses 2011 to 2017, addressing the interval since the last publication of such data in 2012 References 25 which reported on the years 2001 to 2010. During this current reporting period (2011 to 2017), the DRLs have not been exceeded.

As facilities differ with respect to their onsite nuclear activities (e.g., presence of a tritium processing facility) or life-stage activities (e.g., safe shutdown) or operations (e.g., maintenance, rates of power productions), the relevant radionuclides specifically monitored and reported and the actual quantities released will vary. Licensees monitor and report results for a wide range of radionuclides; the standardized reporting documented here is based on the key radionuclides associated with dose to the general public and the facilities’ DRLs. Therefore, direct comparisons between facilities are not possible, since one facility may have different release quantities of radioactive materials than another.

For the facilities covered by this report, the most common radionuclides or radionuclide groupings of interest are tritium (HTO), iodine-131, noble gases, particulates (beta/gamma) and carbon-14 for atmospheric releases and HTO, gross beta-gamma and carbon-14 for liquid releases to surface waters. Since particulate and gross beta-gamma consists of mixtures of radionuclides, the most dose-restrictive (based on potential dose to the general public) radionuclide is often chosen to represent the mixture as the basis for comparison with the DRL.

Releases are reported in the following tables as total becquerels (Bq) per year, or in the case of noble gases, becquerel-mega electron volts (Bq-MeV). A becquerel is an International System of Units (SI) unit of radioactivity defined as the activity of a quantity of radioactive material in which one nucleus decays per second. Since the Bq is a very small unit, releases are reported here in scientific notation. In most cases, numbers are rounded to two or three significant figures. For example, for two significant figures:

• 100                     =           1.0 X 102
• 1,260,000           =           1.3 X 106
• 4,445,758,748   =           4.4 X 109

### Darlington

The data for Darlington covers both DNGS and DWMF. In addition to the standard suite of radionuclides reported for DNGS, OPG also reports atmospheric elemental tritium releases associated with the tritium removal facility, which has its own DRL for that radionuclide.

#### Releases to atmosphere

Table I.1: Trend for Darlington annual radionuclide releases to atmosphere
Year Elemental Tritium (HT) (Bq) Tritium HT) (Bq) Carbon-14 (Bq) Noble Gas Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/ gamma) (Bq) Gross alpha (Bq)
2017 DRL 8.5 X 1017 5.9 X 1016 3.5 X 1014 4.5 X 1016 1.4 X 1012 6.7 X 1011 1.0 X 1011
2017 1.4 X 1014 2.4 X 1014 1.4 X 1012 1.5 X 1013 <1.5 X 108 2.6 X 107 2.0 X 106
2016 1.7 X 1013 1.8 X 1014 1.6 X 1012 1.6 X 1013 1.4 X 108 3.2 X 107 <5.0 X 106
2015 1.7 X 1013 2.5 X 1014 1.3 X 1012 2.2 X 1013 1.4 X 108 3.5 X 107 <6.4 X 106
2014 5.2 X 1013 2.7 X 1014 1.3 X 1012 4.6 X 1013 1.6 X 108 3.1 X 107 <6.4 X 106
2013 1.8 X 1013 2.1 X 1014 1.0 X 1012 3.2 X 1013 1.4 X 108 2.9 X 107 <6.2 X 106
2012 2.6 X 1013 1.3 X 1014 1.0 X 1012 1.9 X 1013 1.4 X 108 3.4 X 107 ---
2011 8.8 X 1013 1.4 X 1014 1.0 X 1012 2.2 X 1013 1.5 X 108 4.0 X 107 ---

#### Releases to surface waters

Table I.2: Trend for Darlington annual radionuclide releases to surface waters
Year Tritium (HT) (Bq) Gross beta/gamma (Bq) Carbon-14 (Bq) Gross alpha (Bq)
2017 DRL 5.30 X 1018 7.10 X 1013 9.70 X 1014 3.20 X 1014
2017 5.6 X 1014 2.6 X 1010 1.7 X 109 <1.6 X 106
2016 3.5 X 1014 4.9 X 1010 2.2 X 109 <1.6 X 106
2015 2.4 X 1014 4.9 X 1010 7.3 X 109 <1.7 X 106
2014 1.7 X 1014 3.0 X 1010 5.5 X 109 1.8 X 106
2013 1.1 X 1014 2.8 X 1010 3.2 X 109 8.5 X 105
2012 1.3 X 1014 3.0 X 1010 6.3 X 109 9.0 X 105
2011 1.1 X 1014 3.1 X 1010 1.9 X 109 1.1 X 106

### Pickering

OPG reports releases separately for PNGS Units 1 to 4 and PNGS Units 5 to 8. The data for Pickering B includes data for PWMF.

