# Regulatory Oversight Report for Nuclear Power Generating Sites: 2019

## Executive summary

The regulatory oversight report describes the regulatory oversight and safety performance of nuclear power generating sites, consisting of nuclear power plants (NPPs) and adjacent waste management facilities (WMFs) in Canada in 2019. For certain topics, updates on developments in 2020 are also described. This is the third CNSC regulatory oversight report to cover both NPPs and WMFs.

Referenced documents in this regulatory oversight report are available to the public upon request.

The following list identifies the facilities for each site covered by this report. Each line in the list identifies facilities that are located at the same site and governed by a single CNSC licence; for this reason, they are assessed together in this report:

• Darlington Nuclear Generating Station (DNGS), which includes the Tritium Removal Facility and Retube Waste Processing Building
• Darlington Waste Management Facility (DWMF), which includes the Retube Waste Storage Building (RWOS-1)
• Pickering Nuclear Generating Station (PNGS)
• Pickering Waste Management Facility (PWMF)
• Bruce A Nuclear Generating Station and Bruce B Nuclear Generating Station
• Western Waste Management Facility (WWMF) and Radioactive Waste Operations Site-1
• Point Lepreau Nuclear Generating Station (PLNGS) and Solid Radioactive Waste Management Facility (SRWMF)
• Gentilly-2 Facilities

CNSC staff concluded that the NPPs and WMFs operated safely in 2019. This conclusion was based on detailed staff assessments of findings from compliance verification activities for each facility in the context of the 14 CNSC safety and control areas. The conclusion was supported by safety performance measures and other observations.

Important performance measures and observations include the following:

• The NPP and WMF licensees followed approved procedures and took appropriate corrective action for all events reported to the CNSC.
• NPPs and WMFs operated within the bounds of their operating policies and principles.
• No serious process failures occurred 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 also below the regulatory limits.
• The frequency and severity of non-radiological injuries to workers were low.
• No radiological releases to 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.

CNSC staff’s assessments for 2019 concluded that the licensees complied with the applicable requirements and also met CNSC staff’s expectations for all SCAs at all the NPPs and WMFs.

## 1 Introduction

### 1.1 About the regulatory oversight report

The Regulatory Oversight Report for Canadian Nuclear Power Generating Sites: 2019 provides Canadian Nuclear Safety Commission (CNSC) staff’s assessment of the overall performance of Canadian nuclear power plants (NPPs) and their adjacent waste management facilities (WMFs) for 2019.

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 provides background information that serves as context for the assessments. Although the assessments for each site are provided in section 3, section 2 contains some assessments of groups of licensees, where appropriate. For example, section 2 compares safety performance data for multiple licensees.

Section 3 contains highlights from the individual assessments for each facility. The CNSC’s approach to the safety assessments of the NPPs and WMFs is described in section 1.4.5.

Sections 2 and 3 are organized according to the CNSC safety and control area (SCA) framework, as it existed at the end of 2019.

Section 4 contains CNSC staff’s conclusions based on the assessments presented in this report.

Some of the terms used in this document are defined in CNSC REGDOC-3.6, Glossary of CNSC Terminology.

This report includes information requested by the Commission from previous regulatory oversight reports and licensing hearings. These requests are tracked through the CNSC’s Regulatory Information Bank (RIB) system. Table 1 provides the RIB tracking number, a description of the request, and where the request is addressed by CNSC staff in this report, as applicable.

Table 1: Details on information requests from the Commission
RIB # Request Report section
17560 Include data for total recordable injury frequency for all workers, including contractors, if it is available 2.8
17557

Follow-up to the licence renewal for Pickering Nuclear Generating Station (PNGS)

1. provide update on the status of the integrated implementation plan (IIP)
2. describe methodology and progress for whole-site probabilistic safety assessment (PSA)
3. provide update on the joint fuel machine reliability project

3.3.0

2.4, 3.3.4

2.6

17522

Provide update on emergency management and preparedness at the PNGS

1. 2017 Ontario Provincial Nuclear Emergency Response Plan (PNERP)
2. implementation plan for the PNGS for 2017 PNERP
3. results from the technical study for 2017 PNERP
4. Ontario’s unified transport management plan
5. revision of public information and disclosure program for the PNGS in regard to emergency preparedness and provision of information to populations beyond the detailed planning zone
2.10
16516

Provide update on the PNGS fish diversion system

1. improvements and resulting fish impingement rate
2. results of Ontario Power Generation’s (OPG’s) thermal plume monitoring
3. a) OPG’s compliance with its Fisheries Act authorization and b) involvement of Indigenous groups in activities related to the authorization

3.3.0

3.3.9

a)    3.3.0

b)    2.15

14761 Describe enhancements at Bruce A to bring internal fire risk below the safety goal target 3.5.4
14760 Monitor Bruce Power’s work to perform site-wide PSA for the next licence renewal 2.4, 3.5.4
14759 Report on Bruce Power’s progress on providing aggregate risk values for the next licence renewal. (The Commission made this request following the 2018 Bruce A and B licence renewal hearing.) 2.4, 3.5.4
14757

Describe developments related to pressure tube fracture toughness for Bruce A and B, including:

1. fracture toughness modelling
2. estimates of the maximum amount of equivalent hydrogen
2.6, 3.5.6
14755 Provide update on the implementation of automated data transfer from Bruce A and B to the CNSC Emergency Operations Centre 3.5.10
14753 Provide update on status of major component replacement for Bruce A and B 3.5.0
8504 Provide update on the CNSC’s regulatory position on risk aggregation 2.4

### 1.2 Scope of the regulatory oversight report

The scope of this 2019 regulatory oversight report is similar to that of the Regulatory Oversight Report for Canadian Nuclear Power Generating Sites: 2018 [2]. The 2019 report covers the NPPs in Canada, including Gentilly-2 Facilities. General statements in the report that refer to “NPPs” are intended to apply to the Gentilly-2 Facilities, while the phrase “operating NPPs” is used for statements that do not apply to the Gentilly-2 Facilities. The report also covers the WMFs located at the same sites, whether they are regulated under the same licence as the NPP or licensed separately.

Generally speaking, the information provided in this regulatory oversight report is pertinent to 2019, and the status that is described is valid as of December 2019. The word “UPDATE” is used to identify topics where more recent information (up to June 1, 2020) is included (for example, progress on corrective actions, descriptions of significant events and updates that the Commission specifically requested).

The detailed scope of the safety assessments in this regulatory oversight report is covered by the set of specific areas that constitute each SCA. They are described in more detail in General Description of Regulatory Framework for Nuclear Power Generating Sites [1]. As noted in that document, some specific areas do not apply to the Gentilly-2 Facilities and the WMFs. Therefore, those areas were not considered in the safety assessments for those facilities.

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

Figure 1 shows the geographic location in Canada of the NPPs and WMFs covered by this report. All sites are located on traditional territories of Indigenous peoples in Canada.

#### 1.3.1 Nuclear power generating sites and associated waste management facilities 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 licensed separately. See sections 3.1 and 3.2 for details. The site also includes the Darlington New Nuclear Project (DNNP).

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 the PWMF are licensed separately. See sections 3.3 and 3.4 for details.

The Bruce site is located in Tiverton, Ontario, and consists of the Bruce A and B Nuclear Generating Stations; OPG’s Western Waste Management Facility (WWMF) and Radioactive Waste Operations Site-1 (RWOS-1); and Canadian Nuclear Laboratory’s (CNL’s) Douglas Point Waste Facility. Bruce A and B are licensed together. The WWMF, RWOS-1 and Douglas Point Waste Facility are each licensed separately. See sections 3.5 and 3.6 for details. Note that the Douglas Point Waste Facility is not covered in this report, but in the Regulatory Oversight Report for Canadian Nuclear Laboratories Sites: 2019.

The Point Lepreau site is located on the Lepreau Peninsula in New Brunswick and consists of the Point Lepreau Nuclear Generating Station (PLNGS) and the Solid Radioactive Waste Management Facility (SRWMF). The operations of PLNGS and the SRWMF are authorized under a single licence. See section 3.7 for details.

The Gentilly nuclear site is located in Bécancour, Quebec, and consists of CNL’s Gentilly-1 Waste Facility and Hydro-Québec’s Gentilly-2 Facilities. The Gentilly‑1 and Gentilly-2 facilities are licensed separately. See section 3.8 for details. Note that the Gentilly-1 Waste Facility is not covered in this report, but in the Progress Update for CNL’s Prototype Waste Facilities, Whiteshell Laboratories and the Port Hope Area Initiative.

#### 1.3.2 Nuclear power plants

Figure 2 provides data for each NPP, including the generating capacity of the reactor units, their initial start-up dates, and reactor status in 2019. See section 3 for additional information on the NPPs and licences.

##### Operating NPPs

Eighteen reactors continued to operate in Canada throughout 2019. They are located at 4 NPP sites, each with a power reactor operating licence (PROL) issued by the CNSC. They are located in 2 provinces (Ontario and New Brunswick) and are operated by 3 distinct licensees (OPG, Bruce Power and NB Power). These NPPs range in size from 1 to 8 power reactors, all of which are of the CANDU (CANada Deuterium Uranium) design.

##### Non-operating reactors and NPP

As noted in figure 2, the DNGS includes Unit 2, which was being refurbished in 2019 and did not operate. The PNGS also includes Units 2 and 3, which remained defueled and in safe storage. They are also governed by the same PROL as the operating units.

In addition, the NPP at the Gentilly-2 Facilities is shut down and is proceeding to decommissioning. It is also governed by a power reactor decommissioning licence.

##### New NPPs

In 2012, the Commission issued a 10-year nuclear power reactor site preparation licence (PRSL) to OPG for the Darlington New Nuclear Project at the Darlington site. The PRSL requires OPG to continue follow-up work on the environmental assessment (EA) conducted in conjunction with the licence application.

UPDATE: OPG submitted its application to renew the PRSL in June 2020.

#### 1.3.3 Waste management facilities

The WMFs that are assessed separately in this regulatory oversight report are the ones that are licensed independently from the adjacent NPP. They include the DWMF, PWMF and WWMF, each of which is owned and operated by OPG under a waste facility operating licence (WFOL).

Table 2 provides data for each WMF, including the initial start-up date, the name of the licensee, the expiry date of the licence, and the type of waste managed at each facility (for example, low- and intermediate-level waste (L&ILW), intermediate-level waste (ILW) and high-level waste (HLW)). See section 3 for additional information on the facilities and licences.

As discussed in section 1.3.1, both the Point Lepreau and Gentilly-2 sites also have WMFs.

Table 2: Basic information on WMFs
Facility Licensee Operation start WFOL expiry Manages
DWMF OPG 2008 Apr 30, 2023

HLW from DNGS

ILW from DNGS refurbishment

PWMF OPG 1996 Aug 31, 2028

HLW from PNGS

ILW from PNGS Units 1–4 refurbishment

WWMF OPG 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 operations

RWOS-1 OPG Mid-1960 Oct 31, 2029 L&ILW from Douglas Point WMF and PNGS

### 1.4 Regulatory framework and oversight

The CNSC regulates the nuclear sector in Canada, including NPPs and WMFs, through licensing, reporting, compliance verification, and enforcement. The CNSC uses a risk-informed regulatory approach, applying resources and regulatory oversight commensurate with the risk associated with the regulated facility and activity. Additional information on the CNSC regulatory framework and oversight is provided in this section and in General Description of Regulatory Framework for Nuclear Power Generating Sites [1].

#### 1.4.1 CNSC requirements

All licensees are required to operate in accordance with the licensing basis. The licensing basis is defined in CNSC REGDOC-3.5.3, Regulatory Fundamentals, and 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 requirements in parts (ii) and (iii) of the licensing basis are unique to each licensed facility – they depend on the content of a given licence, licence application and the applicant’s supporting documentation. Regulations made under the Nuclear Safety and Control Act (NSCA), including the Class I Nuclear Facilities Regulations, provide requirements on the content of licence applications for NPPs and WMFs.

Licence applications for NPPs and WMFs cite CNSC regulatory documents, CSA Group standards, and other publications, as well as the applicant’s own documentation. When a licence is issued, CNSC staff develop a licence conditions handbook (LCH) to identify the specific requirements that apply to that licence. All NPPs and WMFs covered by this report have LCHs.

Appendix B lists all CNSC regulatory documents and CSA Group standards that are identified as containing compliance verification criteria in the LCHs for the NPPs and WMFs covered by this regulatory oversight report. The appendix illustrates the large number of CNSC regulatory documents and CSA Group standards that provide requirements relevant to all SCAs.

Appendix B also indicates the significant number of newer CNSC regulatory documents and CSA Group standards that the licensees are implementing. Details about the implementation of these publications are provided under the relevant SCAs throughout this regulatory oversight report.

In this report, CNSC regulatory documents typically start with “REGDOC-” followed by an identifying number. CSA Group standards are typically identified by “CSA N.xxx” where xxx is the number of the publication.

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 nevertheless are comprehensive, and improved requirements are implemented in a measured and systematic way.

#### 1.4.2 Licensing

The Commission has granted a licence to each of the operating NPPs and WMFs described in this report. The typical period for a WFOL and a PROL has been 10 years and 5 years, respectively, while Hydro-Québec has a 10-year licence to decommission its power reactor. In 2015, the Commission granted OPG a 10-year licence for the DNGS. In 2018, the Commission granted Bruce Power a 10-year licence for Bruce A and B and granted OPG a 10-year licence for the PNGS. For operating NPPs, this longer licence is issued in conjunction with the implementation of a periodic safety review (PSR) process in preparation for the next licence renewal.

The PSR is a comprehensive evaluation of the design, condition and operation of an NPP. As outlined in CNSC REGDOC-2.3.3, Periodic Safety Reviews, a PSR involves an assessment of the current state of the NPP and plant performance to determine the extent to which the NPP conforms to modern codes, standards and practices, and to identify any factors that would limit safe, long-term operation. The PSR provides the licensee a framework to systematically identify practicable safety enhancements, which are documented in an integrated implementation plan (IIP). For operating NPPs, licence conditions have been used to require the licensee to implement the IIP during the licence period and to conduct a PSR in support of the next licence renewal. A PSR is not a requirement for the Gentilly-2 Facilities or the WMFs because the associated hazards are relatively smaller and the requirements change relatively slowly. For these reasons, the regular licensing process and implementation of CNSC regulatory documents and CSA Group standards are sufficient to assure safe, long-term operation.

Section 3 describes the status of the PSR for each operating NPP.

##### Fisheries Act authorizations

In addition to CNSC licences, this regulatory oversight report describes developments related to Fisheries Act authorizations. 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 in accordance with regulations made under the NSCA. LCHs clarify CNSC expectations for these requirements, if needed.

In addition to, and in conjunction with, the reporting requirements in the regulations, a licence condition requires NPP licensees to report to the CNSC in accordance with CNSC 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; for example, quarterly reports on the safety performance indicators that are discussed in this report. REGDOC-3.1.1 also provides detailed requirements related to the submission of other important reports (such as updates to the final safety analysis report, proposed decommissioning plan and annual environmental protection report). REGDOC‑3.1.1 also requires licensees to report any unplanned situations and events to the CNSC.

For the Gentilly-2 Facilities, the requirements in REGDOC-3.1.1 have been adjusted in accordance with its current state and the associated risks [5].

During 2019, NPP licensees reported to CNSC staff on 217 events and submitted 90 scheduled reports. In accordance with the General Nuclear Safety and Control Regulations, WMF licensees also submitted 8 reports to CNSC staff for reportable events that occurred at the DWMF, PWMF and WWMF.

The CNSC published REGDOC-3.1.2, Reporting Requirements, Volume I: Non-Power Reactor Class I Facilities and Uranium Mines and Mills, in January 2018. Beginning in 2019, the WMFs reported to the CNSC in accordance with REGDOC-3.1.2.

#### 1.4.4 Compliance verification program

The safety assessments presented in this report were based on the results of activities planned through the CNSC compliance verification program (CVP). In 2019, these activities included Type II inspections that evaluate the outputs and outcomes of licensee programs; field inspections that collect data on the outputs and outcomes of licensee programs; desktop inspections and reviews; and surveillance and monitoring.

Additional reactive CVP activities for NPPs and WMFs are added as needed. These focus on site-specific matters and known or potential licensee challenges. CNSC staff then validate the annual plans by using a risk-informed approach that considers the status, performance history, and conditions and challenges of each facility, to ensure appropriate regulatory oversight and safety performance evaluation. More CVP activities for NPPs and WMFs may also be added during the year in response to new or emerging licensee challenges. The goal is to ensure that the CVPs for NPPs and WMFs are always timely, risk-informed, performance-based and responsive to developments.

The CVPs for NPPs also include desktop reviews of safety performance indicators submitted quarterly to the CNSC in accordance with REGDOC-3.1.1. This regulatory oversight report reproduces data for some of these indicators. No regulatory limits or thresholds are associated with this data, but CNSC staff monitor the data, watching for trends over time and deviations from the data typically provided by other licensees with similar operations or facilities. CNSC staff follow any unfavourable trend or comparison by increased regulatory scrutiny, which can range from increased surveillance and monitoring, to increased focus during field inspections, adjustment of the timing or scope of a baseline inspection, a focused desktop review or a reactive inspection, depending on the safety significance of the trend or deviation.

#### 1.4.5 Safety assessment ratings

This report presents safety performance ratings for each SCA at each NPP and WMF based on findings generated during CVP activities. All findings are categorized into appropriate SCAs and specific areas and assessed against a set of high-level performance objectives for the SCAs, as well as the detailed regulatory requirements and CNSC staff’s performance expectations. Since the CVP consists of a rolling (typically 5-year) cycle of regulatory activities, not all specific areas are directly evaluated every year.

The SCAs and specific areas are described in more detail in General Description of Regulatory Framework for Nuclear Power Generating Sites [1]. See appendix A for a description of the rating methodology used for this regulatory oversight report.

In generating the ratings, CNSC staff considered 1,475 findings for NPPs and 145 for WMFs in 2019. All but 2 of these findings were assessed as being either compliant or of negligible or low safety significance. In other words, they had a positive, insignificant or small negative impact on safety within the specific area. Sections 3.2.10 and 3.6.14 discuss the 2 “medium” findings that had significant negative effects in the context of the assessment of their respective specific areas.

For the Bruce site,Footnote 1 Bruce A and B are rated separately from the 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 under separate licences and have facility-specific licensing bases. The WMFs at the Point Lepreau and Gentilly-2 sites are governed by the NPP licences and are subject to the same regulatory requirements, so they are assessed together with their respective NPPs (as was done in previous regulatory oversight reports).

#### 1.4.6 Update on CNSC COVID-19 response and related NPP oversight

On March 15, 2020, the CNSC activated its Business Continuity Plan, in response to the COVID-19 pandemic. Effective March 16, all CNSC staff in Ottawa and at regional and site offices were directed to work from home. CNSC management immediately suspended all regular NPP and WMF compliance verification activities and identified activities that were considered critical, in order to support continued safe power reactor operation and regulatory decision making. For example, oversight activities and reviews related to the release of regulatory hold points for Darlington Unit 2 were carried out remotely with no interruption, in adherence to measures put in place by CNSC management, OPG and federal and provincial authorities.

In April 2020, CNSC management approved a new procedure for planning and conducting compliance verification activities at NPPs, to ensure continued regulatory oversight during the COVID-19 pandemic. This procedure was and is to be utilized during and following the pandemic for fiscal year 2020/21 until normal compliance processes resume. The procedure provides a framework and direction for the conduct of oversight activities both remote and onsite, as well as direction on revising the annual compliance plan for this fiscal year (2020–21).

The framework also allows for enhancing the number and capabilities of site inspectors to work remotely. CNSC staff have worked with licensees to obtain comprehensive and remote access to site information systems, actual plant data and participation in all key plant management meetings.

In addition to this new procedure, CNSC staff developed a pandemic-related pre-job brief as additional instructions for site office supervisors to deliver to site inspectors before they perform onsite oversight activities. Provision of personal protective equipment (PPE) to site inspectors prior to any onsite activities forms part of this pre-job brief.

In May 2020, onsite oversight activities resumed at NPPs in a limited capacity. These activities focused on general health and safety issues (such as control of combustible material, housekeeping and contamination posting), as well as licensee adherence to their pandemic response plans and COVID-19 health protocols. As part of its precautions, the CNSC is managing and limiting site inspectors’ access to the site offices and providing additional PPE and sanitization products.

CNSC staff continue to conduct oversight activities during the COVID-19 pandemic to ensure the protection of the environment, and the health and safety of people. Oversight activities completed in 2020 during the pandemic will be further described in the 2020 regulatory oversight report.

## 2 General and supporting information

This section provides information, organized by safety and control area (SCA), which serves as background for the assessments in section 3. In some cases, it describes and assesses data and issues that apply to more than one facility. The subsections are organized according to the specific areas of each SCA, although some specific areas are omitted if there is no new information. General information about the SCAs and the applicability of the specific areas is provided in General Description of Regulatory Framework for Nuclear Power Generating Sites [1].

### 2.1 Management system

#### Safety culture

The CNSC published REGDOC-2.1.2, Safety Culture, in April 2018. This document sets out requirements and guidance for the licensee to foster a healthy safety culture and conduct periodic safety culture assessments. NPP licensees provided implementation plans for REGDOC-2.1.2 in 2019. The CNSC confirmed that Hydro-Québec complied with this regulatory document. As part of their implementation work, OPG, Bruce Power and NB Power made commitments to conduct their next self-assessments in accordance with REGDOC‑2.1.2.

Additionally, most NPP licensees have implemented safety culture monitoring panels following the guidance provided by the Nuclear Energy Institute.

#### Management of contractors

In 2019, NPP licensees reported events related to the topic of counterfeit, fraudulent and suspect items (CFSIs, e.g., as discussed in section 3.3.1 for the PNGS). For the most part, the licensee processes for detection of suspect or counterfeit items have been effective. The particular concern about the reported events was the misrepresentation of product or service quality early in the supply chain (that is, fraudulence), which is difficult to detect. This has been more of a concern in the global context than in Canada. Nonetheless, noting that fraudulence can be detected with improved oversight of suppliers, CNSC staff continued to focus on the licensees’ supply chains, with particular attention to fraudulence. CNSC staff were planning improved oversight activities in early 2021.

All licensees have business continuity plans that would be activated in the case of a labour disruption, major external event, or pandemic.

### 2.2 Human performance management

#### Human performance program

CNSC staff’s inspection activities in 2019 indicated that the NPP and WMF licensees were developing and expanding their human performance programs to consider a systemic approach that includes the interactions of humans, technology and the organization to support worker performance. The licensees were increasing their focus on accountability of workers and on learning from events in order to improve human performance.

#### Personnel certification

Each NPP licence has a condition that requires the licensee to have certified personnel in specific positions. All NPPs have certification requirements for responsible health physicists, and the operating NPPs are also required to have certified shift supervisors, shift managers and reactor operators. Due to the design of Bruce A, Bruce B and the DNGS, the CNSC requires those licensees to also employ certified Unit 0 operators.

Table 3 shows the number of certified personnel who were available in the certified positions at each NPP, as of December 31, 2019. The table also shows the minimum required number of personnel for each position, which is the minimum number of certified personnel that must be present at all times multiplied by the total number of crews.

Table 3: Number of available certifications per NPP and certified positions for 2019
Station Reactor operator Unit 0 operators a Shift supervisor b Health physicist Total
DNGS
Actual 64 18 32 5 119
Minimum 30 10 10 1 51
PNGS Units 1 and 4
Actual 42 21 2 c 66
Minimum 20 10 1 31
PNGS Units 5–8
Actual 64 20 2 c 87
Minimum 30 10 1 41
Bruce A
Actual 49 23 23 4 d 99
Minimum 30 10 10 1 51
Bruce B
Actual 62 22 23 4 d 111
Minimum 30 10 10 1 51
Point Lepreau
Actual 9 7 2 18
Minimum 6 6 1 13
Gentilly-2 e
Actual 2 2
Minimum 1 1
1. There are no Unit 0 positions at PNGS Units 1 and 4 and Units 5–8, or Point Lepreau.
2. At multi-unit NPPs, the shift supervisor number is the total of certified shift managers plus certified control room shift supervisors.
3. There are 2 certified health physicists in all at Pickering, who cover both PNGS Units 1 and 4 and Units 5–8.
4. There are 4 certified health physicists in all at Bruce, who cover both Bruce A and Bruce B.
5. There are no reactor operators, Unit 0 operators or shift supervisors at Gentilly-2.

#### Initial certification examinations and requalification tests

As noted above, health physicists are the only certified personnel employed at the Gentilly-2 Facilities. Since CNSC staff administer the initial examinations and requalification tests of the health physicists for Hydro-Québec, this specific area does not apply to the Gentilly-2 Facilities. There are no certified personnel at the WMFs.

#### Work organization and job design

All NPP licensees have a documented minimum shift complement (MSC), which forms part of its licensing basis. The MSC is monitored each shift and is managed through face-to-face turnover, the use of electronic minimum complement monitoring systems, or the use of whiteboards that track personnel in and out of the facility.

In 2019, licensees reported 1 MSC violation at the DNGS, 2 violations at the PNGS, 1 violation at Bruce A and B and 3 violations at Point Lepreau. All violations were of a short duration and the licensees took appropriate actions; for example, calling in relief personnel, holding over personnel already present and operating in quiet mode.

#### Fitness for duty

CNSC oversight of fitness for duty includes assessments of licensee measures related to managing worker fatigue; the management of alcohol and drug use; and minimum requirements for medical, physical and psychological certificates for nuclear security officers.

##### Managing worker fatigue

All NPP licensees have procedures to manage worker fatigue. The procedures include limits on hours of work.

CNSC REGDOC-2.2.4, Fitness for Duty: Managing Worker Fatigue, specifies requirements and guidance for managing worker fatigue at all high-security si.tes, with the aim of minimizing the potential for errors that could affect nuclear safety and security. OPG, Bruce Power and Hydro-Québec implemented this regulatory document in 2019, while NB Power planned to implement the document by 2020 for normal operations and 2022 for outages. NB Power’s plan involved expanding its security and emergency response team personnel (to a 6-crew format working on a 42-day shift cycle, which would match its operations personnel).

Type I inspections to confirm compliance with REGDOC-2.2.4 were planned in 2020 for OPG and Bruce Power.

UPDATE: In May 2020, NB Power informed the CNSC of a revision to its implementation plan, resulting in a planned implementation for operations by April 2021. CNSC staff reviewed the revised implementation plan and found it acceptable.

##### Managing alcohol and drug use

REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use, sets out requirements and guidance for managing fitness for duty of workers occupying safety-sensitive and safety-critical positions in relation to alcohol and drug use at all high-security sites. All licensees of high-security sites provided implementation plans early in 2018, which CNSC staff accepted. In late 2018, OPG, Bruce Power and NB Power requested an amendment, in order to include oral fluid testing to supplement the urinalysis required by the regulatory document. OPG, Bruce Power and NB Power requested a change to their implementation dates, proposing to implement REGDOC‑2.2.4, Volume II within a period following the date of its amendment (or from the date it is determined that it will not be amended). Specifically, the licensees proposed to implement the requirements other than random testing within 6 months of that date and to implement random testing within 12 months of that date. CNSC staff reviewed and accepted the request and began work in 2019 to revise REGDOC-2.2.4, Volume II.

Hydro-Québec implemented the current version of REGDOC-2.2.4, Volume II in July 2019.

CNSC staff anticipated the amended regulatory document will be submitted to the Commission for approval in 2020.

##### Nuclear security officer medical, physical and psychological fitness

Licensees are required to ensure that all nuclear security officers have medical, physical and psychological certificates that meet the CNSC’s requirements. CNSC REGDOC-2.2.4, Fitness for Duty, Volume III: Nuclear Security Officer Medical, Physical and Psychological Fitness, sets out the expectations and minimum requirements for these certificates. All licensees have made a commitment to fully implement the document by December 31, 2020.

### 2.3 Operating performance

Eighteen reactors continued to operate in Canada throughout 2019, along with the WMFs at the same sites. Unit 2 at Darlington was shut down in 2019 while refurbishment continued.

The licensees’ quarterly reports for operating NPPs include data on the safety performance indicator for the number of unplanned transients, which tracks unplanned transients (unexpected reactor power reductions) for each reactor that is not in a guaranteed shutdown state. Unplanned transients indicate problems within a plant and place unnecessary strain on its systems.

Table 4 summarizes the number of unplanned transients for the operating NPPs (specifically setbacks, stepbacks and reactor trips,Footnote 2). The last row, “Industry total,” provides the data for the operating NPPs as a whole. In 2019, all unplanned transients were properly controlled and adequately initiated by the reactor control systems. CNSC staff also determined that no serious process failures occurred at any NPP in 2019.

Table 4: Number of unplanned transients in 2019
NPP Number of operating reactors Number of hours of operation Trips Stepbacks Setbacks Total unplanned transients Number of trips per 7,000 operating hours
DNGS 3 23,521 0 0 1 1 0.00
PNGS 1 and 4 2 17,378 0 N/A1 0 0 0.00
PNGS 5–8 4 29,780 0 0 5 5 0.00
Bruce A 4 30,002 2 2 2 6 0.47
Bruce B 4 29,393 0 1 1 2 0.00
Point Lepreau 1 8,110 0 0 1 1 0.00
Industry total 18 138,184 2 3 10 15 0.10

1. Stepbacks are not a design feature at PNGS Units 1 and 4.

Figure 3 shows the total number of unplanned transients from 2015 to 2019 for the operating NPPs.

Figure 4 shows the number of unplanned reactor trips for Canada’s operating NPPs per 7,000 hours of operation. The 2019 data for the individual NPPs are provided in table 4. The unplanned total scrams is a WANO indicator defined as the number of unplanned automatic scrams (reactor protection system logic actuations, which are comparable to unplanned reactor trips in the Canadian context) that occur per 7,000 hours of critical operation (which is approximately one year of operation) for an individual reactor. WANO establishes two targets for this parameter for each type of reactor design. The individual target is the minimum target for individual reactors to meet, while the industry target is a more aggressive target used to assess the collective performance of reactors operated by all WANO members. WANO’s targets include ones for pressurized heavy water reactors (PHWRs), which, according to the regulatory oversight report for 2018 [2], would be the appropriate benchmarks for the CANDU reactors. However, CNSC staff have used the more aggressive target for pressurized water reactors (PWRs) for comparison in figure 4, superimposing a line representing WANO’s industry target (0.5 scrams per 7,000 hours critical) for PWRs. Figure 4 indicates that Canadian NPPs have been collectively well within that target since 2015. It is also clear that they would compare even more favourably against the WANO industry target for PWHRs.

To put the Canadian data in context, WANO reported that 72% of reactors worldwide met WANO’s industry target for their respective reactor type in 2019.

#### Reporting and trending

The General Nuclear Safety and Control Regulations outlines specific scenarios under which licensees must file a report to the CNSC. For every reportable event, the licensees must file an event report that provides details regarding the event, including effects on the environment, the health and safety of persons, and the maintenance of security that have resulted or may result from the situation. Corrective actions that the licensees have taken or propose to take with respect to the reportable event must also be included. In 2019, CNSC staff observed that licensees performed all required follow-up on all events and included corrective actions and root cause analyses when appropriate.

Besides requirements for NPP licensees to submit quarterly reports on operations and safety performance indicators, REGDOC-3.1.1 also expands on event reporting requirements in the regulations and specifies requirements for other quarterly and annual reports to the CNSC.

WMF licensees are required to submit annual reports on operations as described in REGDOC-3.1.2. In addition, OPG is required by conditions in the WFOLs to provide a quarterly operations report for all 3 WMFs. Similar to REGDOC-3.1.1, this regulatory document also expands on event-reporting requirements for non-power reactor Class I nuclear facilities and for uranium mines and mills.

#### Outage management performance

During the planned outages in 2019 for all units of operating NPPs, CNSC staff conducted inspections to confirm that regulatory requirements were met and outages were executed safely. All planned and unplanned (forced) outages were followed up appropriately by licensees’ personnel. Through regular status reports on NPPs, CNSC staff informed the Commission about all unplanned outages resulting from reactor trips and associated follow-up in 2019.

#### Safe operating envelope

CNSC staff determined that all licensees of operating NPPs had adequate safe operating envelope (SOE) programs in 2019. The licensees implemented a hierarchy of documents to support production, updates and maintenance of SOE-related documentation. CNSC staff also determined that all licensees operated within their SOEs in 2019.

#### Severe accident management and recovery, and accident management and recovery

The second version of REGDOC-2.3.2, Accident Management, provides updated regulatory requirements for accident management at reactor facilities. All operating NPP licensees have implementation plans for REGDOC-2.3.2.

In 2019, licensees continued to update their severe accident management guidelines (SAMGs) to incorporate post-Fukushima lessons learned, including the addition of guidelines and strategies to deal with multi-unit events for multi-unit NPPs, events in irradiated fuel bays and events during shutdown states. CNSC staff also continued their review of the severe accident management programs for the DNGS and Bruce A and B.

### 2.4 Safety analysis

#### Deterministic safety analysis

In 2019, the NPP licensees continued their safety analysis improvement programs, which include revisions to their facility descriptions and safety analysis reports, in support of the staged implementation of REGDOC-2.4.1, Deterministic Safety Analysis. CNSC staff were satisfied with the progress in 2019 and provided recommendations to the licensees on their ongoing safety analysis improvements. The existing deterministic safety analyses remained adequate during the continued implementation of REGDOC-2.4.1 throughout 2019.

Safety analysis updates in 2019 included those needed to reflect changing reactor conditions, such as the aging of components. The licensees of operating NPPs also submitted to the CNSC specific analyses associated with refurbishment projects and IIPs. Section 3 provides examples.

Large-break loss-of-coolant accidents (LBLOCAs) are analyzed to demonstrate sufficient safety analysis margins for the limiting break size. OPG, NB Power and Bruce Power had proposed the composite analytical approach (CAA) to demonstrate that safety analysis margins for LBLOCA were larger than those evaluated using the traditional safety analysis method that is based on a limit-of-operating-envelope approach. They also intended to use CAA to justify the reclassification of some LBLOCA events as beyond-design-basis accidents by demonstrating the very low frequency of those events. CNSC staff deemed the proposed CAA methodology to be consistent with the requirements in REGDOC-2.4.1.

In 2019, CNSC staff accepted a CAA submission from Bruce Power that demonstrated the low frequency of pipe breaks above a threshold break size (TBS). See section 3.5.4 for details.

UPDATE: In January 2020, Bruce Power submitted a revised LBLOCA analysis and requested that LBLOCA events involving breaks larger than the TBS be reclassified as beyond-design-basis accidents.

OPG continued to support the industry efforts in its resolution of safety analysis margins for LBLOCAs using the CAA as part of its long-term plan. Section 3.1.4 details on OPG’s short-term approach.

NB Power continued to cooperate with Bruce Power in 2019 on the generic aspects of the CAA project and may consider a CAA-based analysis in the future.

#### Probabilistic safety assessment

REGDOC-2.4.2, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants, published in May 2014, introduced requirements that had not been in its predecessor CNSC regulatory document, S-294, also called Probabilistic Safety Assessment (PSA) for Nuclear Power Plants. Examples of the new requirements in REGDOC-2.4.2 are considerations of multi‑unit impacts; combinations of hazards; plant operational states other than the at‑power and shutdown states; and other radioactive sources including the irradiated fuel bays. Point Lepreau has been compliant with REGDOC-2.4.2 since 2016.

In 2019, the DNGS, PNGS and Bruce A and B continued to comply with CNSC regulatory document S-294. The DNGS and PNGS continued to make progress with their implementation plans to comply with REGDOC-2.4.2 requirements by 2020. Bruce Power submitted PSA reports in 2019 to demonstrate compliance with the REGDOC‑2.4.2 requirements, which CNSC staff were reviewing at the end of 2019.

CNSC staff noted that OPG and Bruce Power were addressing the additional requirements outlined in REGDOC-2.4.2 through:

• PSA – for the consideration of multi-unit impacts
• other analysis methods, as allowed by REGDOC-2.4.2 – such as screening and bounding analyses, for the consideration of combinations of external hazards, other plant operational states, and other radioactive sources such as the irradiated fuel bays

The licensees were also participating in CANDU Owners Group projects to address REGDOC-2.4.2 requirements. Table 5 summarizes the status of PSAs at the operating NPPs in 2019.

Table 5: Status of PSAs and reviews
PSA submission DNGS PNGS 1 and 4 PNGS 5–8 Bruce A Bruce B Point Lepreau
Last PSA report received 2015 2018 2017 2019 2019 2016
Review status Completed Completed Completed Ongoing* Ongoing* Completed
Next PSA report expected 2020 2023 2022 2024 2024 2021
Expected compliance REGDOC-2.4.2 2020 2020** 2020** 2019 2019 2016

*   CNSC staff planned to complete their review in 2020.

** OPG made a commitment to provide to the CNSC, by the end of 2020, updates for Pickering Units 1 and 4 and Pickering Units 5–8. The updates would focus solely on the additional updated requirements of REGDOC-2.4.2 that go beyond S‑294 requirements, including, for example, risk assessments of the irradiated fuel bay and other less significant risk contributors.

In addition to addressing the newFootnote 3 requirements in REGDOC-2.4.2, NPP licensees have also worked collaboratively to address direction from the Commission to OPG (associated with the renewal of the operating licence for the PNGS in 2013) to develop an approach for whole-site PSA. Whole-site PSA involves estimating aggregate risk for sites with multiple reactors and other radioactive sources. OPG submitted the whole-site PSA for the PNGS in 2017 [RIB 17557, item ii]. Bruce Power submitted its whole-site PSA methodology in 2018 [RIB 14760] and submitted the aggregated risk values for whole-site PSA for Bruce A and B in April 2019 [RIB 14759]. CNSC staff completed the review in 2019. Based on the information submitted, CNSC staff acknowledged that the submissions provided a good characterization of the whole-site risk for Bruce A and B.

OPG submitted a whole-site, aggregated risk value for the DNGS in 2015. As part of a whole-site PSA for the DNGS, OPG was planning a risk aggregation calculation in 2020 based on the simplified aggregation method that was used for the PNGS and the available results from the DNGS PSA.

As part of the action [RIB 8504] on CNSC staff to provide an update to the Commission on the activities associated with the establishment of a proposed regulatory position on risk aggregation, staff provided the Commission with an update in December 2017 on whole-site PSA [3]. The update included a presentation on staff’s active role in the international effort, especially with the International Atomic Energy Agency (IAEA) and the Nuclear Energy Agency (NEA), and on site-level PSA (including multi-unit PSA) developments such as risk aggregation. The NEA work on the status of site-level PSA developments was completed in December 2018, and the NEA planned to issue the final report in 2020. The IAEA project on multi-unit PSA (MU-PSA) was completed, including its Phase 3 “Review of the MU-PSA Methodology in Light of the Lessons Learnt From the Phase 2 Case Study.” The IAEA was proceeding to publish it as part of the IAEA Safety Report Series.

Both the NEA and IAEA projects reiterated that the scope of risk aggregation is highly dependent on the regulatory requirements, as well as on the intended uses and applications of the PSA. CNSC staff’s position with regard to risk aggregation is further elaborated in section 4.2.2, “Guidance,” of REGDOC-2.5.2, Design of Reactor Facilities: Nuclear Power Plants, and remains valid. Section 4.2.2 states the following:

It is recognized that when the risk metrics for external events are conservatively estimated, their summation with the risk metrics for internal events can lead to misinterpretation. Should the aggregated total exceed the safety goals, conclusions should not be derived from the aggregated total until the scope of the conservative bias in the other hazards is investigated.

#### Severe accident analysis

In 2019, the licensees of operating NPPs continued their severe accident analyses to support PSA Level 2 analysis for the evaluation of plant safety goals, in order to demonstrate the effectiveness of their severe accident management programs and to support severe accident drills and exercises for emergency preparedness and response.

NB Power submitted an updated PSA Level 2 methodology and continued to work on the update of PSA Level 2 analysis. In this updated methodology, a large set of severe accident analyses (using the recently updated severe accident computer code MAAP5-CANDU) was defined and planned for supporting the evaluation of safety goals for Point Lepreau. CNSC staff found NB Power’s methodology for MAAP5-CANDU simulations acceptable.

In 2019, CNSC staff were reviewing the severe accident analysis of the Bruce Power and OPG NPPs in support of their Level 2 PSAs. CNSC staff planned to complete the reviews in 2020.

#### Management of safety issues (including R&D programs)

##### CANDU safety issues

CNSC staff continued to monitor the management of CANDU safety issues (CSIs) by licensees of operating NPPs to ensure timely and effective implementation of plant-specific safety improvement initiatives and risk control measures. In 2019, there were 4 remaining Category 3 CSIs, 3 of which are related to LBLOCA:

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

The different categories of CSIs are described in General Description of Regulatory Framework for Nuclear Power Generating Sites [1]. As noted above, the licensees of operating NPPs continued to develop the CAA methodology in order to address the LBLOCA CSIs. Through an industry-wide agreement, Bruce Power was taking the lead in the regulatory application of the CAA methodology. In 2019, progress was made on long-standing work on the reclassification of the CSIs related to LBLOCA.

For Bruce Power, CNSC staff reviewed the submission related to the CAA for LBLOCA, TBS assessment and additional information in support of the CAA. Subsequently, in November 2019, CNSC staff accepted Bruce Power’s request for reclassification of the 3 LBLOCA CSIs (AA9, PF9 and PF10) from Category 3 to Category 2.

Work in this area by the other licensees was ongoing, and the licensees were expected to submit requests for the reclassification of these CSIs once their analyses were completed.

Remaining Category 3 CSI

The fourth Category 3 issue, IH6, is related to the systematic assessment of the effects of high-energy pipeline breaks inside containment. At the beginning of 2019, this issue only applied as a Category 3 CSI to PNGS Units 1–4 and Point Lepreau. (For PNGS Units 5–8, CNSC staff had reclassified CSI IH6 from Category 3 to Category 2 in 2018.)

For PNGS Units 1–4, in November 2019 CNSC staff completed their review of OPG’s request pertaining to reclassification of CSI IH6. Based on OPG’s response to CNSC staff’s request for additional information and clarification, OPG’s reclassification request was granted. However, this reclassification was conditional on OPG providing further assurance of the actual condition of the non-nuclear, high-energy pipelines inside containment.

For Point Lepreau, CNSC staff reviewed NB Power’s report on CSI IH6 analysis and, in January 2019, reclassified CSI IH6 from Category 3 to Category 2.

Reclassification of CSI AA3

CSI AA3, on computer code and plant model validation, had previously been reclassified from Category 3 to Category 2. As part of ongoing activities to address residual issues related to CSI AA3, the licensees of operating NPPs had contributed to the revision of the CANDU Owners Group (COG) guidelines on code validation and code accuracy assessment, as described in the regulatory oversight report for 2018 [2]. The licensees were also addressing other areas that needed further improvements to meet the objectives of the computer code and plant model validation program associated with CSI AA3. In 2019, the licensees provided a status update on the remaining work related to CSI AA3 and requested the closure of the associated action items. At the end of 2019, CNSC staff’s review was in progress.

##### R&D programs

In 2019, 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 safety provisions in key areas.

The licensees continued to participate in COG R&D and joint project programs, in collaboration with both national and international stakeholders, which included ongoing monitoring, review and maintenance of R&D capability.

In 2019, all licensees submitted their 2018 COG R&D annual reports, which included:

• annual COG R&D program overview reports and operational plans
• multi-year strategic plans and capability maintenance reviews

The COG R&D program included the following 5 base program areas and the strategic R&D program:

• fuel channels
• safety and licensing
• health, safety and environment
• chemistry, materials and components
• Industry Standard Toolset

These programs aimed to support the safe, reliable and efficient operation of CANDU reactors in the short and long term. Their main objectives included the following:

• provide qualitative and quantitative experimental data to demonstrate key phenomena during the late phase of a postulated severe accident
• develop a consistent set of minimal requirements for the assessment of doses
• develop and demonstrate the effectiveness of various mitigation features in containment
• support the industry in increasing safety margins in CANDU stations in all operational states
• provide a database for use in industry tool set computer codes

### 2.5 Physical design

In 2019, each licensee carried out various modifications to improve the overall performance of its facilities and improve safety in design and operations. There were no impacts on the licensees’ abilities to operate within their safety cases while they made these changes.

#### Design governance

In 2019, CNSC staff reviewed the licensees’ updates of their fire protection programs and fire protection assessments and confirmed that they complied with the applicable fire protection requirements.

#### System design

In 2019, CNSC staff confirmed that the licensees’ electrical power systems (EPSs) and instrumentation and control (I&C) functioned as expected.

#### Components 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 (such as fuel defects or fuel bundle vibrations). However, licensee fuel programs and personnel have adequately managed these challenges. Licensees have met regulatory limits for fuel bundle and fuel channel power throughout this period. Fuel performance has returned to historic norms, with the remaining challenges having mitigation strategies in place or in development. CNSC staff continued to monitor the status of the mitigation strategies and were satisfied with the licensees’ management of these issues in 2019. Section 3 provides details on individual licensee challenges and performance.

The licensees of operating NPPs have cable condition monitoring and surveillance programs that are verified through compliance activities to ensure their effectiveness in supporting safe and reliable operations. CNSC staff were satisfied with the licensees’ management of these programs in 2019.

### 2.6 Fitness for service

#### Equipment fitness for service / equipment performance

The licensees of operating NPPs monitor the performance or condition of the special safety systems (SSSs) against unavailability targets (no higher than 0.001) to ensure that these systems are capable of fulfilling their intended functions. Overall, the SSSs performed well in 2019 and met their unavailability targets, with some exceptions as outlined in section 3.

The licensees also monitored missed tests of systems important to safety. Table 6 and figure 5 show data for the operating NPPs and “the industry” as a whole.

The number of total missed safety system tests remained very low in 2019. In all, 47,244 tests were performed and the fraction of missed tests was 0.01%. The impact of missing a single test is negligible because the NPP designs have sufficiently high redundancy to ensure continuous availability of the safety systems. Table 6 indicates that 5 tests of SSSs were not fully completed before the due date.

Table 6: Safety system test performance for 2019
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 10,381 3 1 1 5 0.05
PNGS 14,318 0 0 0 0 0.00
Bruce A 9,628 0 0 0 0 0.00
Bruce B 8,824 0 0 0 0 0.00
Point Lepreau 4,093 2 0 0 2 0.05
Industry total 47,244 5 1 1 7 0.01

In 2016, OPG initiated a joint fuelling machine reliability project with NB Power through COG with the aim of preventing premature failures of the fuelling machine ram seals. Following engineering, testing and manufacturing, OPG received new (type IV) ram seals, housings and sleeves in 2019 for Pickering Units 5–8. OPG completed the initial installation (Unit 8 West) on December 27, 2019 [RIB 17557, item iii].