#### Releases to atmosphere

Table I.3: Trend for PNGS Units 1 to 4 annual radionuclide releases to atmosphere
Year Tritium (HT) (Bq) Carbon-14 (Bq) Noble Gas (Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/gamma) (Bq) Gross alpha (Bq)
2017 DRL 1.2 X 1017 2.2 X 1015 3.2 X 1016 9.8 X 1012 4.9 X 1011 8.7 X 1010
2017 3.1 X 1014 1.3 X 1012 1.5 X 1014 9.6 X 106 6.9 X 106 4.8 X 105
2016 2.2 X 1014 1.2 X 1012 1.1 X 1014 9.9 X 106 5.5 X 106 3.7 X 105
2015 2.4 X 1014 1.0 X 1012 9.3 X 1013 1.4 X 107 5.3 X 106 4.5 X 105
2014 2.5 X 1014 9.1 X 1011 1.1 X 1014 1.0 X 107 4.1 X 106 3.4 X 105
2013 1.7 X 1014 7.8 X 1011 1.1 X 1014 8.4 X 106 3.7 X 106 4.4 X 105
2012 2.6 X 1014 8.8 X 1011 1.1 X 1014 1.1 X 107 4.5 X 106 ---
2011 2.1 X 1014 1.0 X 1012 9.9 X 1013 1.5 X 107 8.2 X 106 ---
Table I.4: Trend for PNGS Units 5 to 8 annual radionuclide releases to atmosphere
Year Tritium (HT) (Bq) Carbon-14 (Bq) Noble Gas (Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/ gamma) (Bq) Gross alpha (Bq)
2017 DRL 1.9 X 1017 2.0 X 1015 4.7 X 1016 8.9 X 1012 7.2 X 1011 1.2 X 1011
2017 3.8 X 1014 1.3 X 1012 3.5 X 1012 4.3 X 106 2.0 X 108 3.7 X 105
2016 4.6 X 1014 1.2 X 1012 5.8 X 1012 4.1 X 106 2.4 X 107 6.2 X 105
2015 3.0 X 1014 1.0 X 1012 1.6 X 1013 4.6 X 106 1.5 X 107 6.1 X 105
2014 2.8 X 1014 9.1 X 1011 1.1 X 1013 5.2 X 106 3.8 X 106 5.2 X 105
2013 2.4 X 1014 9.1 X 1011 6.5 X 1012 4.4 X 106 5.0 X 106 5.8 X 105
2012 2.8 X 1014 9.4 X 1011 1.9 X 1013 6.6 X 106 3.6 X 106 ---
2011 3.4 X 1014 7.7 X 1011 8.4 X 1013 8.8 X 106 3.6 X 106 ---

#### Releases to surface waters

Note that carbon-14 and gross alpha releases associated with Units 1 to 4 are included in the values for Units 5 to 8 reporting, as the radioactive liquid waste management system is discharged through the outfall for units associated with Units 5 to 8.

Table I.5: Trend for Pickering annual radionuclide releases to surface waters
Year Units 1 – 4 Units 5 – 8
Tritium (HT) (Bq) Gross beta/gamma (Bq) Tritium (HT) (Bq) Gross beta/gamma (Bq) Carbon-14 (Bq) Gross alpha (Bq)
2017 DRL 3.7 X 1017 1.7 X 1012 7.0 X 1017 3.2 X 1012 6.0 X 1013 2.6 X 1013
2017 1.1 X 1014 6.6 X 109 2.7 X 1014 2.0 X 1010 1.9 X 109 <2.5 X 106
2016 1.1 X 1014 6.8 X 109 2.1 X 1014 5.1 X 1010 4.7 X 109 <3.7 X 106
2015 9.9 X 1013 4.9 X 109 2.7 X 1014 1.7 X 1010 2.8 X 109 5.4 X 106
2014 1.0 X 1014 9.0 X 109 2.4 X 1014 2.3 X 1010 1.5 X 109 3.2 X 106
2013 1.8 X 1014 6.7 X 109 1.9 X 1014 2.6 X 1010 1.7 X 109 1.3 X 106
2012 1.1 X 1014 1.1 X 1010 1.8 X 1014 1.9 X 1010 1.1 X 109 7.7 X 106
2011 1.2 X 1014 5.1 X 109 2.0 X 1014 1.4 X 1010 2.2 X 109 4.8 X 106

### Point Lepreau

Point Lepreau has DRLs for each individual noble gas and particulate category, and therefore monitors and reports on a wide range of specific radionuclides. For consistency in reporting within this appendix, these releases have been combined as total noble gases and total particulates in tables I.6 and I.7.

#### Releases to atmosphere

Table I.6: Trend for Point Lepreau annual radionuclide releases to atmosphere
Year Tritium  (HT) (Bq) Carbon-14 (Bq) Noble Gas (Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/ gamma) (Bq)
2017 DRL 2.8 X 1017 6.8 X 1015 a 6.0 X 1013 a
2017 1.5 X 1014 3.1 X 1011 4.6 X 1013 <5.2 X 105 <2.2 X 106
2016 1.5 X 1014 1.1 X 1011 9.5 X 1013 5.2 X 105 <2.2 X 106
2015 1.4 X 1013 7.1 X 1010 5.9 X 1012 <5.0 X 105 <8.1 X 105
2014 6.6 X 1013 8.4 X 1010 3.8 X 1012 --- ---
2013 9.1 X 1013 8.0 X 1010 4.6 X 1012 --- ---
2012 1.4 X 1014 3.7 X 1010 8.0 X 1011 --- ---
2011 4.3 X 1011 3.3 X 1015 --- --- ---

a: Point Lepreau specific DRLs for individual noble gas and particulate categories.