UPDATE: OPG completed the next installation (Pickering Unit 7 East) on April 30, 2020. The 2 fuelling machines with replaced seals had fuelled hundreds of fuel channels without experiencing any performance issues. OPG was proceeding with the installation of the new seals for the remaining fuelling machine rams for Units 5–8. OPG also expected to receive additional materials to service rams for Pickering Units 1 and 4 by the end of August 2020.

#### Maintenance

The preventive maintenance completion ratio quantifies the effectiveness of the preventive maintenance program in minimizing the need for corrective maintenance activities for safety-related systems. The average preventive maintenance completion ratio value for operating NPPs was 94% in 2019. CNSC staff were satisfied with the effectiveness of the licensees’ preventive maintenance.

The corrective maintenance backlogs, deficient maintenance backlogs and deferrals of preventive maintenance are also used to monitor the effectiveness of the maintenance programs at NPPs. The corrective and deficient maintenance backlogs, as well as the deferrals of preventive maintenance, reported in this regulatory oversight report are for critical components, which are defined by the licensee as those that are significant in terms of plant safety and/or plant operation.

Table 7 shows the trends of the maintenance backlogs and deferrals for the industry. The industry average of these safety performance indicators continuously decreased or were kept low in 2019. Overall, CNSC staff were satisfied with the progress in 2019. The current levels of the maintenance backlogs and deferrals for critical components for the NPPs represent a negligible risk to the safe operation of the NPPs.

Table 7: Trend of industry maintenance backlogs and deferrals for critical components of NPPs, 2017 to 2019
Safety performance indicator Average quarterly work orders per unit in 2017 Average quarterly work orders per unit in 2018 Average quarterly work orders per unit in 2019 Three-year trending
Corrective maintenance backlog 4 1 1 down
Deficient maintenance backlog 94 16 9 down
Deferrals of preventive maintenance 30 4 2 down

#### Aging management

##### Pressure tubes and fuel channels – Overall performance

With respect to the pressure tubes in operating NPPs, overall CNSC staff were satisfied that the lifecycle management plans (LCMPs) reflected sound aging management. CNSC staff also continued to review the results from fuel channel inspections that occurred routinely during planned inspection outages in 2019. They confirmed that no new flaw-initiation mechanisms were identified and that licensees appropriately evaluated any findings that required disposition, in accordance with CSA Group standards. CNSC staff concluded that fitness-for-service of inspected pressure tubes was effectively demonstrated.

CNSC staff were satisfied with the licensees’ work to ensure that fuel channel spacers continued to perform their design function in 2019. A review of available information confirmed that the spacers were behaving predictably.

CNSC staff have enhanced regulatory oversight for licensees’ activities to assess and manage the aging of fuel channels for units entering periods of extended operation. This increased focus on fuel channels is due to the fact that they are being operated beyond 210,000 effective full-power hours (EFPH) at some units. (Designers assumed 210,000 EFPH in order to establish the inspection requirements and acceptable levels of in-service degradation for CANDU pressure tubes.)

##### Recent developments and research in aging management

For in-service changes in pressure tube properties (such as fracture toughness), equivalent hydrogen (Heq) concentration is more important than EFPH. Fracture toughness is an important parameter that is modelled and used for assessments of leak-before-break and fracture protection of pressure tubes. For temperatures below 250 °C, Heq content in the pressure tube is a critical input to the fracture toughness model. 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.

The licensees continued R&D related to the modelling of fracture toughness of pressure tube material in 2019 as some operating reactors may reach a Heq concentration of 120 ppm before their planned shutdown or refurbishment. In addition, improvements related to the model and its applicability were needed to maintain confidence in its use.

CNSC staff consider that the current regulatory process to monitor additional validation of the existing fracture toughness model up to Heq of 120 ppm is adequate to ensure that the model will adequately support assessments mandated by the CSA Group standards. In preparation for units approaching the validity limit of the existing toughness model (120 ppm Heq in any pressure tube), licensees must also develop a revised toughness model (capable of predicting toughness beyond 120 ppm Heq) and submit the technical basis for CNSC staff’s approval well before any pressure tube reaches 120 ppm.

The licensees must seek CNSC staff concurrence (for the PNGS) or Commission approval (for Bruce A and B) to operate any pressure tube beyond 120 ppm Heq. Appendix C shows details on the current and anticipated future fuel channel conditions [RIB 14757, item ii] and validity of the fracture toughness model for the NPPs in Ontario.

In 2019, CNSC staff actively monitored the industry’s progress in research activities to ensure that licensees have sufficient understanding of degradation issues to safely operate pressure tubes, especially those planned for extended operation. Specifically, CNSC staff monitored the fuel channel life confirmation project, which included the following activities in 2019:

• research focusing on the fracture toughness of near-inlet areas of pressure tubes and changes in toughness occurring as Heq levels exceed 120 ppm [RIB 14757, item i]
• collection of additional pressure tube burst-test data, supporting development of a revised version of the fracture toughness model [RIB 14757, item i]
• continued development of assessment methodologies:
• a probabilistic approach for demonstrating fracture protection (that is, confirmation that a pressure tube will continue to meet its design intent, if an undetected crack is subject to design-basis pressure/temperature transients)
• a fully deterministic approach for assessing the risk of cracking due to hydrided region overload (that is, when a hydrided area is exposed to greater stress than existed when it was initially created)
• continued development of an industry-standard set of fitness-for-service guidelines for Inconel X-750 (a.k.a. “tight-fitting”) annulus spacers

Overall, CNSC staff were satisfied with the licensees’ work to demonstrate and support the safe operation of pressure tubes in the near- and medium-term.

#### Chemistry control

Figures 6 and 7 show the values of the safety performance indicators “chemistry index” and “chemistry compliance index” for operating NPPs from 2015 to 2019. Based on these values, CNSC staff determined that chemistry control was acceptable for all licensees. The comparatively low results for the chemistry compliance index for Bruce A and B (figure 7) were due to a downward trend in moderator (heavy water (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.

#### Periodic inspections and testing

The licensees of operating NPPs are developing periodic inspection programs that comply with CSA N285.7, Periodic Inspection of CANDU Nuclear Power Plant Balance of Plant Systems and Components, which will be adopted as compliance verification criteria in the future for all operating NPPs except the PNGS. Implementation of a program for N285.7 was not practical for the NGS, given the planned shutdown in 2024. However, CNSC staff planned to apply experience gained from its implementation at other NPPs to the PNGS, in order to address potential safety concerns should the need arise.

#### Application of ALARA (as low as reasonably achievable)

In 2019, the total collective dose for monitored individuals at all Canadian NPPs and WMFs was 20.4 person-sieverts (p-Sv), approximately 21% lower than the industry-wide collective dose reported for 2018 (25.9 p-Sv). The number of persons who received a reportable dose in 2019 (9,857) was slightly higher than 2018 values (9,792). The decrease in total collective dose was mainly due to a reduction in high-dose refurbishment activities at the DNGS.

The vast majority of collective doses for the NPPs and WMFs occurs at the operating NPPs. Table 8 shows the collective doses for the individual NPPs. It illustrates that outages (including refurbishment activities) accounted for a much greater fraction of the collective dose than routine operations and that external dose was, collectively, much greater than internal dose.

Table 8: Breakdown of collective dose for operating NPPs in 2019 (person-mSv)
NPP Routine operations Outages Internal External Total
DNGS 394 7,263* 469 7,188* 7,657*
PNGS 869 2,216 652 2,433 3,085
Point Lepreau 224 372 156 440 596
Bruce A 336 4,725 262 4,798 5,061
Bruce B 575 4,100 297 4,377 4,674

* For 2019, only the DNGS had dose attributed to refurbishment activities.

Figures 8, 9, and 10 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 for 2015 to 2019.

Figure 8 shows that, for 2019, the average effective dose at each NPP and WMF ranged from 0.23 to 3.07 mSv per year. In general, the fluctuations in average dose observed from year to year reflect the type and scope of work being performed at each facility. No negative trends were identified in 2019. The annual average effective dose in 2019 for all Canadian NPPs was 2.07 millisieverts (mSv), an approximate decrease of 21.5% from the 2018 value of 2.64 mSv.

Background information on the ALARA principle is provided in General Description of Regulatory Framework for Nuclear Power Generating Sites [1].

#### Worker dose control

Figure 9 presents the maximum annual individual effective doses, as reported by each NPP and WMF for 2015 to 2019. In 2019, the maximum individual effective dose received at a single site was 16.69 mSv, received by a worker who performed duties at both Bruce A and B. No radiation exposures received by persons at any NPP or WMF exceeded the regulatory dose limit of 50 mSv/year for nuclear energy workers, as established in the Radiation Protection Regulations.

Overall, CNSC staff were satisfied with the licensees’ control of worker doses in 2019.

Figure 10 provides the distribution of annual effective doses to all monitored persons at all Canadian NPPs from 2015 to 2019. All doses reported over those years were below the annual regulatory dose limit of 50 mSv for nuclear energy workers. In fact, approximately 84% of the doses reported were at or below the much lower annual regulatory dose limit of 1 mSv for members of the public.

In 2019, no contamination control action levels were exceeded and CNSC staff did not identify issues of safety significance at any NPP or WMF.

### 2.8 Conventional health and safety

#### Performance

This section provides data for the safety performance indicators “accident severity rate” (ASR), “accident frequency” (AF) and “industrial safety accident rate” (ISAR). The ASR is the total number of days lost due to work-related injuries for every 200,000 person-hours (approximately 100 person-years) worked at an NPP. The AF is 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 the number of accidents that result in fatalities, lost-time, or restricted work for every 200,000 hours worked by NPP personnel.

Note that REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants, requires NPP licensees to report these data for their workers and for contractors, but not for third-party contractors (that is, subcontractors). In 2019, the Commission noted the importance of injury data for third-party contractors and also noted the value of obtaining more complete data (specifically, total recordable injury frequency) [6]. Recognizing that the collection of such data was not required by REGDOC-3.1.1, the Commission instructed CNSC staff to compare the costs and benefits of adding that requirement to REGDOC-3.1.1. At the end of 2019, CNSC staff were considering that analysis as part of a planned revision of REGDOC-3.1.1 [RIB 17560].

The ASR, AF and ISAR values for the NPPs and industry average are presented in figures 11, 12 and 13, respectively. The data in these figures indicate continuing low rates of accidents and lost time due to accidents. CNSC staff observed that no work-related fatalities occurred at Canadian NPPs and WMFs in 2019.

ISAR, illustrated in figure 13, is a safety performance indicator that is also monitored by WANO in a similar fashion. The WANO targets for this parameter are superimposed on figure 13 – a minimum target for individual stations to meet and a more aggressive target that is used to assess the collective performance of stations operated by all WANO members. Figure 13 indicates that Canadian NPPs have been individually and collectively well within the respective individual and collective WANO targets since 2015.

To put the Canadian data in context, WANO reported that 85% of stations worldwide met WANO’s minimum target for individual stations and 75% of those stations also met the more aggressive collective target in 2019. In 2019, all of the Canadian NPPs met WANO’s more aggressive collective target.

### 2.9 Environmental protection

#### Effluent and emissions control (releases)

Derived release limits (DRLs) are quantities of radionuclides (released as an airborne emission or waterborne effluent) that are calculated based on the regulatory dose limit for the public of 1 mSv per year. 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. Appendix D lists the DRLs.

Appendix D also provides data on releases of radionuclides to the environment in 2019. The releases were well below the DRLs for each facility. In fact, the releases were, in many cases, 3 or more orders of magnitude less than the applicable DRL. This means that no radiological releases to the environment from the facilities exceeded the regulatory limits. Furthermore, only 1 environmental action level was exceeded in 2019 at the NPPs and WMFs (a monthly environmental action level; see section 3.3.9 for details). The environmental action levels are 10% of the DRL (or less, depending on the facility) for the release type.

#### Environmental management system

All environmental management systems (EMSs) for operating NPPs and WMFs are registered with the International Standards Organization (ISO) 14001:2015 standard, Environmental Management Systems – Requirements With Guidance for Use. As a result of registration, the EMSs are subject to periodic, independent third-party audits and reviews to verify their sufficiency and identify potential improvements. CNSC staff confirmed through inspections that annual management reviews of the EMS took place in 2019, and that corrective actions were documented.

#### Assessment and monitoring

Licensees of NPPs and adjacent WMFs are required to submit annual environmental reports to the CNSC. Licensees also monitor groundwater around all sites and regularly submit the results to the CNSC. CNSC staff reviewed the 2019 monitoring results and concluded that the licensed operations had no adverse impact on the environment.

The CNSC’s Independent Environmental Monitoring Program did not include monitoring activities in 2019 in the near vicinity of the facilities discussed in this regulatory oversight report. Program results from previous years had supported the conclusion that the public and the environment in the vicinity of all sites were protected.

#### Estimated dose to the public

Table 9 shows the estimated doses to the public for airborne emissions and liquid releases from 2015 to 2019. Note that the data for the DWMF, PWMF and WWMF are included in those of the Darlington, Pickering and Bruce sites, respectively. The table shows that the doses were well below the annual regulatory dose limit of 1 mSv for members of the public, as well as below 1.8 mSv, which is the average national annual background dose. A comparison of the 2019 data with that of previous years indicates that the values remained within the same general range (<0.01 mSv) as the values for 2015 to 2018.

The value for estimated dose in 2019 for the Gentilly-2 Facilities (0.003 mSv) was lower than that of 2018 at those facilities but higher than the values for other NPPs. However, 0.003 mSv is still a relatively small value (well below the regulatory limit of 1 mSv).

Darlington site Pickering site Point Lepreau site Bruce site Gentilly-2 0.0005 0.0012 0.0006 0.0029 0.0010 0.0006 0.0015 0.0009 0.0016 0.0010 0.0007 0.0018 0.0007 0.0021 0.0070 0.0008 0.0021 0.0007 0.0017 0.0090 0.0004 0.0017 0.0012 0.0015 0.0030

### 2.10 Emergency management and fire protection

#### Nuclear emergency preparedness and response

The licensees’ nuclear emergency plans include measures to address onsite emergencies, as well as measures that support planning, preparedness and response for offsite emergencies. Note that OPG has a single, Consolidated Nuclear Emergency Plan that covers both the Darlington and Pickering sites and includes the Darlington and Pickering WMFs. The WWMF is covered under the nuclear emergency response plan and fire response plan for Bruce Power.

The following describes developments in 2019 related to offsite emergency planning and also provides, where needed, historical information from previous years related to the provincial nuclear emergency plans and related activities.

##### Province of Ontario

Provincial Nuclear Emergency Response Plan

The Lieutenant Governor in Council of Ontario approved the updated Master Plan for the Provincial Nuclear Emergency Response Plan (PNERP) in December 2017. This approval triggered the development of site-specific implementing plans and subsequent incorporation of the relevant provisions in the Ontario licensees’ emergency plans [RIB 17522, item i].

In 2018, the work focused on the Darlington, Pickering and Bruce Power PNERP implementing plans to ensure conformity with the Master Plan as well as updates to preparedness and response provisions since the last versions were issued in 2009. The Pickering and Bruce Power implementing plans received Order-in-Council approval in March 2018 [RIB 17522, item ii]. The Darlington implementing plan received final approval in March 2019. A technical study examining the planning basis for the Pickering, Darlington, Bruce Power and Fermi 2 areas through robust modelling was submitted in the spring of 2019 to the Solicitor General [RIB 17522, item iii]. Once released, the Ontario licensees plan to revise their training programs for new emergency response personnel accordingly.

Emergency Management Ontario (EMO) made progress in 2019 on a number of PNERP-related preparedness issues, including notification processes and agreements, participation in the CNSC-led working group on potassium iodide distribution (KI Pill Working Group) and the revision of the emergency bulletins for alignment with the new PNERP.

In June 2018, the Ontario Ministry of Transportation (MTO) started working to secure approval to procure a consultant to draft the transportation management methodology and 5 site-specific unified transportation management plans as required by the 2017 PNERP. In the fall of 2019, the approach shifted to consider options for the use of internal ministry resources. MTO staff were also involved in regular intra-ministry discussions to ensure that the unified transportation management plans integrate effective traffic control strategies and can be made operational in the field [RIB 17522, item iv].

OPG continued its work in 2019 to revise its public information and disclosure program for people living beyond the planning zone for Pickering [RIB 17522, item v]. OPG continued to collaborate with its key partners as members of the Pickering/Darlington Nuclear Public Education Sub-Committee (the next meeting of the sub-committee was planned for September 2020) and on the KI Pill Working Group. OPG also supported the Regional Municipality of Durham and the City of Toronto with the development of a local Public Education and Awareness strategy for the areas around the PNGS and DNGS, including those areas outside the detailed planning zone. That strategy and the supporting tactics are targeted for completion by the end of 2020.

IAEA Emergency Preparedness Review mission

In 2018, Ontario’s Office of the Fire Marshal and Emergency Management (OFMEM) continued to support Health Canada and the CNSC in the Ontario portion of the IAEA Emergency Preparedness Review (EPREV) that focused on the DNGS. In June 2019, OFMEM hosted the EPREV team in Toronto. See CMD 20-M14 [7] for details on the EPREV.

Environmental radiation and assurance monitoring is undertaken during a nuclear emergency to inform protective-action decision making as well as recovery planning. At the end of 2019, OFMEM finalized the Environmental Radiation and Assurance Monitoring Plan based on input from various stakeholders including federal departments and several Ontario ministries (Ministry of Health and Long-Term Care; Ministry of Labour, Training and Skills Development; Ministry of Agriculture and Food; and Ministry of Environment, Conservation and Parks). Final approvals were expected in 2020, following which OFMEM planned to work with stakeholders to develop and implement the procedures needed to execute the plan, including necessary training. This effort was expected to take a number of years to complete.

##### Province of New Brunswick

The New Brunswick Emergency Measures Organization (NBEMO) issued the new Point Lepreau Nuclear Off-Site Emergency Plan in August 2018 and made it available online. NBEMO aligned it with the applicable domestic and international requirements and made its interface more user-friendly. CNSC staff confirmed that Point Lepreau complied with the new plan.

In February 2019, the new Off-Site Emergency Operations Centre located in St. George was declared operational.

NBEMO completed a demographic public safety survey between April and September 2019. It posed a variety of questions to all residents, which allowed NBEMO to produce detailed reports on residents living in the various zones surrounding the Point Lepreau site. NBEMO maintained the survey database and also included data on distribution of KI pills (for example, who received them and when, and who refused them).

##### Province of Quebec

The offsite nuclear emergency response plan for Quebec (“Plan des mesures d’urgence nucléaire externe à la centrale nucléaire Gentilly-2,” or PMUNE-G2) was abolished in 2016. However, Quebec’s broader emergency plan (“Plan national de sécurité civile” (PNSC)) has remained in place to address emergencies in general. The PNSC involves the cooperation of various ministries and governmental organizations that have a defined role to play when responding to an emergency. The directorate for public health under Quebec’s Ministry of Health and Social Services will intervene for infectious, chemical, biological or radiological emergencies.

##### Emergency exercises

Bruce Power held a full-scale exercise (Exercise Huron Resilience) at the Bruce site from October 20 to 23, 2019. This exercise tested and validated emergency preparedness, response capabilities and the collaborative and consultation processes of Bruce Power and its stakeholders. See section 3.5.10 for details. Bruce Power conducted a tabletop exercise of its business continuity procedures.

#### Fire emergency preparedness and response

OPG conducted 3 fire drills at each OPG WMF in 2019.

### 2.11 Waste management

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

The minimal low-level radioactive waste (LLW) generated at the DWMF and the PWMF is typically restricted to floor sweepings that have a potential to contain contamination from the preparation and welding of dry storage containers (DSCs). The DWMF and PWMF send their LLW – each facility’s LLW totalling less than 1 drum – to the DNGS and PNGS, respectively, for segregation as necessary. Eventually, the DSCs are transported to the WWMF for processing and storage. LLW at the WWMF is processed and/or stored onsite. OPG does not generate intermediate-level radioactive waste (ILW) at the DWMF, PWMF or WWMF.

OPG has a waste-sorting pilot project at the WWMF to further reduce the volume of waste stored at the facility through incineration, compaction, decontamination or free release.

All NPP and WMF licensees continued to employ effective programs for the characterization, minimization, handling, processing, transporting, storage and disposal of radioactive and hazardous wastes during 2019.

There were no changes to note for 2019 regarding the preliminary decommissioning plans (PDPs) for the nuclear facilities listed in this report. At the time of their review, CNSC staff found that the documents met or exceeded regulatory requirements and guidance. Note: The Bruce Power PDP is provided by OPG. Bruce Power and OPG have made their PDPs publicly available.

Section 2.15 discusses the financial guarantees for decommissioning.

### 2.12 Security

#### Facilities and equipment

The licensees did not report any significant security equipment failures to CNSC staff in 2019.

#### Response arrangements

All licensees provided well-trained and suitably equipped nuclear security officers and nuclear response force members for their facilities and have formal arrangements with offsite armed response services. The licensees contributed significant resources to the CNSC performance testing program by providing expert staff and participants to the Canadian Adversary Testing Team, which is utilized to conduct force-on-force exercises at high-security sites.

#### Drills and exercises

The licensees maintained drill and exercise programs in 2019 that met the applicable regulatory requirements and tested the effectiveness of the physical protection systems at their facilities, consistent with their design-basis threats.

#### Cyber security

Licensees continued to work through the COG cyber security peer group program to share lessons learned and develop best industry practices for implementing cyber security controls.

### 2.13 Safeguards and non-proliferation

#### Nuclear material accountancy and control

CNSC staff confirmed that the accountancy and control of nuclear material at all NPPs and WMFs complied with the applicable regulatory requirements in 2019. The licensees submitted their required monthly general ledgers on time.

The CNSC published REGDOC-2.13.1, Safeguards and Nuclear Material Accountancy, in February 2018. The regulatory document aims to establish a common understanding of the information, access and support that licensees are to provide to the CNSC and to the IAEA in order to facilitate Canada’s compliance with its safeguards agreements.

CNSC staff requested that the affected licensees provide an implementation plan for REGDOC-2.13.1 by July 2018. NB Power and Bruce Power implemented the new regulatory document by the end of 2019. OPG planned to fully implement the regulatory document by 2021, although it was already making significant progress towards implementation in 2019.

CNSC staff determined that Hydro-Québec’s Gentilly-2 Facilities already met the new requirements. No additional action was required for Hydro-Québec.

#### Access and assistance to the IAEA

In 2019, the IAEA conducted 19 announced, 5 short-notice and 30 unannounced inspections at the NPPs and WMFs. Table 10 shows the number of activities conducted by the IAEA at each NPP and WMF in 2019.

Table 10: IAEA safeguards activities for 2019
Activity DNGS DWMF PNGS PWMF Bruce A Bruce B WWMF Point Lepreau Gentilly-2 Totals
Physical inventory verifications 1 1 1 1 1 1 1 1 1 9
Design information verifications 1 1 2 1 1 1 1 1 1 10
Short-notice random inspections 1 N/A 1 N/A 1 1 N/A 1 0 5
Unannounced inspections 5 2 3 6 4 4 4 5 2 30
Complementary access 0 0 0 0 0 0 0 0 0 0

CNSC staff verified that the licensees met the applicable regulatory requirements for access and assistance at the NPPs and WMFs. Pursuant to the Canada/IAEA safeguards agreements and the facilities’ licence conditions, the licensees granted timely access and provided adequate assistance to the IAEA for safeguards activities at the facilities. While the IAEA encountered minor implementation issues during a few inspections, it considered the overall results satisfactory.