#### Releases to surface waters

Table I.7: Trend for Point Lepreau annual radionuclide releases to surface waters
Year Tritium  (HT) (Bq) Gross beta (Bq) Carbon-14 (Bq) Gross alpha (Bq)
2017 DRL 4.6 x 1019 a 3.3 x 1014 a
2017 1.2 X 1014 7.8 X 107 1.8 X 109 7.9 X 106
2016 1.8 X 1014 7.8 X 107 2.9 X 109 7.9 X 106
2015 1.4 X 1014 5.5 X 107 1.0 X 1010 6.7 X 106
2014 3.2 X 1014 1.5 X 108 6.6 X 109 8.6 X 106
2013 2.9 X 1014 1.5 X 108 4.3 X 109 8.6 X 106
2012 7.8 X 1014 7.2 X 107 3.8 X 1010 6.5 X 106
2011 3.4 X 1013 8.2 X 107 1.4 X 107 5.8 X 106

a: Point Lepreau has specific DRLs for individual noble gas and particulate gross beta and gross alpha categories.

### Bruce A and B

Bruce Power reports releases separately for Bruce A and Bruce B.

#### Releases to atmosphere

Table I.8: Trend for Bruce A annual radionuclide releases to atmosphere
Year Tritium  (HTO)(Bq) Carbon-14 (Bq) Noble Gas (Bq-MeV) Iodine-131 (Bq) Particulate (beta/ gamma)(Bq) Gross alpha (Bq)
2017 DRL 1.98 X 1017 6.34 X 1014 1.12 X 1017 1.14 X 1012 1.73 X 1012 2.96 X 1011
2017 7.32 X 1014 1.89 X 1012 9.40 X 1013 2.06 X 107 4.39 X 105 4.08 X 103
2016 5.66 X 1014 1.69 X 1012 5.63 X 1013 4.40 X 106 3.14 X 105 2.46 X 103
2015 7.05 X 1014 3.15 X 1012 5.62 X 1013 5.15 X 107 1.06 X 107 1.23 X 106
2014 7.51 X 1014 1.64 X 1012 5.30 X 1013 3.94 X 108 3.13 X 106 8.02 X 105
2013 5.04 X 1014 2.53 X 1012 6.66 X 1013 <4.94 X 107 <4.84 X 106 <6.67 X 105
2012 4.50 X 1014 2.30 X 1012 6.82 X 1013 2.18 X 106 <7.45 X 106 <6.40 X 105
2011 6.00 X 1014 1.36 X 1012 6.68 X 1013 3.58 X 107 <7.06 X 106 <5.99 X 105
Table I.9: Trend for Bruce B annual radionuclide releases to atmosphere (weekly releases)
Year Tritium  (HT) (Bq) Carbon -14 (Bq) Noble Gas (Bq-MeV Iodine-131 (Bq) Particulate (gross beta/gamma) (Bq) Gross alpha (Bq)
2017 DRL 3.16 X 1017 7.56 X 1014 2.17 X 1017 1.35 X 1012 3.61 X 1012 5.77 X 1011
2017 7.14 X 1014 1.23 X 1012 4.82 X 1013 1.41X 106 2.34 X 106 3.70 X 103
2016 5.70 X 1014 1.13 X 1012 5.25 X 1013 <LDa 1.13 X 1006 1.85 X 103
2015 3.74 X 1014 1.16 X 1012 5.25 X 1013 4.01 X 107 1.63 X 107 2.34 X 106
2014 4.13 X 1014 1.26 X 1012 3.71 X 1013 4.02 X 107 1.53 X 107 2.26 X 106
2013 2.63 X 1014 1.10 X 1012 3.64 X 1012 <4.04 X 107 <1.86 X 107 <2.51 X 106
2012 3.26 X 1014 1.16 X 1012 3.64 X 1012 4.13 X 107 1.80 X 107 <4.38 X 105
2011 7.17 X 1014 1.44 X 1012 3.64 X 1012 4.19 X 107 5.07 X 107 1.78 X 107

a less than analytical detection limit

#### Releases to surface waters

Table I.10: Trend for Bruce A annual radionuclide releases to surface waters
Year Tritium  (HT) (Bq) Gross beta/gamma (Bq) Carbon-14 (Bq) Gross alpha (Bq)
2017 DRL 2.30 X 1018 4.58 X 1013 1.03 X 1015 1.12 X 1014
2017 2.26 X 1014 1.08 X 109 9.13 X 108 <LDa
2016 2.36 X 1014 9.96 X 108 1.66 X 109 6.96 X 104
2015 2.20 X 1014 9.17 X 108 2.45 X 109 1.31 X 106
2014 1.94 X 1014 1.02 X 109 1.13 X 109 1.77 X 106
2013 1.96 X 1014 2.12 X 106 9.95 X 108 9.08 X 108
2012 1.40 X 1014 5.79 X 108 5.37 X 108 1.60 X 106
2011 2.95 X 1014 6.29 X 108 1.70 X 109 1.09 X 106

a less than analytical detection limit

Table I.11: Trend for Bruce B annual radionuclide releases to surface waters
Year Tritium  (HT) (Bq) Gross beta/gamma (Bq) Carbon-14 (Bq) Gross alpha (Bq)
2017 DRL 1.84 X 1018 5.17 X 1013 1.16 X 1015 1.21 X 1014
2017 7.15 X 1014 2.04 X 109 2.39 X 108 <LDa
2016 5.07 X 1014 1.42 X 109 1.76 X 109 <LDa
2015 6.72 X 1014 1.53 X 109 9.07 X 109 1.40 X 106
2014 6.42 X 1014 1.99 X 109 8.06 X 109 1.49 X 106
2013 4.19 X 1014 3.95 X 109 4.90 X 108 8.91 X 108
2012 1.14 X 1015 3.35 X 109 4.63 X 108 1.11 X 106
2011 5.10 X 1014 2.38 X 109 2.82 X 109 1.48 X 106

a less than analytical detection limit

### WWMF

#### Releases to atmosphere

Table I.12: Trend for WWMF annual radionuclide releases to surface waters
Year Tritium  (HT) (Bq) Carbon-14 (Bq) Iodine-131 (Bq) Particulate (gross gamma) (Bq)
2017 DRL 2.96  X 1017 1.09 X 1015 1.90 X 1012 2.34 X 1012
2017 1.72 X 1013 4.09 X 109 1.38 X 105 4.52 X 103
2016 2.06 X 1013 3.94 X 109 1.71 X 105 5.42 X 103
2015 4.14 X 1012 1.41 X 109 1.21 X 105 4.89 X 105
2014 7.17 X 1012 2.96 X 108 1.22 X 105 5.12 X 104
2013 1.43 X 1013 1.96 X 109 6.38 X 104 3.78 X 105
2012 1.04 X 1013 1.88 X 109 6.06 X 104 1.26 X 105
2011 1.99 X 1013 3.45 X 109 8.95 X 104 1.34 X 105

#### Releases to surface waters

Table I.13: Trend for WWMF annual radionuclide releases to surface waters
Year Tritium  (HT) (Bq) Gross Beta (Bq)
2017 DRL 7.70 X 1015 4.46  X 1011
2017 2.59 X 1011 2.84 X 108
2016 6.12 X 1011 4.62 X 108
2015 4.21 X 1011 1.56 X 108
2014 2.44 X 1011 1.26 X 108
2013 1.42 X 1011 1.26 X 108
2012 1.00 X 1011 6.80 X 107
2011 1.20 X 1011 9.02 X 107

### Gentilly-2

The applicable DRLs at the end of calendar year 2017 were updated1 and in force by July 2017.

Note1: CSA Group standard N288 -14, Guidelines for calculating the radiological consequences to the public of a release of airborne radioactive material for nuclear reactor accidents applies to both atmospheric and surface water releases.

#### Releases to atmosphere

Table I.14: Trend for Gentilly-2 annual radionuclide releases to atmosphere
Year Tritium  (HT) (Bq) Carbon-14 (Bq) Noble Gas (Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/gamma) (Bq)
2017 DRL 1.7 x 1017 1.2 x 1015 NA2 NA2 8.0  x 1011
2017 7.31 X 1013 4.47 X 1011 <LDa <LDa 8.32 X 106
2016 7.31 X 1013 3.79 X 1011 <LDa <LDa 5.17 X 105
2015 1.12 X 1014 4.10 X 1011 <LDa <LDa 1.35 X 106
2014 1.19 X 1014 4.83 X 1011 3.15 X 109 <LDa 2.92 X 105
2013 1.14 X 1014 7.49 X 1011 6.96 X 108 <LDa 8.65 X 105
2012 2.13 X 1014 4.41 X 1011 3.87 X 1011 8.31 X 106 1.79 X 106
2011 1.90 X 1014 2.71 X 1011 1.16 X 1011 <LDa 9.13 X 105

2 Not applicable as facility is in safe shut-down.

a  less than analytical detection limit

#### Releases to surface waters

Table I.15: Trend for Gentilly-2 annual radionuclide releases to surface waters
Year Tritium  (HT) (Bq) Gross beta (Bq) Carbon-14 (Bq)
2017 DRL 1.1 x 1019 5.3 x 1013 7.3 x 1014
2017 2.17 X 1014 3.28 X 108 2.79 X 1011
2016 3.83 X 1013 1.33 X 108 5.64 X 1010
2015 1.51 X 1014 5.28 X 108 3.00 X 1011
2014 3.56 X 1014 2.86 X 108 5.28 X 1010
2013 2.14 X 1014 1.84 X 109 1.15 X 1010
2012 3.51 X 1014 1.09 X 109 2.88 X 1010
2011 2.44 X 1014 5.35 X 109 1.89 X 1010

## Appendix J: List of completed CNSC inspections in 2017

Darlington
Safety and control area Inspection title Inspection report sent date
Management system

Problem Identification and Resolution (Event Investigation)