CNSC staff confirmed that the licensees met the applicable regulatory requirements for operational and design information for the NPPs and WMFs in 2019. The licensees submitted their annual operational programs, with quarterly updates for their facilities, to the CNSC on time. The licensees also submitted their annual updates for the Additional Protocol to the CNSC on time, enabling CNSC staff to draft and submit Canada’s Additional Protocol declarations to the 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 the licensees met the applicable regulatory requirements for safeguards equipment, containment and surveillance for the NPPs and WMFs in 2019. The licensees supported IAEA equipment operation and maintenance activities, including maintenance and installation of surveillance equipment (such as IAEA cameras, seals and spent fuel monitors) to ensure the effective implementation of safeguards measures at each facility.

In January 2019, the single-unit CANDU NPPs (that is, Point Lepreau and Gentilly-2) supported IAEA technical visits to discuss a revised safeguards approach for these facilities. This was a follow-up to the IAEA’s site surveys in October 2017. Similar technical visits at the multi-unit NPPs and their associated WMFs took place in September 2018.

#### IAEA safeguards conclusion for Canada

Based on the IAEA’s comprehensive evaluation of all safeguards-relevant information available to it and an evaluation of the consistency of Canada’s declared nuclear program with the results of the IAEA’s verification activities, the IAEA was able to conclude that all nuclear material in Canada, including the nuclear material at the NPPs and WMFs, remained in peaceful activities.

### 2.14 Packaging and transport

There were no packaging and transport events reported in 2019 at the NPPs and WMFs that had any safety significance.

### 2.15 Other matters of regulatory interest

#### Public information and disclosure programs

CNSC REGDOC-3.2.1, Public Information and Disclosure, sets out the requirements for public information and disclosure programs. The primary goal of the program is to ensure that information related to the health, safety and security of persons and the environment, and other issues associated with the lifecycle of nuclear facilities, is shared with the public in a format relevant to the audience. The program includes a commitment and protocol for ongoing, timely dissemination of information related to the licensed facility.

CNSC staff determined that the public information and disclosure programs for the NPPs and WMFs complied with REGDOC-3.2.1 in 2019, and that the licensees provided information on the status of their facilities through various formats to multiple audiences. CNSC staff met with OPG, Bruce Power and NB Power to discuss the benefits of their communications programs, areas for improvement and plans for future initiatives.

Some highlights noted among licensees in 2019 included the following.

##### Ontario Power Generation

In addition to community and Indigenous engagement programs, OPG communicated to the public on the status of the DNGS refurbishment project and operations at the PNGS through regular newsletter updates to local communities, municipal council updates, open houses and the information centre to engage and inform residents and stakeholders. OPG renewed its website, providing users with a refreshed look at its operations, and increased its presence on social media, providing another avenue for public engagement and two-way discussion.

##### Bruce Power

Bruce Power had an extensive community and Indigenous engagement program, which included telephone town hall meetings, an active online presence, an updated website and bus tours, and participation in local community activities. In addition, Bruce Power implemented an online and traditional media campaign highlighting its contribution to the energy and medical communities. Bruce Power conducted extensive research to understand the effectiveness of its communication program with the general public and to learn how to improve and refine messaging to have more impact with its target audiences.

##### NB Power

NB Power continued to maintain an active role in its community. Through multiple venues, NB Power continued to foster relationships with Indigenous and local community members on various projects of mutual interest to share knowledge and experiences and to develop greater common understanding with the Point Lepreau management team. NB Power continued to provide regular station updates and information on new technologies and upcoming projects to multiple audiences.

##### Hydro-Québec

At the Gentilly-2 Facilities, Hydro-Québec provided its target audiences with opportunities to observe the status of the decommissioning project through interviews and meetings. In 2019, Hydro-Québec hosted media access to the Gentilly-2 Facilities and offered tours to key audiences with a specific interest in the decommissioning project. In addition, Hydro-Québec continued to update the project website for its multiple audiences, providing them with opportunities for public inquiries and general discussion as required.

#### Indigenous consultation and engagement

##### General overview

CNSC staff efforts in 2019 supported the CNSC’s ongoing commitment to meeting its consultation obligations and building relationships with Indigenous peoples with interests in Canada’s nuclear power generating sites. CNSC staff continued to work with Indigenous communities and organizations to identify opportunities, such as meetings and facilitated workshops, for formalized and regular engagement throughout the lifecycle of these facilities. Through these activities, CNSC staff aimed to discuss and address all topics of interest and concern to interested Indigenous communities.

In addition, CNSC staff provided interested communities with notices of the opportunity for funding through the CNSC’s Participant Funding Program to review and comment on this report and the opportunity to submit a written intervention and/or appear before the Commission, as part of the associated Commission meeting.

As part of upholding the Crown’s duty to consult Indigenous communities, the CNSC also confirms that its licensees engage those communities in a meaningful way. In 2019, CNSC staff monitored the NPP and WMF licensees to ensure that they actively engaged and communicated with Indigenous groups who have interest in their facilities. CNSC staff confirmed that the licensees’ dedicated Indigenous engagement programs continued to cover their operations at the NPPs and WMFs. CNSC staff were also satisfied with the level and quality of Indigenous engagement conducted by the NPP and WMF licensees about their operations in 2019.

The following summarizes the engagement activities for each site conducted by CNSC staff and the licensees in 2019.

##### Darlington and Pickering sites
###### CNSC staff engagement activities

The DNGS, DWMF, PNGS and PWMF lie within the Treaty territory of the Williams Treaties First Nations (WTFN).Footnote 4 The Mohawks of the Bay of Quinte (MBQ) and the Métis Nation of Ontario (MNO), on behalf of the MNO Region 8 Consultation Committee, have also asked to be kept informed of any activities related to these sites. In 2019, CNSC staff continued to engage with these First Nation and Métis groups in recognition of their longstanding interest in the operations of the DNGS and PNGS. Regular discussions covered the ongoing DNGS refurbishment project and the operations and performance of the DNGS, DWMF, PNGS and PWMF. Additional details are provided below.

In addition, in December 2019 the CNSC and the MNO signed Terms of Reference to provide a forum through which to collaborate and address areas of interest or concern regarding CNSC-regulated facilities and activities. As the MNO is a province-wide organization, a specific engagement plan was being developed between the CNSC and the MNO Region 8 Consultation Committee, whose region includes the Pickering and Darlington sites, to determine the appropriate frequency of regular engagement meetings to address their specific areas of interest.

Throughout 2019, OPG met and shared information with interested Indigenous communities and organizations including the WTFN, the MNO and the MBQ. Topics of discussion included the ongoing DNGS refurbishment project, environmental monitoring activities, fish impingement and entrainment at the DNGS and PNGS [RIB 16516, item iii (b)], OPG’s intent to renew the licence to prepare the site for the Darlington New Nuclear Project, and the proposed DNGS isotope project.

In 2019, OPG continued its efforts to address concerns raised by Indigenous groups and conducted multiple site visits, provided regular briefings, and involved Indigenous communities in environmental monitoring activities.

##### Bruce site
###### CNSC staff engagement activities

The Bruce site lies within the traditional territory of the Chippewas of Nawash Unceded First Nation and Saugeen First Nation, who together form the Saugeen Ojibway Nation (SON), as well as within the asserted traditional harvesting territory of the MNO and Historic Saugeen Métis (HSM). CNSC staff engage with all 3 communities on areas of interest to them. As committed to each of the communities, the updates below were prepared in collaboration with their representatives.

Historic Saugeen Métis (HSM)

Following the licence renewal hearing for Bruce A and B, Terms of Reference were agreed upon and signed on April 12, 2019, between CNSC staff and the HSM; the Terms of Reference formally document the engagement with the HSM’s community. CNSC staff met with HSM representatives in 2019 to discuss areas of interest such as the Douglas Point decommissioning licence application; and Bruce Power’s Fisheries Act authorization, mitigation measures study and major component replacement project. The HSM also participated in the CNSC’s IEMP by identifying local plant species important to the HSM community and assisting technical staff with collection in the field. While the HSM did not have any outstanding concerns related to the nuclear activities on the Bruce site, they continued to actively participate and make informed contributions to address any potential impacts on HSM rights and interests. CNSC staff planned to continue to engage with and update the HSM on regulatory activities twice a year as agreed upon in the Terms of Reference.

Métis Nation of Ontario (MNO)

Since the Commission hearings for Bruce Power’s licence renewal in 2018, the CNSC has continued to work in the spirit of collaboration and partnership to formalize its relationship with the MNO. On December 17, 2019, CNSC staff and the MNO signed Terms of Reference to provide a forum through which both parties can collaborate and address areas of interest or concern raised by the MNO about CNSC-regulated facilities and activities within the MNO’s regions and traditional territories. As the MNO is a province-wide organization, a specific engagement plan under the Terms of Reference was also signed in December 2019 with MNO Region 7, which is the consultation committee region that includes the Bruce site, in order to address their areas of interest.

Per the engagement plan, in 2019 CNSC staff met with MNO Region 7 representatives to discuss topics such as the CNSC’s IEMP; the Douglas Point decommissioning licence application; and Bruce Power’s Fisheries Act authorization, mitigation measures study and major component replacement project.

As discussed at the Commission hearing for Bruce Power’s licence renewal in 2018, MNO Region 7 would like to be more involved in environmental monitoring activities around the Bruce site. In the fall of 2019, MNO Region 7 participated as observers in the CNSC’s IEMP sampling campaign around the Bruce site, to learn more about the program. MNO Region 7 and the CNSC made a commitment to continue collaborating on future campaigns through identification of samples of interest and/or sample collection.

In addition, MNO Region 7 had been conducting surveys of their citizens in the Bruce area. One survey result showed that a number of their citizens had concerns about perceived environmental impacts related to the Bruce site. In response, CNSC staff collaborated with the MNO to share the results of environmental monitoring and information on the different risks posed by radiation and the way these risks are managed, and to answer any questions from MNO citizens. CNSC staff will continue to collaborate and engage with MNO Region 7 in areas of interest regarding the Bruce site.

Saugeen Ojibway Nation (SON)

Terms of Reference were signed on May 21, 2019, between the SON and CNSC staff, which document the CNSC’s commitment to formalize engagement and collaboration with the SON communities, as directed by the Commission in the Bruce Power licence renewal record of decision. Under the Terms of Reference, the SON and the CNSC collaborate on a number of areas including:

• joint review and analysis of licensee submissions, particularly around environmental protection
• participation in the CNSC’s IEMP
• inclusion in the design and review of Bruce Power’s study of available mitigation measures for environmental impacts
• SON community outreach
• sharing of the results of the CNSC’s environmental oversight, such as inspection reports
• identification of federal, provincial and municipal decision-making agencies, as needed
• coordination of meetings with federal and provincial Crown agencies, as needed

A work plan was developed that sets out detailed tasks and timelines for each of these items.

CNSC staff understood that the SON continued to have concerns about the environmental impacts resulting from the nuclear activities at the Bruce site, which the SON presented in their intervention at the Commission hearing on Bruce Power’s licence renewal, on March 14, 2018. The focus of the work plan activities is to ensure SON oversight and inclusion, and a means to obtain additional information that will provide clarity, transparency and assurances for the communities and the SON leadership regarding the interactions between the Bruce site and the environment.

In 2019, CNSC staff and the SON continued to meet and work collaboratively to complete a number of the agreed-upon initiatives in the work plan. These activities included the CNSC’s funding support for a study on traditional land use and occupancy, in order to obtain a baseline inventory of mapped cultural sites in relation to the SON’s territory, including the territory around the Bruce Power site. The study should be completed by the SON in 2020.

The activities also expanded the 2019 IEMP sampling program around the Bruce site to include areas within and around the SON communities and involvement of SON members in the sampling, such as the procurement of fish species of interest from SON community members, as well as the SON’s involvement in Bruce Power’s environmental monitoring programs.

Throughout 2019, both Bruce Power and OPG met and shared information with interested Indigenous communities and organizations, including the SON, MNO and HSM.

For Bruce Power, information and discussion topics included its operations at the Bruce site, its Fisheries Act authorization application, inclusion in the development of the mitigation measure study as well as information on environmental impacts, such as impacts to fish. Bruce Power continued to engage the SON, MNO and HSM on the Fisheries Act authorization, so that it could adequately address their information requests and concerns raised throughout the process in the final application that was submitted to Fisheries and Oceans Canada in November 2019.

The SON completed the first year of the Coastal Waters Monitoring Program (CWMP), which is an initiative funded in cooperation with Bruce Power, but designed, led and implemented by the SON to monitor environmental conditions in the nearshore areas of the Saugeen Peninsula. CNSC staff are also interested in the results of the CWMP, as the data can be used in future environmental risk assessments in relation to the Bruce site.

In 2019, OPG continued its regular updates and meetings with Indigenous groups who have an interest in its operations and projects at the Bruce site including the WWMF and the proposed Deep Geologic Repository (DGR). In 2019, OPG actively engaged with SON community members on the DGR project, both on and off reserve, to ensure that community members were able to get all of the information they needed to determine if the SON communities were supportive of moving forward with the project, or not, on their territory.

UPDATE: In January 2020, the SON held a community vote on OPG’s proposed DGR project, and a vast majority of the SON community members voted to not support the project. As a result, the OPG, respecting its commitment to the SON to not go forward with the project without their support, has indicated that it will no longer pursue the proposed DGR project at the Bruce site.

##### Point Lepreau site
###### CNSC staff engagement activities

The Point Lepreau site lies within the traditional territory of 9 Mi’gmaq communities of New Brunswick represented by Mi’gmawe’l Tplu’taqnn (MTI), 6 Maliseet communities of New Brunswick represented by the Wolastoqey Nation of New Brunswick (WNNB) and the Peskotomuhkati Nation, as well as the Sipekne’katik First Nation, which is situated in Nova Scotia. CNSC staff regularly engages and communicates with the interested First Nations and their representative organizations on areas of interest to them.

In 2019, a major focus of the CNSC’s engagement activities was to formalize the relationship between the interested First Nations and CNSC staff. CNSC staff provided information and updates to MTI, WNNB and Peskotomuhkati leadership and met with them individually to discuss topics of interest, including the CNSC’s Independent Environmental Monitoring Program, compliance verification activities at the Point Lepreau site, NB Power’s application for a Fisheries Act authorization, the CNSC’s independent laboratory in Ottawa, potential construction of small modular reactors in Canada, as well as ongoing engagement relationships. In June 2019, MTI and WNNB representatives also participated in a tour of the CNSC’s laboratory. CNSC staff made a commitment to continue meeting with these First Nations in order to provide key updates on nuclear activities and projects in their territory of interest.

In 2019, NB Power worked with several First Nation communities and organizations, including the WNNB, MTI, the Peskotomuhkati Nation, Sipekne’katik First Nation, the Union of New Brunswick Indians and Mawiw Council. Information and discussion topics included NB Power’s operations at the Point Lepreau site, its application for a Fisheries Act authorization, waste management, environmental monitoring, environmental and regulatory approval processes, education, cultural awareness and sensitivity.

NB Power also implemented a number of activities to support Indigenous knowledge and establish more awareness and sensitivity among NB Power workers. The efforts involve members of New Brunswick Indigenous communities leading medicine walks and participating in regular activities at the site. Activities include collaborative environmental and safety monitoring, as well as the delivery of presentations to Indigenous leadership. Point Lepreau leadership and personnel learned from the Indigenous involvement and integrated some of those lessons into its approach to station management, particularly with respect to environmental management. As well, NB Power worked with Indigenous groups to build capacity within their communities to better understand and self-direct learning on nuclear technology and its use in New Brunswick, waste management and new opportunities in nuclear development, and NB Power’s role in a clean electricity mix. NB Power also attended several open houses in Mi’gmaq communities.

##### Gentilly-2 site
###### CNSC staff engagement activities

The Gentilly-2 site lies within the traditional territory of the Abénakis of Wôlinak and Odanak, represented by the Grand Conseil de la Nation Waban-Aki (GCNWA) as well as the Nation huronne-wendat. CNSC staff continued to keep interested First Nations informed throughout 2019 about the Regulatory Oversight Report for Canadian Nuclear Power Generating Sites: 2018 [2], which the GCNWA participated in reviewing.

Throughout 2019, Hydro-Québec continued its commitment to engage and communicate with Indigenous groups with an interest in its operations and sites, and met and shared information with interested First Nation communities and organizations, particularly the GCNWA. As part of their engagement activities, Abenaki representatives have expressed to Hydro-Québec that a point of land located at the eastern portion of the Gentilly-2 property may have potential for Indigenous archaeology. In November 2019, representatives of the GCNWA had access to the outdoor site of the Gentilly-2 Facilities for possible archaeological excavations. The representatives considered the first visit to the field to be productive and it was agreed that both parties would follow up on the request to carry out archaeological surveys during 2020, near the Gentilly River. Hydro-Québec continued to engage the Abenaki representatives regarding their interest in these lands – in particular their archaeological potential.

#### Nuclear liability insurance

The Nuclear Liability and Compensation Act (NLCA) requires nuclear installations (nuclear facilities that have the potential to undergo a nuclear criticality event) to carry nuclear liability insurance. The NLCA is administered by Natural Resources Canada (NRCan). CNSC staff confirmed with NRCan that the licensees complied with the financial security obligations of the NLCA as of June 1, 2019.

#### Financial guarantees

CNSC staff reviewed the annual reports for licensee’s financial guarantees. CNSC staff were able to confirm that in 2019 the financial guarantee cost estimates were still valid and that the licensees had sufficient funds to meet decommissioning liabilities. Note: Bruce Power’s financial guarantee is covered under OPG’s financial guarantee.

OPG’s financial guarantee was valued at $18.992 billion in 2019, which exceeded the required value of$17.133 billion. As of March 2017, the value of the financial guarantee for Point Lepreau was $689.7 million, which exceeded the required value of$567.8 million.

To cover its obligations, Hydro-Québec holds a trust fund and an irrevocable commitment from the Government of Quebec.

UPDATE: In March 2020, Hydro-Québec submitted its updated financial guarantee to the CNSC. The trust fund was valued at $158 million as of December 31, 2019; the commitment from the Government of Quebec amounted to$685 million. The total exceeded the required financial guarantee value of \$776 million.

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

### 3.1 Darlington Nuclear Generating Station

#### 3.1.0 Introduction

The DNGS is located on the north shore of Lake Ontario in Clarington, Ontario, 5 kilometres outside the town of Bowmanville and 10 kilometres southeast of Oshawa. The CNSC regulates the DNGS and Tritium Removal Facility (TRF) under a power reactor operating licence (PROL). The DNGS consists of 4 CANDU reactors that are rated at 881 MWe (megawatts electrical) each.

OPG developed a plan to refurbish the 4 reactors. The refurbishment of Unit 2 began in October 2016 and continued throughout 2019. In November 2017, OPG began operating the Retube Waste Processing Building in time for the processing of the removed reactor components from Unit 2 (fuel channel 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 in stainless steel containers as titanium tritide within a concrete vault.

##### Licensing

In December 2015, the Commission renewed the PROL for the DNGS for a period of close to 10 years; the PROL also covers the TRF and expires on November 30, 2025.

On July 18, 2019, the Commission issued its record of decision [8] that approved OPG’s request [4] to revise the DNGS Integrated Implementation Plan (IIP), in which OPG laid out the steps and timetable for the safety improvements associated with the refurbishment. In addition, on November 5, 2019, a CNSC staff member authorized by the Commission approved the removal of Regulatory Hold Point 1, allowing OPG to load fresh fuel in the refurbished Unit 2 reactor.

UPDATE: CNSC staff removed the other regulatory hold points associated with the restart of Unit 2 during the first half of 2020.

##### Licence conditions handbook

CNSC staff revised the DNGS licence conditions handbook (LCH) on December 20, 2019.

##### Fisheries Act authorization

On June 24, 2015, Fisheries and Oceans Canada issued a Fisheries Act authorization to OPG for the DNGS. The authorization contains a condition for OPG to report to the staff of of both Fisheries and Oceans Canada and the CNSC on the offset plan (compensation for residual harm to fish and fish habitats). In 2019, OPG submitted the reports.

##### Refurbishment

CNSC staff actively monitored and conducted compliance verification inspections of the project to refurbish DNGS Unit 2, which started its refurbishment outage on October 14, 2016. The project had 4 phases:

1. Lead-in – preparation activities such as defuelling and dewatering the reactor
2. Component removal – removal of key components, in particular pressure tubes, end fittings, calandria tubes and feeder pipes
3. Installation – installation of reactor components and the associated testing / quality control verifications to demonstrate fitness-for-service
4. Lead-out – transition from the end of the installation phase to full-power operation

By the end of 2019, OPG was completing the installation phase of the project. Following the removal of Regulatory Hold Point 1, OPG began loading fresh fuel into the Darlington Unit 2 reactor core in November 2019.

CNSC staff focused their regulatory oversight on regulatory deliverables in the IIP. They also focused efforts on verification activities associated with the completion of prerequisites for removal of regulatory hold points in the return to service of Unit 2. In addition, CNSC staff conducted compliance verification activities, as established in the Darlington Refurbishment Project Type II Compliance Plan for Unit 2.

The IIP was progressing according to schedule, with OPG planning and completing 127 IIP tasks with IIP commitment due dates in 2019 [RIB 20544]. Table 11 summarizes the overall and 2019 IIP tasks that were planned, completed, under review and closed. At the end of 2019, CNSC staff were reviewing 37 of the completed 127 IIP tasks and had closed the other 90 IIP tasks tied to 2019.

Table 11: Status of the IIP at the DNGS (based on planned dates)
Total commitments Overall 2019
Planned by the licensee 625 a 127
Completed by the licensee 369 127 b
Under review by the CNSC 59 37
Closed 310 90
1. This number was 627, but 2 IIP tasks were eliminated per the 2019 record of decision [4].
2. Of these 127 IIP items, 79 were actually completed prior to 2019 and the remaining 48 were completed in 2019.

CNSC staff were satisfied with the progress on the IIP in 2019.

Of the 625 IIP items, there were 93 items specifically associated with Unit 2 refurbishment.

UPDATE: From 2016 through to 2020, OPG completed all 93 IIP items required for the return-to-service of Unit 2. CNSC staff reviewed and closed those items as prerequisites for the removal of additional regulatory hold points related to the return to service of Unit 2. As of May 2020, CNSC staff had closed 324 IIP items.

##### Safety improvement opportunities

As part of its 2012 environmental assessment for the refurbishment project, OPG had made a commitment to address several safety improvement opportunities (SIOs). These commitments were later incorporated into the IIP to consolidate all the implementation activities. The SIOs involved features to improve safety of the plant for beyond-design-basis accidents. All but 2 SIOs had previously been addressed, as described in the regulatory oversight report for 2018. One of the remaining SIOs involves modifications to shield tank over-pressure (STOP) protection. Those modifications were completed for Units 1, 3 and 4 before 2018. As planned, OPG completed the modification for Unit 2 in 2019 before restarting the unit in accordance with the IIP schedule. The other remaining SIO concerned the provision of makeup water to the heat transport system using emergency service water and diesel-driven, fire-water pumps.

However, OPG’s request to the Commission in early 2019 to allow a revision to the IIP involved changes to the means by which the SIO associated with the emergency service water system would be implemented. Based on the Commission’s decision [8], the SIO will rely on emergency mitigating equipment and on existing Group 2 equipment and components to provide makeup water, as opposed to new diesel driven, fire-water pumps as originally proposed.

UPDATE: OPG completed the required work to address the remaining SIO and declared the modification available for service in Unit 2 in March 2020. OPG plans to make similar modifications in the other units during their respective refurbishment outages.

##### Event initial reports

No event initial reports pertaining to the DNGS were submitted to the Commission for the period covering January 1, 2019 to June 1, 2020.