Report Number: DRPD-2017-023

Dec. 22, 2017

Management Systems

Report Number: OPG-DWMF-2017-01

July 17, 2017

Human performance management

Authorized Nuclear Operator Training Program

Report Number: OPG-2017-004

May 24, 2017

OPG Contract Management Personnel Training

Report Number: OPG-2017-005

Jan. 18, 2018

Conduct of a Simulator-based Certification Examination

Report Number: DRPD-2017-015

Sept. 15, 2017

Chemical Laboratory Staff Training Program

Report Number: OPG-2017-008

Jan. 18, 2018

Operating performance

Refurbishment Work Planning and Scheduling

Report Number: DRPD-2017-002

Feb. 28, 2017

Quarterly Inspection, Third Quarter FY 2016/17

Report Number: DRPD-2017-003

Mar. 13, 2017

Defueling Inspection

Report Number: DRPD-2017-004

Mar. 24, 2017

Refurbishment INS-14-01

Report Number: DRPD-2017-005

May 26, 2017

Tritium Removal Facility Inspection

Report Number: DRPD-2017-006

Apr. 6, 2017

Quarterly Field Inspections – Q4

Report Number: DRPD-2017-011

June 28, 2017

Quarterly Field Inspections – Q1

Report Number: DRPD-2017-016

Sept. 15, 2017

Foreign Material Exclusion

Report Number: DRPD-2017-019

Nov. 24, 2017

Outage Inspection (Generic: GSS, HS, Start-up, Maintenance, HP-TII-3A)  D1711

Report Number: DRPD-2017-020

Nov. 2, 2017

Quarterly Refurbishment Field Inspections – Q1

Report Number: DRPD-2017-021

Dec. 15, 2017

Quarterly Field Inspections – Q2

Report Number: DRPD-2017-024

Dec. 22, 2017

Supply Management (Refurbishment INS-01-01)

Report Number: DRPD-2017-025

Jan. 22, 2018

Multiple SCAs (Operating Performance)

Report Number: OPG-DWMF-2017-02

Feb. 13, 2018

Physical design

Pressure Boundary Program and AIA Services Agreement Inspection

Report Number: DPRD-2017-008

June 5, 2017

Unit 2 Refurbishment Temporary Containment Boundary Pressure Test

Report Number: DRPD-2017-009

Aug. 3, 2017

Safety Improvement Opportunity Compliance Verification:  Containment Filtered Venting System

Report Number: DRPD-2017-012

July 21, 2017

System Design

Safety Improvement Opportunity Compliance Verification: Powerhouse Steam Venting System

Report Number: DRPD-2017-001

Feb. 9, 2017

Fitness for service

Software Maintenance

Report Number: DRPD-2017-018

Nov. 24, 2017

Radiation Protection Activities Associated With the Reactor Vault During Refurbishment (Refurb INS-07-03)

Report Number: DRPD-2017-027

Jan. 18, 2017

Worker Dose Control

Report Number: DRPD-2017-013

July 21, 2017

Conventional Health and Safety

Darlington Refurbishment Conventional Health and Safety, INS-08-01

Report Number: DRPD-2017-007

June 5, 2017

Emergency management and fire protection

Emergency Exercise (RD-353)

Report Number: DRPD-2017-022

Dec. 15, 2017

Fire Protection (Refurbishment INS-10-02)

Report Number: DRPD-2017-026

Jan. 22, 2017

Safety Improvement Opportunity Compliance Verification: Emergency Power Generator 3

Report Number: DRPD-2017-014

July 21, 2017

Security

Force on Force

Report Number: DRPD-2017-010

Site Security Inspections – SS1 (Rounds)

Report Number: DRPD-2017-017

Pickering
Safety and control area Inspection title Inspection report sent date
Management system

Organization Roles and Responsibilities

Report Number: PRPD-2017-003/ OPG-2017-003

Apr. 6, 2017

Self and Independent Assessments

Report Number: PRPD-2017-013

Aug. 31, 2017

Contractor Management Inspection

Report Number: PRPD-2017-010

Sept. 26, 2017

Human performance management

Conduct of Simulator Based Requalification Tests

Report Number: PRPD-2016-022

Feb. 13, 2017

OPG Contract Management Personnel Training  Report Number: OPG-2017-005

Jan. 18, 2018

Pickering Radiation Protection Technician Training Program

Report Number: PRPD-2017-005

March 7, 2017

Authorized Nuclear Operator Training Program

Report Number: PRPD-2017-004 /OPG-2017-004

May 24, 2017

Minimum Shift Complement

Report Number: PRPD-2017-011

July 28, 2017

Chemical Laboratory Staff Training Program

Report Number: OPG-2017-008

Jan. 18, 2018

Operating performance

Q3  Quarterly Report 17–18

Report Number: PRPD-2015-29

Feb. 29, 2016

Unit 6 P1561 Outage

Report Number: PRPD-2015-26

Mar. 14, 2016

Q1 Quarterly Report  16–17

Report Number: PRPD-2016-016

Aug. 31, 2016

Q3 Quarterly Report 16–17

Report Number: PRPD-2016-025

Mar. 13, 2017

P1671 Unit 7 Planned Maintenance Outage

Report Number: PRPD-2016-026

Apr. 12, 2017

Q4  Quarterly Report 17–18

Report Number: PRPD-2017-012

June 13, 2017

Pickering Waste Management Facility

Report Number: OPG-PWMF-2017-01

July 4, 2017

Q1 Quarterly Report 17–18

Report Number: PRPD-2017-018

Aug. 21, 2017

Planned Maintenance Outage

Report Number: PRPD-2017-014

Sept. 20, 2017

Q2  Quarterly Report 17–18

Report Number: PRPD-2017-020

Dec. 8, 2017

Pickering Waste Management Facility

Report Number: OPG-PWMF-2017-02

Feb. 14, 2018

Physical design

Units 1–4 Electrical Distribution System

Report Number: PRPD-2016-019

Feb. 2, 2017

Environmentally Qualified Equipment

Report Number: PRPD-2016-020

Feb. 21, 2017

Fitness for service

Chemistry Control

Report Number: PRPD-2017-002

May 15, 2017

Instrument Air

Report Number: PRPD-2017-001

May 29, 2017

Fuel Channel Pressure Tubes Analysis and Methodologies

Report Number: PRPD-2017-007

Sept. 13, 2017

Maintenance and Reliability – Reactive Desktop Review  Report Number: PRPD-2017-022

Jan. 25, 2018

Fixed Area Gamma Monitoring (FAGM) and Semi-Portable Alarming Gamma Monitoring (S-PAGM) systems

Report Number: PRPD-2016-023

Mar. 6, 2017

Worker Dose Control

Report Number: PRPD-2017-008

Apr. 4, 2017

Environmental protection

Report Number: PRPD-2017-009

Aug. 30, 2017

Emergency management and fire protection

Fire Protection Program

Report Number: PRPD-2017-006

May 15, 2017

Record of Fire Protection Equipment Deficiencies

Report Number: PRPD-2017-FIR-043

Dec. 21, 2017

Security

Pickering Waste Management Facility

Report Number: PWMF-NSD-2017-001

Nov. 29, 2017

Point Lepreau
Safety and control area Inspection title Inspection report sent date
Operating performance

Quarterly Field Inspection Report Q3 2016–17

Report Number: GPLRPD-2017-001

May 4, 2017

Quarterly Field Inspection Report Q4 2016–17

Report Number: GPLRPD-2017-005

June 8, 2017

Quarterly Field Inspection Report Q1 2017–18

Report Number: GPLRPD-2017-009 Q1 2017–18

Aug. 8, 2017

Quarterly Field Inspection Report Q2 2017–18

Report Number: GPLRPD-2017-014 Q2 2017–18

Nov. 28, 2017

Quarterly Field Inspection Report Q3 2017–18

Report Number: GPLRPD-2017-022

Jan. 25, 2018

Outage Inspection

Report Number: GPLRPD-2017-004

July 21, 2017

Human performance management

Training Programs (for NLOs)

Report Number: GPLRPD-2017-008

Aug. 3, 2017

Conduct of Simulator Certification and Examinations and Requalification Tests

Report Number: GPLRPD-2017-015

Dec. 22, 2017

Conduct of a Simulator Based Certification Examination

Report Number: GPLRPD-2017-002

May 16, 2017

Conduct of Written Certification Examinations and Requalification Tests

Report Number: GPLRPD-2017-020

Jan. 19, 2018

Fitness for service

Chemistry Control

Report Number: GPLRPD-2017-011

Dec. 12, 2017

Maintenance Planning and Scheduling

Report Number: GPLRPD-2017-018

Jan. 24, 2018

Report Number: GPLRPD-2017-006

July 4, 2017

Environmental Protection

Effluent Control and Monitoring – EF2 Site Specific

Report Number: GPLRPD-2017-016

Jan. 24, 2018

Packaging and Transport

Packaging and Transport Inspection at NPP's

Report Number: GPLRPD-2017-017

Dec. 12, 2017

Security

Security

Report Number: GPLRPD-2017-003

Cyber Security

Report Number: GPLRPD-2017-007

Monitor Security Exercise (SSE)

Report Number: GPLRPD-2017-010

Site Security Inspections – SS1 (Rounds)

Report Number: GPLRPD-2017-012

Site Security Inspections – SS2

Report Number: GPLRPD-2017-013

Bruce A and B
Safety and control area Inspection title Inspection report sent date
Management System

Contractor Management

Report Number: BRPD-AB-2017-006

May 3, 2017

OPEX

Report Number: BRPD-AB-2017-010

July 6, 2017

Human performance management

Fatigue Management (Desktop Review)

Report Number: BRPD-AB-2017-007

Mar. 8, 2017

Design, Development and Grading of a Bruce A Simulator-based Examination (Desktop Review)

Report Number: BRPD-A-2017-002

Apr. 4, 2017

Bruce Engineering Division Personnel Training Program

Report Number: BRPD-AB-2017-013

Nov. 17, 2017

Design and Development of the July 2017 Bruce A ANO Simulator-based Certification Examination (Desktop Review)

Report Number: BRPD-A-2017-007

Dec. 20, 2017

Reactor Unit Comprehensive Simulator-Based Requalification Test at Bruce B

Report Number: BRPD-B-2017-007

Jan. 25, 2017

Operating performance

Bruce A and B Generating Stations Quarterly Field Inspection – Quarter 4, Fiscal Year 2016–17