##### Compliance program

The compliance program included numerous activities in 2019 to confirm OPG’s compliance with the licensing basis for the DNGS. Appendix B lists the publications that provided compliance verification criteria for those activities for the DNGS.

Table 12 lists the inspections at the DNGS that CNSC staff considered in their safety assessments in this regulatory oversight report. (Inspection reports were included if they were sent to OPG by January 31, 2020, with the exception of DRPD-2019-04955.)

Table 12: List of inspections at the DNGS
Safety and control area Inspection title Inspection report sent date
Management system

Records Management Program

Report number: DRPD-2019-01695

Aug 6, 2019

Unit 3 Refurbishment Supply Chain Management

Report number: DRPD-2019-03585

Jan 6, 2020
Human performance management

Conduct of Simulator-Based Initial Certification Examinations

Report number: DRPD-2019-01450

Mar 26, 2019

Human Performance Program

Report number: DRPD-2019-01883

Apr 3, 2019

Fleet Wide Desktop Inspection of the Leadership and Management Training Program

Report number: DRPD-2019-02877

Jun 11, 2019

Evaluation of Refurbishment Training Programs

Report number: DRPD-2019-03468

Oct 2, 2019

Health Physics Training Program (desktop inspection)

Report number: DRPD-2019-03409

Dec 12, 2019
Operating performance

Quarterly Field Inspection Third Quarter FY 2018/19

Report number: DRPD-2018-01823

Mar 15, 2019

Quarterly Field Inspection Fourth Quarter FY 2018/19

Report number: DRPD-2019-00275

Jun 3, 2019

D1941 Outage

Report number: DRPD-2019-00277

Jun 26, 2019

Quarterly Field Inspection First Quarter FY 2019/20

Report number: DRPD-2019-03925

Oct 9, 2019

Refurbishment Field Inspection Report First Quarter FY 2019/20

Report number: DRPD-2019-04614

Oct 24, 2019

Quarterly Field Inspection Second Quarter FY 2019/20

Report number: DRPD-2019-04082

Sep 23, 2019

Problem and Event Cause and Resolution Effectiveness and Trend Analysis

Report number: DRPD-2019-03434

Jan 13, 2020

Quarterly Field Inspection Third Quarter FY 2019/20

Report number: DRPD-2019-04955

Feb 21, 2020*
Physical design

Darlington Refurbishment – Commissioning of SSC to Verify Technical Specifications

Report number: DRPD-2019-01158

Mar 1, 2019

Commissioning of SSC to Verify Technical Specifications – RHP1

Report number: DRPD-2019-03936

Dec 10, 2019
Fitness for service

SSC Monitoring

Report number: DRPD-2019-02479

Apr 29, 2019

Emergency Power Supply Systems and Associated Fuel Management System

Report number: DRPD-2019-00952

May 23, 2019

Darlington NGS Instrument Calibration

Report number: DRPD-2019-02122

May 29, 2019

Darlington Unit 2 Refurbishment Foreign Material Exclusion

Report number: DRPD-2019-04074

Sep 23, 2019

Inter-Unit Feedwater Tie – System Inspection

Report number: DRPD-2019-02705

Oct 23, 2019

Darlington NGS Maintenance Planning and Scheduling

Report number: DRPD-2019-04520

Oct 24, 2019

Radiation Protection Program Implementation During Reconstruction of Unit 2 Reactor

Report number: DRPD-2019-01276

Apr 30, 2019

RP2 Worker Dose Control – Dosimetry

Report number: DRPD-2019-FIR-04344

Nov 12, 2019

Application of ALARA

Report number: DRPD-2019-03206

Dec 12, 2019
Security

Site Security – Response Arrangements

Report number: DRPD-2018-FIR-01555

Mar 8, 2019

Nuclear security reactive inspection

Report number: DRPD-2019-03861

Jun 28, 2019

Nuclear security reactive inspection

Report number: DRPD-2019-04445

Sep 10, 2019

Site Security

Report number: DRPD-2019-04308

Jan 29, 2020

* Accepted after the January 31, 2020, deadline.

In addition to the inspections listed, CNSC staff considered various other sources of information in their assessment of the safety and control areas (SCAs). They rated all SCAs at the DNGS as “satisfactory” in 2019. Although CNSC staff did identify various examples of excellent safety performance and instances of meeting and/or exceeding regulatory requirements in 2019, they did not assign “fully satisfactory” ratings at the SCA level. (This contrasts with the regulatory oversight report for 2018, where the DNGS received multiple “fully satisfactory” ratings.) This was strictly because of a lack of opportunity (due to the COVID-19 pandemic) for CNSC staff to assure the consistent application of criteria for “fully satisfactory” ratings across all SCAs – it does not reflect, in itself, a decline in safety at the DNGS in 2019.

#### 3.1.1 Management system

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the management system SCA at the DNGS in 2019.

##### Management system

In 2019, CNSC staff conducted over 25 inspections to verify compliance of the management system with the applicable requirements and found the results acceptable. For example, CNSC staff noted that OPG complied with the applicable regulatory requirements for the following [DNGS DRPD-2019-01883]:

• clearly defining and communicating roles and responsibilities for the human performance program in the organizational structure
• controlling the preparation and distribution of documents

CNSC staff found several non-compliances of low and negligible safety significance in work-control documents related to radiation protection [DRPD-2019-03206] and nuclear security [DRPD-2019-04308]. At the end of 2019, CNSC staff were satisfied with the progress OPG had made on the implementation of corrective actions.

In 2019, CNSC staff were satisfied that the corrective actions taken by OPG had addressed the concerns about the completeness of implementing programs and interfaces in OPG’s nuclear management system [2]. CNSC staff reviewed OPG’s revised nuclear management system, which was submitted in late 2019, and confirmed its compliance with the applicable regulatory requirements. CNSC staff planned to review the implementation of the revised nuclear management system and its implementing programs in 2020 or 2021.

In 2019, CNSC staff noted multiple compliant findings regarding the roles and responsibilities of DNGS personnel, including those involved in instrument calibration [DRPD-2019-02122] and nuclear refurbishment training [DRPD-2019-03468].

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

CNSC staff also identified multiple compliant findings in 2019 related to OPG’s measures for performance assessment, improvement and management review. For example, CNSC staff noted satisfactory self-assessments by OPG related to execution of work during the Unit 4 outage [DRPD-2019-00277] and hours of work [DRPD‑2019‑04082]. There were also 2 findings of low safety significance on the same topic. One of them showed that OPG had inadequate corrective action to address performance gaps and weaknesses identified by a self-assessment of emergency power supply systems and an associated self-assessment of the fuel management system [DRPD-2019-00952]. OPG made a commitment to revise the self-assessment and to ensure proper documentation of actions to correct adverse conditions. At the end of 2019, CNSC staff were continuing to monitor OPG’s progress to correct these deficiencies. Secondly, they noted that OPG had failed to conduct periodic self-assessments of the ALARA process. [DRPD-2019-03206]. OPG made a commitment to complete a self-assessment of the radiation protection program, including the ALARA process. CNSC staff continued to monitor OPG’s corrective action and expected the self-assessment to be completed in late 2020.

##### Change management

CNSC staff found that OPG met the applicable regulatory requirements in the change management specific area, based on multiple findings in 2019 that demonstrated OPG’s effective implementation of the engineering change control program at the DNGS.

##### Safety culture

The most recent safety culture self-assessment at the DNGS was in 2018. OPG presented the results to the CNSC during a meeting in July 2019. Through observations at the site, CNSC staff were satisfied that OPG continued to foster a healthy safety culture in 2019.

#### 3.1.2 Human performance management

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the human performance management SCA at the DNGS in 2019.

##### Human performance program

CNSC inspections identified 16 compliant findings in 2019 directly applicable to the human performance program at the DNGS.

##### Personnel training

The DNGS had a well-documented and robust training system in 2019 based on a systematic approach to training (SAT), as indicated by 29 compliant findings that CNSC staff documented in various compliance verification activities. CNSC staff also identified 4 non-compliant findings of negligible safety significance and three 3 findings of low safety significance. None of the findings with low safety significance represented, individually or collectively, a significant deficiency with respect to personnel training at the DNGS.

##### Personnel certification

In 2019, the CNSC developed and conducted 5 certification examinations for responsible health physicists (4 initial certification examinations and 1 renewal of certification). All candidates passed the examinations and were certified by the CNSC. CNSC staff also confirmed that OPG was compliant with its program documentation during an inspection of simulator-based initial certification examinations [DRPD-2019-01450].

##### Fitness for duty

There was 1 violation of the minimum shift complement (MSC) at the DNGS in 2019. A nuclear operator for Unit 0 failed to register himself out of the electronic system and left the station without conducting a face-to-face turnover with a qualified relief worker. This resulted in an inaccurate count of Unit 0 operators between the day and evening shifts, and a 43-minute MSC violation. OPG subsequently called in a relief worker to fulfill the necessary duties in the emergency response organization.

OPG reported 4 hours-of-work violations for certified personnel at the DNGS in 2019. In 3 instances, an authorized nuclear operator (ANO) exceeded the limit of 60 hours per week. In the other instance, an ANO had only 24 hours off (not the required 48 hours) between 3 day shifts and the next night shift. However, none of these violations, either individually or collectively, represented a significant deficiency with respect to OPG’s fitness-for-duty program at the DNGS.

CNSC staff continued to monitor and assess OPG’s implementation of REGDOC-2.2.4, Fitness for Duty: Managing Worker Fatigue, and planned to conduct compliance verification activities in 2020.

#### 3.1.3 Operating performance

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the operating performance SCA management at the DNGS in 2019.

In 2019, CNSC staff identified 41 compliant findings from compliance verification activities related to the operating performance SCA, as well as 4 non-compliances of low safety significance. One of the non‑compliances was for not ensuring that all combustible materials safety (CMS) non-compliances identified outside of routine OPG inspection (“TAP”) reports were evaluated as adverse conditions [DRPD-2019-03434]. A second non-compliance was related to the conduct of brake‑holding tests of the fuel-handling bridges that were necessary due to degraded equipment conditions [DRPD-2019-04082]. These 2 non-compliances were assessed as low risk because they did not pose a significant concern for plant safety.

##### Procedures

The other 2 non-compliances of low safety significance were related to OPG procedures. In 1 field inspection, CNSC staff observed that OPG failed to consistently adhere to procedures. An inspection of problem and event cause and of resolution effectiveness and trend analysis identified the second non-compliance. The issues revolved around the verification of instructions in an OPG procedure to ensure they were current and correct. OPG’s corrective action plan for these 2 non-compliances was in progress at the end of 2019.

##### Reporting and trending

In 2019, OPG submitted all scheduled quarterly and annual reports as required and within the appropriate timelines. Although there was an instance in which a reportable event was not reported on time, OPG’s follow-up activities met CNSC staff’s expectations.

##### Safe operating envelope

In 2019, CNSC staff conducted several compliance verification activities regarding the safe operating envelope for the DNGS. CNSC staff noted a few minor discrepancies; however, they determined that the findings were administrative in nature and would not negatively impact the safe operating envelope limits and conditions.

##### Severe accident management and recovery

As part of regulatory oversight of IIP items related to severe accident management and recovery, CNSC staff reviewed the OPG completion declaration form and the inspection results for dampers in the containment atmosphere cooling system. OPG had conducted intrusive inspections to determine the components in the reactor vault and fuelling duct dampers that were failing and their associated failure modes. Following OPG’s clarification of the assessment results, CNSC staff agreed with OPG’s assessment and recommended that an internal follow-up review be conducted in 5 years to confirm the effectiveness of OPG’s trending of damper failures and corrective action to reduce the number of failures.

#### 3.1.4 Safety analysis

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safety analysis SCA at the DNGS in 2019.

##### Deterministic safety analysis

OPG continued to carry out safety analyses in 2019 as part of its staged implementation of CNSC REGDOC-2.4.1, Deterministic Safety Analysis. CNSC staff reviewed OPG’s revised implementation plan for REGDOC-2.4.1. OPG provided responses to CNSC staff’s recommendations and comments on the analysis plans for the loss of flow and loss of reactor power regulation scenarios. CNSC staff reviewed the responses and concluded that OPG had adequately dispositioned the remaining issues. CNSC staff were satisfied with OPG’s progress on the implementation of REGDOC-2.4.1 at the end of 2019.

In 2018, OPG had submitted a revised analysis for the large-break loss-of-coolant accident (LBLOCA) that employed a more realistic implementation of the very conservative limit of envelope methodology. The analysis was intended to demonstrate that a sufficient safety analysis margin exists for the limiting break size. CNSC staff reviewed the LBLOCA analysis and concluded that more quantification and confirmatory work was needed – specifically related to computer code validation and uncertainties analysis – to support the analysis.

In 2019, OPG submitted an analysis of neutron overpower (NOP) that reflected the impact of aging of the heat transport system of DNGS Units 1, 3 and 4 up until the anticipated aged configuration. CNSC staff were reviewing the submission at the end of 2019.

UPDATE: In April 2020, CNSC staff provided OPG with findings and recommendations related to the technical adequacy of the methodology, codes and the assumptions used for the NOP analysis.

In 2019, CNSC staff also reviewed OPG’s limited-scope LBLOCA analysis to support the return to service of DNGS Unit 2. They informed OPG of their expectation for a full scope analysis to support the return to service of all future refurbished DNGS units.

##### Probabilistic safety assessment

As part of its implementation of CNSC REGDOC-2.4.2, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants, OPG had submitted several new or revised PSA methodologies (including those for at-power and outage states (both Level 1 and Level 2), screening analyses for both internal and external hazards (which included a source identification and screening guide), seismic and high wind). CNSC staff finished their review and accepted the methodologies in 2019.

CNSC staff completed their review of the updated hazard screening analysis as part of the 2020 PSA update. The analysis systematically screened internal and external hazards (including potential combinations of external hazards) on reactor and non-reactor sources (irradiated fuel bay and used-fuel dry storage). CNSC staff determined that OPG’s submission complied with REGDOC-2.4.2.

OPG took initiatives to lead international effort and break new ground in the PSA area by developing new methodologies to address the new REGDOC-2.4.2 requirements. For example, OPG developed new and revised methodologies to address the new requirements for consideration of non-reactor sources and operational states. OPG also continued to actively participate in CANDU Owners Group projects for the development of new methodologies to address REGDOC-2.4.2 requirements.

##### Severe accident analysis

In 2019, CNSC staff completed their review of OPG’s severe accident analysis to support the operation of the new emergency heat sink pipeline during in-core loss-of-coolant accidents. CNSC staff were, in general, satisfied with the quality of the analysis and provided recommendations for improvements to OPG.

#### 3.1.5 Physical design

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the physical design SCA at the DNGS in 2019.

##### Design governance

CNSC staff’s review of the annual, third-party facility condition assessment, along with various field inspections, confirmed that OPG met the applicable regulatory requirements for plant condition inspections related to fire protection at the DNGS. The review of the third-party report also identified recommendations to further align DNGS operations with the applicable regulatory requirements for fire protection. CNSC staff considered OPG’s action plan to address the recommendations in the report acceptable.

During field inspections of seismic qualification in 2019, CNSC staff concluded that the seismic integrity of seismically qualified areas and routes were maintained in accordance with the facility design. However, during one of the field inspections, CNSC staff observed that OPG had failed to adequately maintain clearance between a scaffold tube and a seismically qualified component in accordance with the applicable requirements. OPG’s response to this non-compliance was acceptable to CNSC staff.

##### System design

In 2019, CNSC staff conducted a commissioning inspection of structures, systems and components to verify technical specifications prior to the release of Regulatory Hold Point 1 (loading of new fuel into Unit 2) [DRPD-2019-03936]. The inspection verified compliance with regulatory requirements for the commissioning of the containment filtered venting system and the systems for continued monitoring during beyond-design-basis events. However, CNSC staff observed some minor non-compliances related to the quality, accuracy and completeness of the commissioning reports.

UPDATE: In March 2020, OPG provided an update on its corrective action plan to address the above non-compliances, which CNSC staff found acceptable. OPG was expected to implement the corrective action plan by the end of 2020.

##### Component design

CNSC staff conducted several compliance verification activities in 2019 related to component design. Their IIP reviews related to cables confirmed that OPG had a mature surveillance program for cable condition monitoring, surveillance and aging management at the DNGS. CNSC staff also reviewed the annual fuel monitoring and inspection report and noted that the DNGS continued to experience low defect rates and decreasing trends in observed fuel bundle wear. CNSC staff concluded that OPG operated within the design and operating limits, including iodine limits and power limits for both individual fuel bundles and fuel channels. OPG effectively managed fuel performance issues while maintaining safe operations at the DNGS in 2019.

#### 3.1.6 Fitness for service

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the fitness for service SCA at the DNGS in 2019.

##### Equipment fitness for service / equipment performance

CNSC inspections of equipment fitness for service in 2019 identified 3 compliant findings. However, 1 non-compliance of negligible safety significance and 1 non-compliance of low safety significance were observed. The first non-compliance was related to the approval process for the reports related to commissioning. CNSC staff were satisfied with the prompt response from OPG. The second non-compliance was related to the failure to perform routine field walkdowns as required. The licensee subsequently took corrective actions to comply with the field walkdown requirements.

CNSC staff reviewed the annual risk and reliability report for 2018 for the DNGS and confirmed that OPG had met all the applicable regulatory requirements. CNSC staff also confirmed that all special safety systems for DNGS Units 1, 3 and 4 met their unavailability targets in 2019.

##### Maintenance

CNSC staff conducted several inspections in 2019 related to maintenance. These activities identified 23 compliant findings, 4 non-compliances of negligible safety significance and 5 non-compliances of low safety significance. The non-compliances were related to calibration deficiencies, justification of maintenance deferrals, deficiencies in system walkdowns, and foreign material exclusion during maintenance activities. CNSC staff were satisfied with OPG’s response to the non-compliances identified.

The critical corrective maintenance backlog and the number of critical preventive maintenance deferrals were kept at a very low level in 2019. The critical deficient maintenance backlog was reduced and was better than the industry average. The preventive maintenance completion ratio improved to 96% in 2019. There were no safety-significant findings in the maintenance area related to events. Table 13 shows the trends of the corrective critical maintenance backlog, deficient critical maintenance backlog, and the number of deferrals of preventive maintenance critical components.

Table 13: Trend of maintenance backlogs and deferrals for critical components for DNGS, 2017 to 2019
Parameter Average quarterly work orders per unit Three-year trending Quarterly 2019 work orders Industry average for 2019
2017 2018 2019 Q1 Q2 Q3 Q4
Corrective maintenance backlog 1 0 1 Steady 1 0 0 1 1
Deficient maintenance backlog 37 11 5 Down 8 7 3 3 9
Deferrals of preventive maintenance 7 0 2 Down 3 2 1 0 2
##### Chemistry control

The information from technical reviews and quarterly and annual reports related to chemistry control exceeded CNSC staff’s expectations. OPG resolved any minor non‑compliances promptly and there were no chemistry-related incidents in 2019. The safety performance indicators “chemistry index” and “chemistry compliance index” were close to 100%, with only a few parameters in the low 90s.

##### Periodic inspections and testing

In 2019, OPG continued to transition its periodic inspection program plans from compliance with the 2005 edition of CSA N285.4, Periodic Inspection of CANDU Nuclear Power Plant Components, towards full compliance with the 2014 edition. In 2019, CNSC staff accepted the revised DNGS plans as compliant with the 2014 edition of N285.4.

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the radiation protection SCA at the DNGS in 2019.

##### Application of ALARA

In 2019, CNSC staff inspected the application of ALARA at the DNGS [DRPD-2019-03206] and identified 7 compliant findings. During the inspection, OPG demonstrated a significant number of tools that were used to probe, analyze and understand radiation protection performance. For Unit 2, OPG’s total collective radiation exposure (CRE) was 5,179 p-mSv, which exceeded its target of 4,300 p-mSv. OPG attributed the target exceedance to the additional time to complete the installation of fuel channels and upper and lower feeders.

CNSC staff continued to meet quarterly with OPG to exchange information throughout 2019. The information received during these meetings, in addition to that gathered during the inspection of the application of ALARA and the outage inspection of Unit 4 [DRPD‑2019-00277], demonstrated to CNSC staff that OPG continued to implement several initiatives to maintain worker dose ALARA. For example, OPG had implemented improved shielding capabilities in high dose rate areas, in addition to improving existing shielding on installed equipment.

CNSC staff noted that OPG did meet its collective internal dose target for its planned outage activities; however, OPG exceeded the CRE covering outage activities. OPG reported that its outage CRE was 1,920 p-mSv compared to its established target of 1,790 p-mSv. Post-outage reviews attributed this target exceedance to several factors; some of them were within OPG’s control, including:

• higher than anticipated dose rates
• additional work due to the discovery of unplanned hotspots
• post-execution decontamination of transport flasks

Overall, CNSC staff found sufficient evidence that OPG was making considerable effort to maintain worker doses ALARA and using several tools to allow for improved monitoring and control of those doses. The operating station was within 3% of its year-end CRE and, although OPG exceeded the year-end CRE for Unit 2, the factors that contributed to the exceedance were well understood. CNSC staff noted that failure to achieve a target is not an adverse condition, since targets are established in advance of work without knowledge of the actual conditions that will be encountered or the challenges that may ensue during the work. Furthermore, there was sufficient evidence to demonstrate that OPG continued to make progress on longer-term improvements to lower working radiation fields across the station. CNSC staff continued to monitor OPG’s implementation of these initiatives, but noted that due to the nature of these improvements, the benefits will take time to materialize.

CNSC staff concluded that OPG’s performance exceeded CNSC staff’s expectation with respect to the application of ALARA.

##### Worker dose control

CNSC staff identified 5 non-compliances that were relevant to worker dose control. These non-compliances were associated with the following:

• improper selection and use of radiation personal protective equipment
• inadequate protection of a contractor work group
• a failure to provide workers with accurate radiological hazard information before they started their work
• inadequate contamination control during the work

Individually, these non-compliances were found to be of low safety significance. However, considering them as a whole, CNSC staff determined that OPG had failed to ensure compliance with its procedures, and noted that such a failure poses an avoidable increase in risk to workers if left uncorrected.

UPDATE: In February 2020, CNSC staff completed their review of OPG’s corrective actions for each of these non-compliances and were satisfied with OPG’s response. They continued to monitor OPG’s implementation of the corrective measures in 2020.

Furthermore, while reviewing an event report, CNSC staff identified that some workers in the DNGS fuel-handling group had been placed on an incorrect bioassay schedule. CNSC staff followed up with a field inspection [DRPD-2019-FIR-04344] and found that 69 workers in the fuel-handling group had been similarly placed on an incorrect bioassay schedule, and that this problem had persisted since 2011. The inspection did not identify any worker who was likely to have received an exposure of regulatory concern. However, the compounding factors led CNSC staff to determine that OPG had failed to ensure compliance with its radiation protection program. The cause of this non-compliance was OPG staff’s use of outdated and unapproved procedures and guidelines, as well as OPG supervisors’ failure to perform adequate oversight that would have identified these errors. CNSC staff agreed with OPG’s corrective action plan and continued to monitor its implementation.

As committed to in its response to the requests pursuant to subsection 12(2) of the General Nuclear Safety and Control Regulations (discussed in the 2018 regulatory oversight report [2]), OPG implemented a confirmatory bioassay monitoring program for alpha nuclides in September 2019. In October 2019, OPG identified, and informed CNSC staff about, 3 workers subject to this program who had received alpha uptakes. CNSC staff analyzed the information provided by OPG and confirmed that the magnitude of each individual’s exposures was well below 1 mSv and thus did not present an exposure of regulatory concern. Additionally, in the last quarter of 2019, OPG collected 33 other samples that did not have detectable alpha-emitting radionuclides. This information demonstrated that OPG had effective methods for monitoring radiological exposures to its workers.