Report Number: BRPD-AB-2017-011

June 6, 2017

Unit 5 Planned Outage

Report Number: BRPD-B-2017-001

July 7, 2017

SDS2 System Inspection

Report Number: BRPD-A-2017-003

Aug. 15, 2017

Bruce A and B Generating Stations Quarterly Field Inspection – Quarter 1, Fiscal Year 2017–18

Report Number: BRPD-AB-2017-015

Sept. 13, 2017

Event Investigation Inspection

Report Number: BRPD-AB-2017-017

Nov. 9, 2017

Bruce A and B Generating Stations Quarterly Field Inspection – Quarter 2, Fiscal Year 2017–18

Report Number: BRPD-AB-2017-019

Nov. 20, 2017

Unit 2 Forced Outage

Report Number: BRPD-A-2017-006

Nov. 22, 2017

Unit 3 Planned Outage

Report Number: BRPD-A-2017-004

Dec. 19, 2017

Bruce A and B Generating Stations Quarterly Field Inspection – Quarter 3, Fiscal Year 2017–18

Report Number: BRPD-AB-2017-020

Jan. 17, 2018

Unit 6 Planned Outage

Report Number: BRPD-B-2017-006

Jan. 18, 2018

Physical design

Fire Protection Bruce A and B

Report Number: BRPD-AB-2017-004

May 2, 2017

Instrumentation Calibration

Report Number: BRPD-AB-2017-016

Nov. 7, 2017

Electrical Power Systems

Report Number: BRPD-B-2017-005

Dec. 13, 2017

Pressure Boundary Program

Report Number: BRPD-AB-2017-002

Apr. 3, 2017

Software Maintenance

Report Number: BRPD-AB-2017-018

Dec. 13, 2017

Fitness for service

Chemistry Control

Report Number: BRPD-AB-2017-005

Apr. 12, 2017

Emergency Water System and Interunit Feedwater Tie System

Report Number: BRPD-B-2017-002

Apr. 28, 2017

Emergency Boiler Cooling System

Report Number: BRPD-A-2017-001

May 2, 2017

Worker Dose Control at Bruce Power

Report Number: BRPD-AB-2017-001

Mar. 7, 2017

Occupational ALARA Planning and Controls

Report Number: BRPD-AB-2017-014

Nov. 10, 2017

Conventional health and safety

Electrical Shock Reactive Inspection – B-2017-28612767

Report Number: BRPD-B-2017-004

Aug. 15, 2017

Environmental protection

Conventional Hazardous Waste

Report Number: BRPD-AB-2017-003

Apr. 12, 2017

Environmental Monitoring

Report Number: BRPD-AB-2017-021

Feb. 2, 2018

Emergency management and fire protection

Fire Drill

Report Number: BRPD-AB-2017-009

June 14, 2017

Emergency Exercise Bruce B

Report Number: BRPD-B-2017-008

Jan. 26, 2018

Security

Security Inspection (BRPD-AB-2017-008)

June 6, 2017

Security Inspection (BRPD-AB-2017-012)

Oct.13, 2017

WWMF
Safety and control area Inspection title Inspection report sent date
Management System

Management Systems

Report Number: OPG-DWMF-2017-01

July 17, 2017

Management Systems

Report Number: OPG-RWOS1-2017-01

July 17, 2017

Operating performance

Baseline Inspection Western Waste Management Facility

Report Number: OPG-WWMF-2017-01

July 4, 2017

Baseline Inspection Western Waste Management Facility

Report Number: OPG-WWMF-2017-02

Aug. 8, 2017

OPG’s Western Waste Management Facility

Report Number: OPG-WWMF-2017-03

Feb. 5, 2018

Security

Security Inspection at WUFDSF

Report Number: WUFDSF-NSD-2017-001

Jan. 10, 2018

Gentilly-2
Safety and control area Inspection title Inspection report sent date
Management system

Conservation des enregistrements à Gentilly-2

Report Number: DPRGPL-2017-001

Sept. 17, 2017

Security

Security Inspection

Report Number: DPRGPL-2017-002

Aug. 14, 2017

## Appendix K: Responsibilities and details for nuclear emergency preparedness and response

### Nuclear emergency response in Canada

In Canada, nuclear emergency response is a shared responsibility among all levels of government and the private sector. In accordance with International Atomic Energy Agency (IAEA) guidance and requirements, Canadian nuclear emergency response responsibilities are subdivided into onsite and offsite nuclear emergency responses.

Onsite nuclear emergency response pertains to all actions and measures taken within the boundary of the licensee’s site, whereas offsite nuclear emergency response pertains to actions and measures taken outside and beyond the boundary of the licensee’s site. These two areas of response require specific roles and responsibilities from different stakeholders yet, closely related as they are, they also require coordination between all levels of government and the licensee. For example:

• effluent and emissions control (releases)
• Provincial governments are responsible for offsite nuclear emergency response.
• If requested by the provincial government, the federal government may provide support to the province.

All levels of government and the CNSC have nuclear emergency response plans in place, including operational facilities equipped and staffed for coordinating and directing their responses to a nuclear emergency. In addition, all CNSC licensees have emergency response plans and/or measures in place to effectively respond in the event of an emergency. The CNSC maintains regulatory oversight of the nuclear emergency response carried out by the licensee.