In the 2018 regulatory oversight report [2], CNSC staff had concluded that OPG’s worker dose control exhibited a notable downward trend. Similarly, in 2019, CNSC staff noted that, while no worker had received an unplanned dose of regulatory concern, OPG’s performance in a number of identified areas failed to meet both its program requirements and the CNSC’s regulatory expectations. However, CNSC staff determined that OPG met overall expectations with respect to worker dose control, based on the fact that no worker at the DNGS had exceeded their exposure control level or regulatory dose limits. CNSC staff continued their oversight over OPG’s performance and corrective actions in 2019.

In 2019, CNSC staff identified 10 compliant findings from compliance verification activities specific to radiological hazard control. CNSC staff also identified 3 non‑compliances of negligible safety significance and 4 non-compliances of low safety significance. The following low safety-significant findings were associated with procedural non-compliances:

• inconsistent approach to performing, reviewing and approving radiological surveys [DRPD-2019-01276]
• a failure to provide direct protection to a contractor work group [DRPD-2019-04614]
• a failure to perform contamination surveys to assess changing radiological conditions [DRPD-2019-04614]

In addition, OPG reported 10 events related to radiological hazard control. Of those events, 7 occurred in the operating part of the station and were associated with improper posting and labelling of hazards, inadequate calibration of fixed-area ambient gamma monitors, improper storage of radioactive material, and contamination control. The remaining 3 occurred at Unit 2 and were associated with improper posting and labelling of hazards and inadequate contamination control. CNSC staff noted that, although this number of events was high, no exceedances of either environmental or personnel action levels resulted from inadequate contamination control.

For the 7 non-compliances identified during inspections, and each of the 10 event reports, OPG implemented acceptable remedial and corrective actions. CNSC staff also noted that the operating part of the station was below its year-end target of 130 total personal contamination events (PCE) and that Unit 2 was below its year-end target of 457 PCEs.

In the 2018 regulatory oversight report, CNSC staff had also identified a downward trend in OPG’s radiological hazard control. For 2019, CNSC staff concluded that OPG had implemented measures to reverse this trend and showed clear improvement.

#### 3.1.8 Conventional health and safety

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the conventional health and safety SCA at the DNGS in 2019.

In 2019, CNSC staff noted multiple compliant findings related to conventional health and safety. However, during field inspections, 2 non-compliances of low significance were noted. In one instance, OPG failed to properly inspect and clean fume-hood ventilation systems [DRPD-2019-04082]. In a separate field inspection, OPG did not fully comply with the applicable regulations for protection against exposure to hydrazine [DRPD-2019-00275]. CNSC staff concluded that OPG promptly and adequately addressed the minor non-compliances.

CNSC staff observed that the accident severity rate (ASR) and the industrial safety accident rate (ISAR) for the DNGS were each 0.0 in 2019, as no lost time injuries were reported. The accident frequency (AF) decreased to 0.21 in 2019. CNSC staff found the ASR, ISAR and AF values at the DNGS acceptable. Section 2.8 provides additional ASR, ISAR and AF data.

#### 3.1.9 Environmental protection

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the environmental protection SCA at the DNGS in 2019.

CNSC staff observed that all airborne and waterborne radiological releases from the DNGS remained below the regulatory limits and action levels. Appendix D shows the absolute values for releases and DRLs for the DNGS.

During field inspections, CNSC staff concluded that OPG took all reasonable precautions to protect the environment and the health and safety of persons.

During an effluent monitoring program field inspection, CNSC staff identified a non-compliance with scheduling requirements for annual calibration of measuring equipment [DRPD-2018-01823]. OPG provided a corrective action plan that CNSC staff found acceptable.

Based on the review of 2019 environmental monitoring data, CNSC staff concluded that the public and the environment in the vicinity of the site were protected and that no health impacts were expected to result from the Darlington site operations in 2019.

The reported estimated dose to members of the public from the DNGS for 2019 was at 0.4 μSv. This was a decrease from the estimated dose of 0.8 μSv in 2018, and well below the annual dose limit of 1 mSv (1,000 μSv). See section 2.9 for additional information.

#### 3.1.10 Emergency management and fire protection

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the emergency management and fire protection SCA at the DNGS in 2019.

CNSC staff conducted several field inspections in 2019 regarding nuclear emergency preparedness and, in general, identified compliant findings. However, there were 3 non-compliances of negligible safety significance regarding the use of daily inspection forms and maintenance of equipment. CNSC staff were satisfied with OPG’s response to address the non-compliances.

During a field inspection of fire emergency preparedness and response [DRPD-2019-04082], CNSC staff identified 5 compliant findings, as well as 2 non-compliances of negligible safety significance: fire hoses past their testing dates, as well as a fire brigade member not wearing bunker gear in a warm zone during a station fire drill. CNSC staff were satisfied with OPG’s response to address the non-compliances.

In 2019, OPG reported to the CNSC 3 events related to fire emergency preparedness and response. One event included a fire door incorrectly propped open; in the other incidents, hot work caused a minor ignition. OPG took corrective actions that met CNSC staff’s expectations.

#### 3.1.11 Waste management

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the waste management SCA at the DNGS in 2019.

CNSC field inspections in 2019 confirmed that OPG complied with the applicable regulatory requirements for the collection of radioactive waste and the minimization and segregation of conventional waste.

OPG’s reporting on safety performance indicator “low- and intermediate-level radioactive solid waste generated” and the data for 2019 met CNSC staff’s expectations.

#### 3.1.12 Security

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the security SCA at the DNGS in 2019.

CNSC staff inspected security facilities and equipment in 2019 and identified 5 compliant findings [DRPD-2019-04308]. OPG reported 1 event related to facilities and equipment, but CNSC staff deemed that it had no safety significance. CNSC staff’s review of the quarterly reports for the DNGS revealed only minor non-compliances, and CNSC staff were satisfied with OPG’s corrective actions.

CNSC staff inspected security response arrangements in 2019 and identified only compliant findings [DRPD-2018-FIR-01555].

OPG conducted a force-on-force exercise at the DNGS as part of its performance testing program in 2019. CNSC staff reviewed OPG’s self-assessment report and were satisfied with the corrective measures proposed by OPG. CNSC staff concluded that OPG deployed authorized, suitably equipped and trained nuclear security officers at the DNGS and provided an effective intervention against the design-basis threat.

CNSC staff conducted 2 field inspections and a Type II inspection in 2019 and identified compliant findings related to security practices. Relevant performance information from desktop reviews and quarterly reports also met expectations.

CNSC staff concluded that OPG had fully implemented CSA N290.7-14, Cyber Security for Nuclear Power Plants and Small Reactor Facilities, as of November 2019.

#### 3.1.13 Safeguards and non-proliferation

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safeguards and non-proliferation SCA at the DNGS in 2019.

OPG made a commitment to full implementation of CNSC regulatory document REGDOC-2.13.1, Safeguards and Nuclear Material Accountancy, by March 31, 2021. The CNSC reviewed OPG’s implementation plan and discussed the identified gaps with OPG in February 2019. CNSC staff noted that OPG continued to progress in 2019 towards the full implementation of REGDOC-2.13.1. The CNSC agreed with the implementation plan proposed by OPG.

CNSC staff noted 2 compliant findings for assisting the IAEA inspectors during their inspections. Similarly, CNSC staff noted that OPG assisted the IAEA during its maintenance on safeguard equipment.

OPG submitted the required annual operational program with quarterly updates, as well as the annual update to the Additional Protocol, to the CNSC in a timely manner. CNSC staff reviewed these documents and determined that they met the applicable regulatory requirements and staff’s expectations. In support of Unit 2 restart activities, OPG also submitted a proposed safeguards plan for new fuel load. In consultation with the IAEA, CNSC staff reviewed the plan and found it acceptable.

On October 31, 2019, the overhead lights in the truck bay of the east fuelling facilities auxiliary area (FFAA) blacked out for an unknown duration. This event violated OPG’s operation manual, which requires a minimum of 25% of overhead lighting to be on continuously in areas where IAEA cameras are mounted, such as the south truck bays of the east and west FFAAs. The apparent cause of the event was the inadequate documentation on the impact of loss of lighting panels on IAEA cameras during the breaker and relay maintenance.

#### 3.1.14 Packaging and transport

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the SCA packaging and transport at the DNGS in 2019.

In 2019, CNSC staff conducted a field inspection of packaging and transport at the DNGS [DRPD-2019-04955] and identified only compliant findings.

### 3.2 Darlington Waste Management Facility

#### 3.2.0 Introduction

The DWMF is located on the north shore of Lake Ontario in Clarington, Ontario, 5 kilometres outside the town of Bowmanville and 10 kilometres southeast of Oshawa. It is on the Darlington nuclear site, which also contains the DNGS, discussed in section 3.1. The CNSC regulates the DWMF under a waste facility operating licence (WFOL). At the DWMF, OPG processes and stores dry storage containers (DSCs) containing used nuclear fuel (high-level radioactive waste) generated solely at the DNGS. OPG also manages the intermediate-level radioactive waste generated from the refurbishment of the DNGS. This waste is stored in Darlington storage overpacks (DSOs) at the Retube Waste Storage Building (RWSB) at the DWMF.

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

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

The WFOL for the DWMF authorizes OPG to construct 2 additional DSC storage buildings (Storage Buildings #3 and #4), which would allow for an additional storage capacity of 1,000 DSCs.

##### Licensing

The Commission renewed the WFOL for the DWMF in March 2013, with an expiry date of April 30, 2023. The licence was not amended in 2019.

##### Licence conditions handbook

CNSC staff did not revise the DWMF LCH in 2019. However, OPG implemented several CNSC regulatory documents (new publications or new versions of existing publications) in 2019. Future revisions of the LCH will reflect them as sources of compliance verification criteria for the DWMF.

##### Event initial reports

No event initial reports pertaining to DWMF were submitted to the Commission for the period covering January 1, 2019 to June 1, 2020.

##### Compliance program

The compliance program included numerous activities in 2019 to confirm OPG’s compliance with the licensing basis for the DWMF. Appendix B lists the publications that provided compliance verification criteria for those activities for the DWMF.

Table 14 lists the inspection conducted at the DWMF that CNSC staff considered in their safety assessments in this regulatory oversight report. (Inspection reports were included if they were sent to OPG by January 31, 2020.)

Table 14: List of inspections at the DWMF
Safety and control area Inspection title Inspection report sent date
Emergency management and fire protection Emergency Management – Fire Brigade Drill Report number: OPG-DWMF-2019-01 November 19, 2019

In addition to the inspection listed, CNSC staff considered various other sources of information in their assessment of the safety and control areas (SCAs). Those activities identified numerous examples of compliance with regulatory requirements and excellent safety performance, as well instances of non-compliance and opportunities for improved performance. For 2019, CNSC staff rated all SCAs at the DWMF as “satisfactory.”

#### 3.2.1 Management system

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the management system SCA at the DWMF in 2019.

CNSC staff did not identify findings directly linked to the management system. Based on indirect observations in 2019, reviews of the quarterly and annual operational reports for the DWMF, and findings and observations from inspections prior to 2019, CNSC staff concluded that OPG continued to effectively implement the existing OPG management system framework at the DWMF in 2019.

#### 3.2.2 Human performance management

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the human performance management SCA at the DWMF in 2019.

CNSC staff’s reviews of the quarterly and annual operational reports for the DWMF in 2019 did not identify any issues or concerns related to training or other specific areas under this SCA.

CNSC staff continued to monitor and assess OPG’s implementation of CNSC REGDOC-2.2.4, Fitness for Duty: Managing Worker Fatigue, and planned to perform compliance verification activities in 2020.

#### 3.2.3 Operating performance

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the operating performance SCA at the DWMF in 2019.

OPG processed 59 DSCs at the DWMF in 2019. CNSC staff’s review of OPG’s operational reports did not identify any issues or situations that suggested the licensed activities at the DWMF were unsafe. The reviews also confirmed that OPG’s reporting and trending, and its responses to comments and requests for follow-up information/clarification, met CNSC staff’s expectations.

In 2019, OPG notified CNSC staff of a DSC that had not been processed within a year – a non-compliance with the DWMF safety report. OPG indicated that there were no safety impacts or risks in exceeding the 1-year limit. OPG also executed corrective actions to prevent recurrence. CNSC staff were satisfied with the response.

#### 3.2.4 Safety analysis

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safety analysis SCA at the DWMF in 2019.

In 2019, CNSC staff reviewed OPG’s fire hazard assessments for the DWMF and confirmed that the licensee demonstrated compliance with the applicable regulatory requirements. OPG did not submit any significant updates to the safety analysis report for the DWMF in 2019; the next revision is expected in 2022.

#### 3.2.5 Physical design

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the physical design SCA at the DWMF in 2019.

CNSC staff did not identify any non-compliant findings related to design during their compliance verification activities for the DWMF in 2019.

#### 3.2.6 Fitness for service

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the fitness for service SCA at the DWMF in 2019.

As part of the aging management activities for DSCs, OPG submitted the aging management report for the OPG WMFs. CNSC staff reviewed the submission and found that it complied with OPG’s aging management program.

During their reviews of the quarterly operations reports, CNSC staff did not identify any maintenance-related issues at the DWMF in 2019.

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the radiation protection SCA at the DWMF in 2019.

CNSC staff did not conduct any inspections at the DWMF in 2019 that focused on radiation protection. However, their reviews of quarterly reports submitted by OPG confirmed the following:

• The DWMF achieved its year-end collective dose target.
• OPG did not exceed any action levels for dose to workers. The annual effective doses for all DWMF workers were well below the regulatory limit of 50 mSv.
• OPG did not exceed any action levels for contamination control.
• The perimeter dose rates at the DWMF were within OPG’s targets and consistent with the results of the previous years.

#### 3.2.8 Conventional health and safety

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the conventional health and safety SCA at the DWMF in 2019.

OPG did not report any lost-time accidents at the DWMF or any other events related to conventional health and safety in 2019. Also, CNSC staff’s compliance verification activities did not identify any non-compliant findings relevant to conventional health and safety.

#### 3.2.9 Environmental protection

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the environmental protection SCA at the DWMF in 2019.

CNSC staff reviewed the quarterly reports and databases for the DWMF in 2019 and confirmed that the results met staff’s expectations. CNSC staff also confirmed that there were no exceedances of the derived release limits (DRLs) and no exceedances of environmental action levels.

CNSC staff concluded that DWMF operations did not pose an unacceptable risk to human health and the environment in 2019. OPG planned to submit an updated environmental risk assessment for the DWMF in 2021.

#### 3.2.10 Emergency management and fire protection

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the emergency management and fire protection SCA at the DWMF in 2019.

In 2018, CNSC staff had determined that OPG was not performing an annual fire response drill per the applicable regulatory requirements. This was described in the regulatory oversight report for 2018 [2]. In September 2019, CNSC staff inspected OPG’s fire response drill at the DWMF [OPG-DWMF-2019-01] and identified a finding of medium safety significance. It was an accounting issue during the fire drill, when one DWMF OPG staff member did not go outside to one of the two assembly areas. The worker exited the facility and was accounted for 30 minutes after the fire alarm had sounded. The missing worker was unaware of correct OPG emergency procedures.

CNSC staff requested that OPG provide a list and timeline for corrective actions to address the deficiency, as well as a description of any compensatory measures taken before implementation of the corrective actions.

UPDATE: OPG provided the requested information to CNSC staff in January 2020. CNSC staff were satisfied with OPG’s immediate and long-term corrective actions, specifically the reinforcement of accounting training for all OPG DWMF staff.

#### 3.2.11 Waste management

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the waste management SCA at the DWMF in 2019.

In 2019, CNSC staff reviewed the latest revision of OPG’s decommissioning program and also reviewed OPG’s standard for the management of waste and other environmentally regulated materials. The documents met the applicable regulatory requirements and CNSC staff’s expectations.

#### 3.2.12 Security

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the security SCA at the DWMF in 2019.

CNSC staff did not identify any major non-compliant findings with regard to security at the DWMF in 2019.

CNSC staff confirmed that performance information from quarterly reports and the inspection met their expectations for security. OPG reported minor failures related to security facilities and equipment, which were addressed to the satisfaction of CNSC staff.

#### 3.2.13 Safeguards and non-proliferation

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safeguards and non-proliferation SCA at the DWMF in 2019.

CNSC staff confirmed that OPG submitted its required monthly general ledgers on time, except in one instance (for July 2019). OPG notified CNSC staff that the report was a day late. CNSC staff were satisfied with OPG’s response and determined that there was no significant impact on safeguards implementation.

CNSC staff participated in the 2019 physical inventory verifications and design information verifications by the IAEA. The verifications generated satisfactory results.

OPG submitted the required annual operational program with quarterly updates, as well as the annual update to the Additional Protocol, to the CNSC in a timely manner. CNSC staff determined that these documents met the applicable regulatory requirements and staff’s expectations.

#### 3.2.14 Packaging and transport

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the packaging and transport SCA at the DWMF in 2019.

### 3.3 Pickering Nuclear Generating Station

#### 3.3.0 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 Pickering site consists of the PNGS and the PWMF, both owned and operated by OPG. The CNSC regulates the PNGS and PWMF under 2 separate, independent licences – a power reactor operating licence (PROL) for the PNGS and a waste facility operating licence (WFOL) for the PWMF. Section 3.4 reports on the PWMF.

The PNGS consists of 8 CANDU reactors. Units 1, 2, 3 and 4 (formerly known as PNGS A) went into service starting in 1971. Units 2 and 3 were defuelled 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 (formerly known as PNGS B) continue to operate safely 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 for Units 5–8 has a gross electrical output of 540 MWe.

OPG plans to end commercial operation at the PNGS by December 31, 2024. Following permanent shutdown, each unit will undergo stabilization activities in preparation for an extended phase of safe storage with surveillance. This phase will begin in 2028.

##### Licensing

In 2018, the Commission renewed the PROL for a 10-year period, valid from September 1, 2018 to August 31, 2028. This licence period includes 3 phases of operational activities:

• continued commercial operation until December 31, 2024
• stabilization phase (post-shutdown defuelling and dewatering), which lasts approximately 3 to 4 years
• beginning of safe storage for Units 1 and 4 and Units 5–8
##### Licence conditions handbook

One revision was made to the licence conditions handbook (LCH) in 2019.

##### Fisheries Act authorization

In January 2018, Fisheries and Oceans Canada issued a Fisheries Act authorization to OPG for operations at the PNGS; it is valid until December 2028. Among its provisions is a requirement for OPG to engage Fisheries and Oceans Canada if fish impingement exceeds 3,619 kg (annual average weight of fish) in 2 consecutive years.

In 2018, 5,616 kg of fish were impinged at the PNGS. CNSC staff reviewed OPG’s impingement monitoring report for 2018 and made several recommendations to OPG in October 2019, which included the following:

• promptly engage Fisheries and Oceans Canada to determine potential follow-up requirements
• install the planned mid-water float additions to the fish diversion system (FDS), if feasible, to combat the effects of algae loading (algae intrusion)
• consider further increasing FDS maintenance should its performance continue to be impacted by algae loading
• consider the current science regarding increased algae loading in Lake Ontario and other options to combat its effects
• consider other impingement mitigation measures
• provide updates on installation timelines, locations and effectiveness of mid-water float additions in future fish impingement monitoring reports

Fisheries and Oceans Canada concurred with these recommendations.

In 2019, 15,114 kg of fish were impinged [RIB 16516, item i and item iii (a)]. The increase in fish impingement did not appear to be caused by spills or waterborne releases from PNGS operations. OPG attributed the exceedances to rapid water temperature changes related to lake conditions. OPG asserted that high winds caused the upwelling of colder water from lower depths, resulting in either direct mortality or a significant reduction in swimming performance that prevented the fish from avoiding the cooling water intake. The fish impinged were largely alewife, which are particularly sensitive to sudden temperature changes. In addition, some of the exceedances were likely related to the weighing down of the FDS barrier net during algae loading, allowing fish to pass over the FDS.

OPG engaged Fisheries and Oceans Canada to determine potential follow-up requirements, as required by its Fisheries Act authorization. OPG’s engagement with Indigenous groups on the topic of fish impingement and compliance with its Fisheries Act authorization at the PNGS is described in section 2.15 [RIB 16516, item iii (b)].

UPDATE: In March 2020, OPG submitted an analysis of the impingement exceedances to Fisheries and Oceans Canada and the CNSC. CNSC staff reviewed the report and provided comments and recommendations to Fisheries and Oceans Canada. In April 2020, OPG submitted its impingement monitoring report for 2019. CNSC staff were reviewing it as of June 1, 2020.

Integrated implementation plan (IIP) [RIB 17557, item i]

OPG developed an integrated implementation plan (IIP) for the PNGS that defines resolution actions to address issues identified through the periodic safety review conducted in support of the 2018 licence renewal. Each IIP resolution action is completed through the execution of one or more IIP actions. OPG has established a schedule to manage the completion of the 35 IIP resolution actions and the 63 supporting IIP actions. According to this schedule all actions must be completed by December 31, 2020. Table 15 summarizes the status of the IIP as of December 31, 2019.

Table 15: Status of the IIP at the PNGS
Total commitments Overall 2019
Planned by the licensee 98* 28
Completed by the licensee 78 36
Under review by the CNSC 36 28
Closed by the CNSC 42 8

* Includes 63 IIP actions and 35 IIP resolution actions

In 2019, OPG completed 24 IIP actions (including 3 postponed from 2018 and 4 from 2020) and 12 resolution actions (including 1 from 2020). CNSC staff were satisfied with OPG progress, as only 20 IIP commitments remain for completion in 2020 (10 IIP actions and 10 IIP resolution actions).

Overall, CNSC staff have closed 42 IIP commitments (30 IIP actions and 12 IIP resolution actions) and have 36 IIP commitments under review (23 IIP actions and 13 resolution actions).

OPG did not submit any notification of changes related to the IIP to the CNSC in 2019.

##### Event initial reports

One (classified) event initial report pertaining to the PNGS was submitted to the Commission for the period January 1, 2019 to June 1, 2020.

##### Compliance program

The compliance program included numerous activities in 2019 to confirm OPG’s compliance with the licensing basis for PNGS. Appendix B lists the publications that provided compliance verification criteria for those activities for PNGS.

Table 16 lists the inspections conducted at the PNGS that CNSC staff considered in their safety assessments in this regulatory oversight report. (Inspection reports were included if they were sent to OPG by January 31, 2020, with the exception of PRPD-2019-04793.)

Table 16: List of inspections at the PNGS
Safety and control area Inspection title Inspection report sent date
Management system

Records Management Program – Management of Documents and Records

Report number: PRPD-2019-00606

Aug 6, 2019
Human performance management

Human Performance Program

Report number: PRPD-2019-00607

Apr 3, 2019

Report number: PRPD-2019-02754

Jun 11, 2019

Pickering Units 1 and 4 Conduct of a Reactor Operator Simulator-based Certification Examination

Report number: PRPD-2019-01721

Jun 28, 2019

Review of PNGS Q4 2018 Report on NPP Personnel

Report number: PRPD-2019-03976

Aug 12, 2019

Design, Development and Grading of a Pickering 1–4 Reactor Operator Simulator-Based Certification Examination

Report number: PRPD-2019-01784

Oct 18, 2019

Certified Training Program

Report number: PRPD-2019-03870

Dec 12, 2019
Operating performance

Quarterly Field Inspection Third Quarter FY 2018/19

Report number: PRPD-2018-01509

Mar 14, 2019

P1881 Unit 8 Planned Outage Inspection

Report number: PRPD-2018-00840

Mar 21, 2019

Quarterly Field Inspection Fourth Quarter FY 2018/19

Report number: PRPD-2019-02116

Jun 10, 2019

Quarterly Field Inspection First Quarter FY 2019/20

Report number: PRPD-2019-03480

Sep 20, 2019

Quarterly Field Inspection Second Quarter FY 2019/20

Report number: PRPD-2019-03882

Dec 16, 2019
Fitness for service

P1971 Unit 7 Planned Maintenance Outage

Report number: PRPD-2019-00608

Aug 27, 2019

System Inspection – Auxiliary Boiler Feedwater System

Report number: PRPD-2019-03901

Dec 3, 2019

Report number: PRPD-2019-04793

Feb 12, 2020*
Environmental protection

Effluent Control and Monitoring Program

Report number: PRPD-2019-03373

Nov 21, 2019
Security

Nuclear security reactive inspection

Report number: PRPD-2019-03860

Jun 28, 2019

Nuclear security reactive inspection

Report number: PRPD-2019-04446

Sep 10, 2019

(classified)

Report number: PRPD-2019-FIR -05572

(classified)

Report number: PRPD-2020-FIR-05646

(classified)

Report number: PRPD-2020-FIR-06001

*Accepted after the January 31, 2020 deadline.

In addition to the inspections listed, CNSC staff considered various other sources of information in their assessment of the safety and control areas (SCAs). They rated all SCAs at the PNGS as “satisfactory” in 2019. Although CNSC staff did identify various examples of excellent safety performance, and instances of meeting and/or exceeding regulatory requirements in 2019, they did not assign “fully satisfactory” ratings at the SCA level. (This contrasts with the regulatory oversight report for 2018, where the PNGS received multiple “fully satisfactory” ratings). This was strictly because of a lack of opportunity (due to the COVID-19 pandemic) for staff to assure the consistent application of criteria for “fully satisfactory” ratings across all SCAs – it does not reflect, in itself, a decline in safety at the PNGS in 2019.

#### 3.3.1 Management system

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the management system SCA at the PNGS in 2019.

##### Management system

In 2019, CNSC staff were satisfied that the corrective actions taken by OPG had addressed the concerns about the completeness of implementing programs and interfaces in OPG’s nuclear management system [2]. CNSC staff reviewed OPG’s revised nuclear management system, which was submitted in late 2019, and confirmed its compliance with the applicable regulatory requirements. CNSC staff planned to review the implementation of the revised nuclear management system and its implementing programs in 2020 or 2021.

##### Change management

In 2018, CNSC staff inspected OPG’s event investigation process [2] and found non-compliances related to documentation and change control, event categorization and investigation, and assurance that all causes of events are addressed and independently verified. OPG developed and implemented a corrective action plan in 2019, and all deficiencies were resolved to CNSC staff’s satisfaction by early 2020.

Also in 2018, CNSC staff inspected software maintenance [2]. They focused on change management, maintenance of the integrity of software for instrumentation and control systems important to safety, and assurance that the software will reliably perform its design functions. CNSC staff raised 3 enforcement actions for deficiencies in document control, identification of discrepancies related to firmware, and procedural use and adherence. OPG implemented a corrective action plan in 2019.

UPDATE: OPG resolved all issues to the CNSC’s satisfaction by mid-2020.

##### Safety culture

In 2019, OPG implemented REGDOC-2.1.2, Safety Culture, with the exception of the requirements related to nuclear security culture. OPG has made a commitment to revise its governance to include nuclear security culture by November 26, 2020. OPG conducted its most recent safety culture self-assessment in 2018; OPG planned to conduct its next self-assessment within 5 years of that date.

##### Records management

In 2019, CNSC staff inspected the records management program at the PNGS [PRPD-2019-00606]. CNSC staff concluded that OPG complied with the applicable regulatory requirements and effectively demonstrated that:

• documents and information were being used for the performance of activities
• records were retrievable and were stored and retained in a manner to prevent loss, deterioration or damage

Two enforcement actions were raised to ensure that OPG issued administrative governance documents with approved formats and templates, as well as to ensure that the Pickering quality assurance vaults comply with 2-hour separation fire ratings and that actions are taken to mitigate fire damage to records. OPG developed and implemented a corrective action plan in 2019.

UPDATE: OPG resolved all deficiencies to the satisfaction of CNSC staff by mid‑2020.

##### Management of contractors

In 2019, OPG reported that a vendor’s sub-supplier had modified test results for PNGS bleed condenser tubing that had not yet been installed. The sub-supplier had fraudulently modified chemical analysis results that were obtained from the ingots when the ingots did not meet the vendor’s technical specification. CNSC staff conducted a full investigation to identify causes and corrective actions. Although the technical specifications for the ingots were not met, another sub-supplier independently confirmed that the chemical analysis for each lot of tubing produced from the ingots conformed to the vendor’s requirements. The vendor modified its approved supplier list and initiated a “counterfeit, fraudulent and suspect items” investigation in accordance with its quality assurance program and determined the extent of condition.

OPG conducted its own extent of condition determination and requested that its vendors also determine the extent of condition. No affected products were found. CNSC staff were continuing to monitor OPG’s follow-up actions at the end of 2019.

#### 3.3.2 Human performance management

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the human performance management SCA at the PNGS in 2019.

##### Human performance program

In 2019, CNSC staff inspected the human performance program [PRPD-2019-00607] and concluded that it met the applicable regulatory requirements.

##### Personnel training

In 2019, CNSC staff conducted a desktop inspection of OPG’s leadership and management training program [PRPD-2019-02754] and a Type II inspection of OPG’s certified training program [PRPD-2019-03870]. These activities, combined with other compliance verification activities, identified 25 findings related to personnel training, the vast majority of which were compliant or of negligible safety significance. They supported the conclusion that the PNGS had a well-documented and robust training system based on a systematic approach to training (SAT). CNSC staff were satisfied with OPG’s progress in correcting the minor deviations.

##### Personnel certification

In August 2019, the Commission approved a one-time exemption to section 26.1 of RD-204, Certification of Persons Working at Nuclear Power Plants, which allowed a person to progress through the last training program for control room shift supervisor.

In late 2018, OPG asked CNSC staff to decertify a certified individual. CNSC staff agreed to decertify the individual based on the justification provided and discussions with OPG in 2019. An opportunity to be heard was given to the individual, but none was requested within the prescribed time frame. The decertification did not indicate any deficiencies in the health of the certification program at the PNGS.

CNSC staff’s reviews of PNGS’s quarterly reports on NPP personnel in 2019 confirmed that OPG complied with the applicable certification requirements. General compliance with requirements for certification activities was also noted during a Type II inspection of OPG’s conduct of a simulator-based certification examination for a reactor operator [PRPD-2019-01721] and a field inspection of the retention of records that support initial certifications and their renewals [PRPD-2019-03480]. A desktop inspection of the design, development and grading of simulator-based certification examinations for operators of PNGS Units 1–4 [PRPD-2019-01784] identified 3 non-compliances of low safety significance. For example, CNSC staff found that there was a comprehensive test scenarios did not meet the requirements for clarity and uniqueness in the response of a primary malfunction. CNSC staff issued 3 enforcement actions and continued to monitor OPG’s corrective actions.

##### Fitness for duty

The minimum shift complement at the PNGS met the applicable regulatory requirements in 2019, based on 3 inspections. However, 2 minor minimum shift complement violations were reported in 2019. In both events, the required qualifications for minimum shift complement personnel were not met for brief periods of less than 2 hours each. CNSC staff reviewed both events and were satisfied with the corrective actions taken by OPG.

CNSC staff verified the fitness for duty of workers at the PNGS in 2018 through a field inspection [PRPD-2018-01509]. CNSC staff confirmed that OPG had restorative sleep provisions to support workers in exceptional circumstances related to managing worker fatigue. No violations of limits of hours of work occurred at the PNGS in 2019.

CNSC staff also reviewed OPG’s implementation of REGDOC-2.2.4, Fitness for Duty: Managing Worker Fatigue (which was completed in 2019), and were satisfied with the results.

#### 3.3.3 Operating performance

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the operating performance SCA at the PNGS in 2019.

CNSC staff concluded that OPG met the applicable regulatory requirements for the conduct of licensed activities at the PNGS in 2019, based on 5 Type II inspections. OPG operated PNGS safely and securely in accordance with the regulatory requirements for the conduct of operations, including plant status control, surveillance, infrequently performed operations and independent verification of work.

In 2019, the PNGS experienced 1 manual reactor trip, 0 stepbacks, 3 automatic setbacks and 2 manual setbacks. CNSC staff determined that the trips and setbacks were properly controlled and that power reductions were adequately initiated by the reactor control systems. There were no impacts on reactor safety. CNSC staff verified that OPG personnel followed approved procedures and took appropriate corrective actions for all transients.

##### Outage management performance

CNSC staff concluded that OPG’s management of outages at the PNGS met the applicable regulatory requirements and expectations in 2019 and met the requirements in REGDOC-3.1.1 for the completion of regulatory undertakings. CNSC staff observed that OPG demonstrated satisfactory levels of performance and achievement of objectives during planned outages. In 2019, CNSC staff inspected planned outages for Unit 7 and Unit 8. For example, they confirmed that OPG used an approved reactor guaranteed shutdown state, continuously monitored heat sinks and components, kept equipment in the correct configuration to maintain reactor safety, and operated the main control room in accordance with its operations program. Furthermore, the planned outage inspections noted compliance in the areas of reactivity management, containment envelope and regulatory undertakings, and did not result in any CNSC enforcement actions.

##### Procedures

In 2019, CNSC staff continued to follow up on issues related to procedures including procedure use and adherence that were identified during an inspection in 2018 of an emergency response exercise. For example, CNSC staff directed OPG to ensure that all personnel and equipment surveys were performed at inter-zonal radiation monitoring locations and that OPG personnel provide accurate technical information to stakeholders. CNSC staff were satisfied with OPG’s progress to address these and other remaining issues in 2019. CNSC staff also followed up on issues identified during a 2016 inspection of the electrical distribution system. They closed the enforcement action in 2019 following their review of OPG’s corrective action related to its testing program of the standby and emergency power generators at the PNGS.

CNSC staff inspected software maintenance [2] and found deficiencies related to the control and adequacy of documentation and the need to revise several documents in order to align with OPG governance for procedure use and adherence. CNSC staff were satisfied with OPG’s corrective actions, which were completed in mid-2019.

##### Reporting and trending

CNSC staff noted OPG’s overall compliance with requirements for quarterly and annual scheduled reports as set out by REGDOC-3.1.1, including those related to report timing, content and the completion of regulatory undertakings during outages. OPG also responded to the CNSC’s informal requests for follow-up information/clarification in a timely manner.

OPG submitted reportable events that required a detailed event report in 2019. OPG took action to address CNSC staff concerns about the quality of OPG’s event reports for the PNGS. CNSC site staff noted continual improvements related to event reporting in 2019. For example, there was only one occasion in 2019 when a supplementary information report was necessary (3 were necessary in 2018).

##### Safe operating envelope

In 2019, CNSC staff identified issues of low safety significance related to the safe operating envelope (SOE) program at the PNGS, although the issues did not negatively impact the SOE limits and conditions. For example, there were some delays in the update of SOE program-related documents (such as instrumentation uncertainty calculations). A CNSC field inspection [PRPD-2019-03882] identified some instances, administrative in nature, where the OPG compliance framework was inconsistent with SOE documents for the emergency coolant injection system. OPG addressed the concerns to CNSC staff’s satisfaction prior to the issuance of the inspection report; no enforcement actions were necessary.

##### Severe accident management and recovery

In 2019, CNSC staff completed its review of OPG’s revised definition of requirements and measures to manage beyond-design-basis accidents at the PNGS. CNSC staff confirmed that the revised measures provided an appropriate framework (severe accident management guidelines (SAMGs) and emergency mitigating equipment guidelines (EMEGs)) for identifying appropriate mitigating actions for an event that is, or has the potential to progress to, a severe accident.

#### 3.3.4 Safety analysis

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safety analysis SCA at the PNGS in 2019.

##### Deterministic safety analysis

The PNGS IIP included actions related to safety analyses that account for aging of the heat transport system up to December 31, 2024. Aging of the heat transport system affects reactor trip setpoints that are very important parameters for safe operation; margins associated with setpoints can become smaller as the NPP ages. Therefore, in 2019, OPG submitted an update of the safety analysis models and analyses of loss-of-flow, small-break loss-of-coolant accident and neutron overpower protection to demonstrate that the shutdown system will remain effective. CNSC staff reviewed the submissions and provided comments, which OPG was expected to address by the end of September 2020.

##### Probabilistic safety assessment

CNSC staff determined that OPG’s performance exceeded CNSC expectations for probabilistic safety assessment (PSA) in 2019. OPG submitted full-scope PSA updates for PNGS Units 5–8 and for PNGS Units 1 and 4 in 2017 and 2018, respectively. CNSC staff completed their reviews of the updates in 2018 and 2019, respectively, and concluded that they complied with the applicable regulatory requirements (set out in CNSC regulatory document S-294, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants).

As part of its transition to compliance with REGDOC-2.4.2, also called Probabilistic Safety Assessment (PSA) for Nuclear Power Plants, OPG continued to submit revised PSA methodologies, to meet the requirements of REGDOC-2.4.2. In 2019, OPG submitted the following PSA methodologies: Level 1 and Level 2 PSAs for at-power and outage states, internal and external hazard screening analysis, seismic, and high wind. CNSC staff reviewed and accepted these methodologies. OPG planned to complete the implementation plan for the transition to REGDOC‑2.4.2 at the PNGS by the end of 2020, which included submission of PSA reports to address the additional requirements beyond S-294, such as an irradiated fuel bay risk assessment. Following the full implementation of REGDOC-2.4.2, OPG plans to submit its next full PSA updates for PNGS Units 5–8 by the end of 2022 and for PNGS Units 1–4 by the end of 2023.

CNSC staff were satisfied with OPG’s progress in the development of the whole-site PSA for the PNGS. OPG was actively participating in COG and international projects on whole-site PSA. In 2019, CNSC staff concluded its follow-up review of whole-site PSA for the PNGS, noting that OPG had adequately responded to CNSC comments on the relevant submissions [RIB 17557, item ii].

##### Severe accident analysis

CNSC staff determined that OPG maintained a severe accident analysis program that met or exceeded the applicable regulatory requirements and expectations. OPG continued to support industry R&D in the area of severe accident analysis.

In 2019, OPG developed software to estimate the source term and doses that members of the public could receive in the event of a reactor accident. CNSC staff are reviewing the software and the related methodology to calculate filtered venting flow rate from the reactor vacuum building (if venting is deemed necessary). Specifically, they are assessing the adequacy of assumptions in the calculations and the appropriateness of the input data to ensure that these tools meet the applicable regulatory requirements for safety software quality assurance. They plan to complete their review in 2020.

In 2019, CNSC staff completed their review of the assessment of containment integrity for beyond-design-basis accidents, which had been submitted in 2018. They were satisfied with the assessment and with OPG’s responses to the review comments.

#### 3.3.5 Physical design

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the physical design SCA at the PNGS in 2019.

##### System design

CNSC staff concluded that OPG met the applicable regulatory requirements for system design in 2019 for the PNGS. Overall, the design of the plant and its systems has been stable and underwent only minor changes in 2019.

##### Component design

CNSC staff concluded that OPG met the applicable regulatory requirements for component design in 2019 for the PNGS.

CNSC staff were satisfied with fuel performance at the PNGS in 2019. OPG operated within the applicable design and operating limits, iodine limits and maximum bundle power and channel power limits. The inspection rate met the minimum expectation of 20 bundles per unit per year and, similarly, the defect rate per unit did not exceed the CNSC expectation of 1 defect per unit per year. CNSC staff determined that, overall, OPG adequately managed fuel performance issues while maintaining safe operations at the PNGS in 2019.

#### 3.3.6 Fitness for service

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the fitness for service SCA at the PNGS in 2019.

##### Equipment fitness for service / equipment performance

In 2019, CNSC staff reviewed the annual risk and reliability report for 2018 for the PNGS and noted that the PNGS met all the applicable regulatory requirements. CNSC staff also confirmed that all special safety systems for PNGS Units 1 and 4 and Units 5–8 met their unavailability targets in 2019.

##### Maintenance

The performance of OPG’s maintenance program met CNSC expectations in 2019. In 2019, OPG kept the critical corrective maintenance backlog very low. Also, OPG reduced the critical deficient maintenance backlog to below industry average. The number of critical preventive maintenance deferrals was above industry average but it was trending downward. OPG improved the preventive maintenance completion ratio in 2019 to 98%. CNSC staff did not identify any safety-significant issues related to maintenance associated with events reported for the PNGS in 2019. Table 17 shows the trends of the corrective critical maintenance backlog, deficient critical maintenance backlog, and the number of deferrals of preventive maintenance critical components.

Table 17: Trend of maintenance backlogs and deferrals for critical components for PNGS, 2017 to 2019
Parameter Average quarterly work orders per unit Three-year trending Quarterly 2019 work orders Industry average for 2019
2017 2018 2019 Q1 Q2 Q3 Q4
Corrective maintenance backlog 7 2 1 Down 2 0 0 0 1
Deficient maintenance backlog 104 16 7 Down 17 5 3 4 9
Deferrals of preventive maintenance 81 11 5 Down 9 4 5 2 2

CNSC staff conducted numerous inspections in 2019 that confirmed that OPG’s maintenance program consistently met the applicable regulatory requirements for the PNGS.

##### Aging management

CNSC staff confirmed that the major component lifecycle management plans (LCMPs) at the PNGS continued to meet the applicable regulatory requirements in 2019.

The LCMPs for the PNGS include specific mitigating strategies should fitness-for-service assessments identify degradation mechanisms that would prevent the acceptance criteria from being met until the end of the evaluation period. The scope of OPG’s in-service inspections of major components at the PNGS exceeded the minimum inspection requirements in 2019. Updates to the steam generator LCMP included additional inspections of Units 1 and 4 to support extension of the end of commercial operation to 2024.

In 2019, OPG submitted engineering assessments of degradation mechanisms that spanned the near-term operation and met all applicable CSA Group standard acceptance criteria. CNSC staff continued to monitor the implementation of the fuel channel life management project, a project to further develop the analytical tools necessary to demonstrate pressure tube fitness for service for continued operation.

The PNGS is licensed to operate up to 295,000 effective full-power hours (EFPH) for its pressure tubes. At the end of 2019, the longest-operating pressure tubes had approximately 250,000 EFPH of service. OPG predicted that the pressure tubes would not reach the licensing limit prior to 2024.

Following the 2018 renewal of the PROL in 2018, CNSC staff included several new compliance verification criteria in the LCH related to pressure tube fracture toughness. These criteria involved confirmation of the ongoing use of the current model for fracture toughness, the assessment of the time available until the current model cannot be used, and the development of a new model. In 2018, OPG submitted an uncertainty analysis of the results of the current fracture toughness model. In 2019, CNSC staff reviewed the submission and provided comments to OPG.

OPG also updated CNSC staff on pressure tube burst tests and confirmed the validity of the fracture toughness model for the specific test conditions used. OPG confirmed that no Pickering pressure tube was expected to reach the validity limit for the current model (120 ppm Heq; see appendix C) prior to the end of operation.

OPG also continued to work with industry partners on the development of the technical basis for a new fracture toughness model for pressure tube material. As required by the LCH, in late 2018 OPG submitted its first semi-annual update on industry R&D related to model development.

OPG demonstrated good progress in 2019 towards the implementation of probabilistic fracture protection assessments.

##### Chemistry control

In 2019, CNSC staff inspected the auxiliary boiler feed system [PRPD-2019-03901] and confirmed that OPG’s system chemistry met the applicable regulatory requirements. CNSC staff verified that the chemistry parameters were within specifications 100% of the time. The PNGS remained within its chemistry specifications, as demonstrated by the safety performance indicators “chemistry index” and “chemistry compliance index,” which OPG reported to the CNSC in accordance with REGDOC-3.1.1 (see section 2.6).

In 2018, CNSC staff had accepted OPG’s request to defer the Unit 7 reactor building leakage rate test by 6 months. In 2019, CNSC staff confirmed that OPG had completed the test as required and met all the applicable regulatory requirements [PRPD-2019-00608].

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the radiation protection SCA at the PNGS in 2019.

##### Application of ALARA

OPG improved its management of collective doses (collective radiation exposure (CRE)) to workers in 2019 through station-specific ALARA initiatives that exceeded CNSC staff’s expectations. In 2019, the CRE at the PNGS was 3,102 person-mSv, an average of 517 person-mSv/unit. This was better than OPG’s target of 923 person-mSv/unit.

The largest contributor to CRE at the PNGS was the outage-related work. In 2019, the Unit 5 and Unit 7 outages performed better than outage targets for collective external EPD (electronic personal dosimeter) doses and collective internal doses. Table 18 shows the collective dose actuals and targets for external and internal dose.

Table 18: Collective dose actuals and targets for external and internal dose
Unit outage Collective dose (person-mSv)
External Internal
Actual Target Actual Target
5 1,099 1,200 160 230
7 795 1,045 167 220

OPG also incorporated a number of ALARA initiatives into the outages to improve performance.

##### Worker dose control

CNSC staff determined that OPG exceeded CNSC staff’s expectations for worker dose control at the PNGS in 2019 and noted numerous compliant findings related to worker dose control during inspections. Section 2.7 provides data for doses to workers at the Pickering site. Radiation doses to workers at the PNGS were below the regulatory dose limits, as well as the action levels in OPG’s radiation protection program. CNSC staff did not observe any adverse trends or safety-significant unplanned exposures at the PNGS in 2019. Additionally, there were no event reports related to worker dose control in 2019.

In 2019, OPG addressed, to the satisfaction of CNSC staff, the outstanding actions related to fixed-area gamma monitoring and the Type I semi-portable alarming gamma monitoring system.

CNSC staff conducted various Type II inspections in 2019. They identified 13 findings through these inspections and confirmed that OPG met the applicable regulatory requirements at the PNGS for radiological hazard control. No enforcement actions were raised.

#### 3.3.8 Conventional health and safety

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the conventional health and safety SCA at the PNGS in 2019.

CNSC’s oversight of OPG worker practices and awareness in conventional health and safety included various inspections in 2019. CNSC staff noted compliance with the applicable labour codes (for example, with respect to scaffolding, worker protection (such as barriers and danger signs), and health and safety). For example, they observed good housekeeping and noted that OPG provided personal protective equipment that personnel wore in the field. CNSC staff identified a number of non-compliant findings of low safety significance, but did not deem it necessary to take enforcement action since corrective actions were taken by OPG immediately.

The accident severity rate (ASR) for the PNGS in 2019 was 0.0. This was lower than the 2018 ASR (6.4) and also lower than the industry average, which was 1.5 in 2019. The accident frequency (AF) for the PNGS in 2019 was 0.14. This was lower than the AF for 2018 (0.25) and lower than the industry average of 0.26 in 2019. Although AF is defined to include fatalities, there were no work-related fatalities at the PNGS in 2019. The industrial safety accident rate (ISAR) for the PNGS in 2019 was 0.0 (the WANO target for individual NPPs is 0.5).

#### 3.3.9 Environmental protection

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the environmental protection SCA at the PNGS in 2019.