In Canada, the CNSC licensees are the onsite authorities responsible for the management and implementation of onsite emergency response, in accordance with their CNSC-approved emergency response plans and procedures. This means that the licensees are directly responsible for:

• identifying and assessing the safety significance of the emergency
• controlling and mitigating the emergency
• notifying and coordinating with the offsite authorities and the CNSC
• notifying the CNSC in accordance with the applicable regulations and licence conditions
• providing recommendations regarding offsite protective actions
• informing the general public about onsite actions and conditions (e.g., reactor status)

The licensees’ communications and alert strategies include sirens (in the immediate vicinity of NPPs), automated phone-dialing systems, vehicle-mounted mobile public address systems, media messages (radio/television), Web site information, email alerts, and in some areas, door-to-door notification.

### Provincial, territorial or municipal governments

For emergencies that have an offsite impact, the provincial, territorial or municipal government is the appropriate responsible authority for offsite actions.

Provincial and territorial governments have primary responsibility for protecting the health and safety of the general public, property and the environment within their borders. They are also the primary authorities for informing the general public about protective actions and offsite conditions.

The provinces determine the need for protective actions and direct their implementation, which can include:

• sheltering
• evacuation
• ingesting potassium-iodine pills
• ingestion control measures

The provinces also ensure, in coordination with the municipalities, that arrangements are in place for:

• making KI pills available
• establishing reception and evacuation centres to accommodate evacuees
• establishing emergency worker centres to ensure radiation protection for emergency workers

### Federal government

Under the Emergency Management Act, the Minister of Public Safety is responsible for coordinating the Government of Canada’s response to an emergency, which is documented in an “all-hazards” response plan (the Federal Emergency Response Plan (FERP)). The Federal Nuclear Emergency Plan (FNEP) is an annex to the FERP which provides the supplemental and specific multi-departmental and inter-jurisdictional arrangements necessary to address the health risks associated with a radiological or nuclear emergency.

During an integrated response to a nuclear emergency under the FERP/FNEP, all levels of government and various agencies and organizations have the responsibility to develop and implement emergency response plans to deal with the consequences and impacts outside the boundaries of the nuclear facility licensed by the CNSC. The licensee is responsible for the response inside the boundaries of its facility.

An integrated Government of Canada response is required when:

• a province/territory requests federal support to deal with an emergency
• an emergency affects multiple jurisdictions and/or government institutions and requires a coordinated response
• an emergency directly involves federal assets, services, employees, statutory authority or responsibilities, or affects confidence in government
• an emergency affects other aspects of the national interest

Global Affairs Canada is also responsible for liaising with the international community and their diplomatic missions in Canada, assisting Canadians abroad and coordinating the national response to nuclear emergencies that occur in foreign countries, but have an impact on Canada.

### CNSC

For nuclear emergencies involving licensed facilities and substances, the CNSC:

• performs regulatory oversight of the licensee’s activities (monitoring, evaluation of protective action recommendations, advice, assistance, and when appropriate, direction in the form of directives and orders)
• performs an independent assessment of the onsite conditions and potential offsite consequences to provide or confirm the licensee’s recommendations concerning any protective measures that may be needed
• participates as a federal agency in the whole-of-government response to a nuclear emergency, in accordance with the requirements of both the FERP and the FNEP

For nuclear emergencies not involving licensed substances, the CNSC plays a supporting role in the response under the FERP/FNEP. This includes (but is not limited to) providing technical assistance and support to the lead organization, in accordance with CNSC’s authorities and responsibilities.

### Compliance verification by CNSC inspectors

CNSC inspectors, including emergency preparedness inspectors, perform inspections routinely to confirm that the licensees’ emergency preparedness programs are always fully implemented and functional.

The NPP and WMF licensees maintain emergency plans that include measures to address onsite emergencies as well as measures that support planning, preparedness and response for offsite emergencies. Each licensee’s emergency plan is specific to its particular site and organization. However, all emergency plans typically cover:

• documentation of the emergency plan
• basis for emergency planning
• personnel selection and qualification
• emergency preparedness and response organizations
• staffing levels
• emergency training, drills and exercises
• emergency facilities and equipment
• emergency procedures
• assessment of emergency response capability
• assessment of accidents
• activation and termination of emergency responses
• protection of facility personnel and equipment
• interface arrangements with offsite organizations
• arrangements with other agencies or parties for assistance
• recovery program
• public information program
• public education program

## Endnotes

Footnote 1

Quiet mode is a mode of operation that does not allow for any evolution that may disturb reactor operation.

Footnote 2

At Point Lepreau, the pressure tubes began their service life in 2012 following refurbishment and are not expected to approach the Heq limit of 120 ppm for many years.

Footnote 3

The annual collective dose is the sum of the effective doses received by all the workers at that facility in a year. It is measured in person-sieverts (person-Sv).

Footnote 4

The average effective dose or average effective dose – non-zero results only is obtained by dividing the total collective dose by the total number of individuals receiving a dose above the minimum reportable level of 0.01 mSv.