In 2019, all airborne and waterborne releases were less than the environmental derived release limits (DRLs) for the respective types of releases. OPG’s environmental action levels are approximately 10% of the DRL for the release type. In 2019, a single environmental action level exceedance occurred at the PNGS. The waterborne emissions of gross beta/gamma for November 2019 totalled 1.4 Ci, which exceeded the corresponding OPG action level (0.403 Ci/month).

As a follow-up to the licence renewal for the PNGS, OPG commenced a 2-year thermal plume monitoring study in Lake Ontario in 2019. OPG planned to submit a thermal plume report that covers 2 consecutive years of sampling by March 31, 2021 [RIB 16516, item ii].

The maximum dose to the public from operations at the PNGS, as estimated by OPG, remained low (1.7 μSv, versus the limit of 1,000 μSv (1 mSv)). OPG continued satisfactory progress towards implementation of CSA N288.7-15, Groundwater Protection Programs at Class I Nuclear Facilities and Uranium Mines and Mills, at the PNGS, with a scheduled completion date of December 31, 2020.

Overall, CNSC staff observed that operations at the PNGS did not pose an unacceptable risk to human health and the environment.

#### 3.3.10 Emergency management and fire protection

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the emergency management and fire protection SCA at the PNGS in 2019.

As a result of inspections in 2019 to assess OPG’s conventional and nuclear emergency preparedness, CNSC staff observed a small number of non-compliances of low safety significance in the area of drill conduct, management of combustibles, and maintenance and storage of emergency mitigating equipment (EME). For example, OPG had not ensured that the EME generator fuel levels were maintained above OPG’s requirement of 75% capacity. OPG subsequently changed its procedure to include checking and filling of the tank following generator tests. Overall, those findings did not affect the operational readiness of the equipment in the event of an emergency.

In 2019, CNSC staff reviewed the fire hazard assessment and fire safe shutdown analysis for the PNGS and confirmed that they met the applicable regulatory requirements. OPG provided acceptable responses to CNSC staff’s review comments on the fire hazard assessment.

OPG’s new program for combustible material safety increased accountability, education and simplification with respect to fire safety and led to significant improvement in the control of combustibles within the PNGS.

#### 3.3.11 Waste management

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the waste management SCA at the PNGS in 2019.

CNSC inspections in 2019 confirmed that OPG complied with the applicable regulatory requirements for the management of low- and intermediate-level radioactive waste and the minimization and segregation of conventional waste. CNSC staff were also satisfied with the values of the safety performance indicator “low- and intermediate-level radioactive solid waste generated,” for the PNGS in 2019.

#### 3.3.12 Security

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the security SCA at the PNGS in 2019.

CNSC staff conducted a field inspection in 2019 that identified 2 minor non-compliances related to security facilities and equipment [PRPD-2019-FIR-05572]. At the end of 2019, OPG made a commitment to address the findings.

CNSC staff also conducted a field inspection in 2019 that identified a minor non-compliance related to response arrangements [PRPD-2020-FIR-05646]. OPG addressed the non-compliance to the satisfaction of CNSC staff.

Three other field inspections identified non-compliances of negligible safety significance related to security practices. At the end of 2019, OPG was working to address the findings.

#### 3.3.13 Safeguards and non-proliferation

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safeguards and non-proliferation SCA at the PNGS in 2019.

Pursuant to the Canada/IAEA safeguards agreements and the facilities’ licence conditions, OPG granted adequate access and assistance to the IAEA for safeguards activities, including inspections and the maintenance of equipment at the PNGS. See section 2.13 for additional details and a description of the verification activities conducted.

In 2019, the CNSC, OPG and IAEA continued to work to resolve an issue related to nuclear material accountancy and control. This issue was first raised during a physical inventory verification (PIV) in November 2016, when IAEA inspectors found that some of the spent fuel in the irradiated fuel bays could not be adequately verified because of accessibility issues. By the end of 2019, CNSC staff were satisfied with OPG’s corrective actions and were continuing discussions on the resolution of the issue with the IAEA. While the IAEA acknowledged OPG’s and the CNSC’s efforts and the progress on improving accessibility of nuclear material, a small number of stacks of irradiated fuel bundles in 2 out of the 3 bays remained inaccessible for verification to the PIV standard. The IAEA’s annual statement on the conclusions of inspections for the PNGS may continue to reflect the inaccessibility of this fuel until the material in question is verified.

UPDATE: The issue was closed in 2020 when the IAEA applied safeguards seals to ensure the remaining inaccessible material in question remained frozen until it is available for verification in the future (for example, during decommissioning activities).

CNSC staff conducted field inspections at the PNGS during the November PIV [PRPD-2018-01509] and during the short-notice random inspection in April 2019 [PRPD-2019-03480]. CNSC staff concluded that OPG complied with its own standard for ensuring that access and assistance was provided to the IAEA. CNSC staff conducted a field inspection of the November PIV and concluded that OPG complied with the same standard for implementing measures to ensure that safeguards equipment seals remain intact.

#### 3.3.14 Packaging and transport

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the packaging and transport SCA at the PNGS in 2019.

CNSC staff confirmed that the transport of nuclear substances to and from the PNGS was conducted safely in 2019. For onsite movements of nuclear substances, OPG ensured an equivalent level of safety as required for offsite transportation to protect the health and safety of workers, the public and the environment.

CNSC staff conducted a field inspection of packaging and transport in 2019 and did not identify any non-compliances [PRPD-2019-02116].

### 3.4 Pickering Waste Management Facility

#### 3.4.0 Introduction

The PWMF is located on the north shore of Lake Ontario in Pickering, Ontario, 32 kilometres northeast of Toronto and 21 kilometres southwest of Oshawa. It is on the Pickering nuclear site, which also contains the PNGS, discussed in section 3.3. The CNSC regulates the PWMF under a waste facility operating licence (WFOL). At the PWMF, OPG processes and stores dry storage containers (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 the PNGS Units 1–4 in 34 above‑ground dry storage modules (DSMs) located at the Retube Component Storage Area (RCSA) at the PWMF. With the exception of periodic inspection, monitoring, and maintenance of DSMs and the RCSA, there have been no operational activities for RCSA since 1993.

The PWMF spans 2 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 the DSC Processing Building, 2 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 currently has the capacity to store 1,154 DSCs. Loaded DSCs from PWMF Phase I to PWMF Phase II are transferred on OPG property with a security escort.

Under the WFOL for the PWMF, OPG is authorized to construct 3 additional DSC storage buildings in Phase II (Storage Buildings #4, #5 and #6) and 1 DSC processing building to replace the current DSC Processing Building. The additional storage buildings would allow OPG to store all of the used fuel generated at the PNGS to the end of its commercial operational life, and the new DSC processing building would increase OPG’s processing capabilities at the PWMF from 50 DSCs per year to approximately 100 DSCs per year.

##### Licensing

In February 2018, the Commission renewed the WFOL, which is valid from April 1, 2018 to August 31, 2028.

##### Licence conditions handbook

CNSC staff issued an LCH for the PWMF in June 2018 in conjunction with its WFOL renewal. CNSC staff did not revise the PWMF LCH in 2019. However, OPG implemented several CNSC regulatory documents (new publications or new versions of existing publications) in 2019. Future revisions of the LCH will reflect them as sources of compliance verification criteria for the PWMF.

##### Event initial reports

No event initial reports pertaining to the PWMF were submitted to the Commission for the period covering January 1, 2019 to June 1, 2020.

##### Compliance program

The compliance program included numerous activities in 2019 to confirm OPG’s compliance with the licensing basis for the PWMF. Appendix B lists the publications that provided compliance verification criteria for those activities for the PWMF.

Table 19 lists the inspections conducted at the PWMF that CNSC staff considered in their safety assessments in this regulatory oversight report. (Inspection reports were included if they were sent to OPG by January 31, 2020.)

Table 19: List of inspections at the PWMF
Safety and control area Inspection title Inspection report sent date
Human performance management

Compliance Inspection

Report number: OPG-PWMF-2019-03&04

Nov 6, 2019
Operating performance

Type II Compliance Inspection

Report number: OPG-PWMF-2019-01

Jun 6, 2019

Compliance Inspection

Report number: OPG-PWMF-2019-03&04

Nov 6, 2019
Emergency management and fire protection

Compliance Inspection

Report number: OPG-PWMF-2019-02

Nov 6, 2019

In addition to the inspections listed, CNSC staff considered various other sources of information in their assessment of the safety and control areas (SCAs). Those activities identified numerous examples of compliance with regulatory requirements and excellent safety performance, as well instances of non-compliance and opportunities for improved performance. For 2019, CNSC staff rated all SCAs at the PWMF as “satisfactory.”

#### 3.4.1 Management system

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the management system SCA at the PWMF in 2019.

CNSC inspections confirmed the overall compliance and effectiveness of OPG’s management system framework at the PWMF in 2019 [OPG-PWMF-2019-03&04]. For example, CNSC staff confirmed that OPG met the applicable requirements to:

• document its human performance program and apply the graded approach
• define responsibilities and roles in the organizational structure
• provide the necessary resources to the organization
• continually improve, and apply operational experience into planning and execution of, its programs (in this case, the human performance program)
• identify, document and resolve adverse conditions
• maintain records
• control documents
• appropriately label DSCs
• maintain training records

In terms of business continuity, onsite CNSC staff’s observations in 2019 confirmed that the PWMF had adequate contingency plans to maintain or restore critical safety and business functions in the event of disabling circumstances, such as a pandemic, severe weather, or labour actions.

#### 3.4.2 Human performance management

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the human performance management SCA at the PWMF in 2019.

CNSC inspections in 2019 confirmed that the PWMF complied with the applicable regulatory requirements for its human performance program [OPG-PWMF-2019-03&04]. However, CNSC staff found that OPG did not comply with its place-keeping requirements for procedures in work plan document. At the end of 2019, OPG was working on corrective actions to ensure that its personnel adhere to the place-keeping requirements.

UPDATE: In 2020, OPG completed the corrective actions and CNSC staff found them acceptable.

The same inspection also identified 3 compliant findings relevant to personnel training. In addition, CNSC staff reviewed the quarterly and annual 2019 operational reports for the PWMF in 2019, as well as OPG’s notification package for the construction of Storage Building #4 (SB4), and did not identify any issues or concerns related to training.

CNSC staff continued to monitor and assess OPG’s implementation of CNSC REGDOC-2.2.4, Fitness for Duty: Managing Worker Fatigue, and planned to perform compliance verification activities in 2020.

#### 3.4.3 Operating performance

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the operating performance SCA at the PWMF in 2019,

OPG processed 60 DSCs at the PWMF in 2019. CNSC staff’s reviews of OPG’s operational reports did not identify any issues or situations that suggested that licensed activities at the PWMF were unsafe. The reviews also confirmed that OPG’s reporting and trending, and its responses to comments and requests for follow-up information/clarification, met CNSC staff’s expectations.

CNSC staff’s compliance verification activities identified 6 compliant findings related to reporting and trending, and no non-compliances.

#### 3.4.4 Safety analysis

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safety analysis SCA at the PWMF in 2019.

In 2018, CNSC staff reviewed OPG’s update of the PWMF safety analysis report [2]. As of 2019, some outstanding items still remained that required further review by CNSC staff. For example, CNSC staff identified issues with the heat decay model used to model the used fuel in the DSCs.

UPDATE: In June 2020, OPG submitted a revised safety report, which included changes to the heat decay model. CNSC staff found the submission acceptable.

#### 3.4.5 Physical design

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the physical design SCA at the PWMF in 2019.

In 2019, OPG submitted its construction notification package for SB4. CNSC staff reviewed the package and found that it met their expectations for site characterization design.

#### 3.4.6 Fitness for service

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the fitness for service SCA at the PWMF in 2019.

In 2019, OPG submitted its aging management inspection reports, which documented OPG’s aging management activities for DSCs at all WMFs. CNSC staff reviewed the submission and found that it complied with OPG’s aging management program. CNSC staff noted that follow-up “underside” inspections of the base plates of 2 DSCs were deferred until 2020. They identified no issues with the deferral.

During their reviews of the quarterly operations reports, CNSC staff did not identify any maintenance issues at the PWMF in 2019.

CNSC staff concluded that OPG met the applicable regulatory requirements, and its performance met CNSC staff’s expectations, for the radiation protection SCA at the PWMF in 2019.

CNSC staff’s review of the construction notification package for Storage Building #4 included comments related to radiation protection. Examples include questions around changes to the dose rates for workers through the addition of Storage Building #4. OPG addressed the comments in a timely manner.

CNSC staff’s reviews of quarterly reports submitted by OPG confirmed that:

• the PWMF achieved its year-end collective dose target
• OPG did not exceed any action levels for contamination control
• the perimeter dose rates at the PWMF were within OPG’s targets
• the results for loose contamination were consistent with the results of previous years
• OPG did not exceed any action levels for dose to workers; the annual effective doses for all PWMF workers were well below the regulatory limit of 50 mSv

CNSC staff conducted a Type II inspection in 2019 and identified 2 compliant findings related to radiation protection [OPG-PWMF-2019-01]. They noted that their measurements of radiation fields were consistent with the measurements posted on the radiation signs. Additionally, all portable monitors checked by CNSC staff were in good working condition and calibrated within the required period.

#### 3.4.8 Conventional health and safety

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the conventional health and safety SCA at the PWMF in 2019.

During the Type II inspection in 2019, CNSC staff identified 5 compliant findings related to conventional health and safety [OPG-PWMF-2019-01]. These included the following observations:

• eye wash stations were accessible
• housekeeping was generally acceptable
• OPG staff wore appropriate PPE and dosimeters
• material safety data sheets (MSDS) were available and up to date for the heavy-duty degreaser and the like-acid cleaner
• cabinets containing corrosives had appropriate signage

OPG did not report any lost-time accidents at the PWMF or any other events related to conventional health and safety in 2019.

#### 3.4.9 Environmental protection

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the environmental protection SCA at the PWMF in 2019.

CNSC staff reviewed the quarterly reports and databases for the PWMF in 2019 and confirmed that the results met staff’s expectations. They also confirmed that there were no exceedances of the derived release limits (DRLs) or of environmental action levels. They concluded that the operation of the PWMF did not pose an unacceptable risk to human health and the environment in 2019.

The Type II inspection identified 1 compliant finding related to environmental protection in 2019 [OPG-PWMF-2019-01]. During the inspection, CNSC staff reviewed the environmental gamma monitoring quarterly results for 2017 and 2018 at the Retube Components Storage Facility (RCSF) and Used Fuel Dry Storage Facility (UFDSF) and found them complete.

OPG planned to submit an updated ERA for the Pickering site (including the PWMF) in fiscal year 2022–23.

#### 3.4.10 Emergency management and fire protection

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the emergency management and fire protection SCA at the PWMF in 2019.

In 2018, CNSC staff had determined that OPG was not performing an annual fire response drill per the applicable regulatory requirements [2]. In August 2019, OPG held a fire response drill at the PWMF. CNSC staff inspected the results of this drill in September 2019 [OPG-PWMF-2019-02]. Overall, CNSC staff were satisfied with these results and provided a recommendation to OPG.

OPG notified CNSC staff of a fire system impairment at Storage Building #3 in September 2019 that was due to a card failure in a booster panel. OPG ordered a new card and initiated its fire impairment plan. CNSC staff were satisfied with OPG’s preventive measures and noted that OPG corrected the failure.

#### 3.4.11 Waste management

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the waste management SCA at the PWMF in 2019.

CNSC inspection findings in 2019 confirmed that OPG continued to comply with the applicable regulatory requirements for waste management. During one inspection at the PWMF, CNSC staff observed that DSCs were properly labelled with information that included the DSC number, contents, location and date loaded, date stored, the number of fuel bundles and the radiation trefoil sign [OPG-PWMF-03&04]. CNSC staff observed different colours of waste bins throughout the facility. These bins are to help with identification and segregation of contaminated and non-contaminated waste (contaminated vs. likely clean waste).

In 2019, CNSC staff reviewed the latest revision of OPG’s decommissioning program and also reviewed OPG’s standard for the management of waste and other environmentally regulated materials. The documents met the applicable regulatory requirements and CNSC staff’s expectations.

#### 3.4.12 Security

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the security SCA at the PWMF in 2019.

CNSC staff did not identify any major non-compliant findings with regard to security at the PWMF in 2019. There was 1 security-related event at the PWMF in 2019, and CNSC staff were satisfied with the actions OPG took to address the issue.

CNSC staff confirmed that performance information from desktop reviews, quarterly reports and the field inspection met their expectations.

#### 3.4.13 Safeguards and non-proliferation

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safeguards and non-proliferation SCA at the PWMF in 2019.

CNSC staff confirmed that OPG submitted its required monthly general ledgers on time, except in one instance (the report for July 2019). OPG notified CNSC staff that the report was a day late. CNSC staff were satisfied with OPG’s response and determined that there was no significant impact on safeguards implementation.

CNSC staff participated in the 2019 physical inventory verifications and design information verifications by the IAEA. The verifications generated satisfactory results.

OPG submitted the required annual operational program with quarterly updates, as well as the annual update to the Additional Protocol, to the CNSC in a timely manner. CNSC staff determined that these documents met the applicable regulatory requirements and staff’s expectations.

#### 3.4.14 Packaging and transport

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the packaging and transport SCA at the PWMF in 2019.

### 3.5 Bruce Nuclear Generating Station

#### 3.5.0 Introduction

Bruce A and Bruce B nuclear generating stations are located on the shores of Lake Huron, in the Municipality of Kincardine, Ontario. Bruce Power operates the facilities under a lease agreement with the owner, Ontario Power Generation (OPG). Bruce A has 4 CANDU reactors with a gross power of 831 MWe (megawatts electrical) each (Units 1–4). Bruce B has 4 CANDU reactors with a gross power of 872 MWe each (Units 5–8). All 8 units were operational throughout 2019.

This report groups the 2 stations together because Bruce A and B have 1 power reactor operating licence (PROL) and Bruce Power uses common programs at both stations. However, the performance of each station was assessed separately due to the differences in implementation of some programs at Bruce A and 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 3.6 of this regulatory oversight report.

##### Licensing

The Commission renewed the PROL for Bruce A and B in 2018 for a period of 10 years, valid from October 1, 2018 to September 30, 2028. The 10-year licence period will encompass Bruce Power’s operation, as well as activities related to the major component replacement (MCR) of Units 3 to 8, which started in January 2020. The PROL for Bruce A and B was not amended in 2019.

##### Licence conditions handbook

CNSC staff revised the LCH for Bruce A and B on April 1, 2019.

##### Fisheries Act authorization

In December 2019, Fisheries and Oceans Canada issued a Fisheries Act authorization for the ongoing operation of Bruce A and B. The authorization covers the death of fish through impingement and entrainment due to the water intakes that draw water from Lake Huron for the cooling water systems.

The conditions of the authorization include monitoring and inspections, as well as maintenance of structures (velocity cap/chain rope barrier) to reduce fish impingement. Bruce Power is also required to submit a final impingement and entrainment monitoring plan by March 2023 after engaging with Indigenous groups. The offsetting plan includes the removal of the Truax Dam (Saugeen River, Walkerton), which took place in August 2019 and contribution of funds to Ontario’s Ministry of Natural Resources and Forestry’s lake trout rehabilitation program in Lake Huron.

##### Periodic safety review

Bruce Power conducted a periodic safety review in support of its PROL renewal and the planned refurbishment of Units 3 to 8. Bruce Power also developed and began implementing its integrated implementation plan (IIP), which proposed various safety improvements.

Table 20 summarizes the IIP tasks that were planned, completed, under review and closed, both in 2019 and overall since the beginning of the project. The work in the IIP was progressing according to schedule, with Bruce Power completing 18 IIP tasks in 2019; these included the 10 tasks that were planned for completion in 2019 as well as 8 others that were planned for completion in either 2018 or 2020. At the end of 2019, CNSC staff were reviewing 4 IIP tasks, having closed all of the other IIP tasks that Bruce Power completed in 2019.

Table 20: Status of the IIP at Bruce A and Bruce B (based on planned dates as of the end of 2019)
Planned by the licensee 191 10
Completed by the licensee 40 18
Closed by the CNSC 36 14
Under review by the CNSC as of Dec 2019 4

UPDATE: Bruce Power submitted the annual IIP update for 2019 in March 2020. CNSC staff reviewed the update and confirmed that Bruce Power had made acceptable progress on all IIP items. They also determined that Bruce Power’s revisions to the scope or schedule of 3 IIP items were acceptable (within the licensing basis).

##### Refurbishment (MCR project)

The MCR project involves Units 3 to 8 and includes the replacement of major components such as the steam generators, fuel channels and feeders. The MCR outages started in January 2020 with Unit 6.

CNSC oversight of prerequisite activities for Unit 6 began in January 2019, a year prior to the start of the project. CNSC staff conducted 3 Type II inspections and 2 desktop inspections in 2019 that covered the processes for contractor management and supply chain. CNSC staff did not identify any major issues.

UPDATE: The MCR outage began on January 17, 2020, with preparatory work activities [RIB 14753].

##### Event initial reports

No event initial reports (EIRs) pertaining to Bruce A and B were submitted to the Commission for the period covering January 1, 2019 to June 1, 2020.

##### Compliance program

The compliance program included numerous activities in 2019 to confirm Bruce Power’s compliance with the licensing basis for Bruce A and B. Appendix B lists the publications that provided compliance verification criteria for those activities for Bruce A and B.

Table 21 lists the inspections at Bruce A and B that CNSC staff considered in their safety assessments in this regulatory oversight report. (Inspection reports were included if they were sent to Bruce Power by January 31, 2020).

Table 21: List of inspections at Bruce A and B
Safety and control area Inspection title Inspection report sent date
Management system

Bruce B, MCR inspection – Project and Contractor Management

Report number: BRPD-MCR-2019-1971

Apr 17, 2019

Bruce B, MCR inspection – MCR Supply Management Unit 6

Report number: BRPD-MCR-2019-2098

May 16, 2019

Bruce A and B, Field Inspection – Configuration Management

Report number: BRPD-A-2019-FIR-4174

Aug 23, 2019

Bruce B, Unit 6, MCR Inspection – Engineering Change Control

Report number: BRPD-MCR-2019-04078

Dec 11, 2019

Observation of Safety Culture Monitoring Panel

Report number: BRPD-AB-2019-FIR-05668

Dec 16, 2019
Human performance management

Bruce A, Desktop Inspection – Design, Development and Grading of a Bruce A UO CRO Simulator-based Certification Examination

Report number: BRPD-A-2019-02183

Mar 11, 2019

Bruce A and B, Security Personnel Training Program

Report number: BRPD-AB-2019-0789

May 27, 2019

Bruce A and B, Desktop Inspection – Development and Marking of a Bruce Power Supplementary Station Specific Certification Examination

Report number: BRPD-AB-2019-03077

Oct 9, 2019

Bruce A and B, Bruce Power Authorized Nuclear Operator Training Program

Report number: BRPD-AB-2019-04830

Dec 18, 2019
Operating performance

Bruce A and B, Bruce A and B, Quarterly Field Inspection Report for Quarter 3, FY 2018-2019

Report number: BRPD-AB-2018-1370

Mar 8, 2019

Bruce B Unit 8 Planned Outage

Report number: BRPD-B-2019-1548

Mar 15, 2019

Bruce A and B, Quarterly Field Inspection Report for Quarter 4, FY 2018-2019

Report number: BRPD-AB-2019-2214

Jun 5, 2019

Bruce A Unit 3 2019 Planned Outage

Report number: BRPD-A-2019-02216

Jun, 28, 2019

Bruce B Unit 7 Planned Maintenance Outage

Report number: BRPD-B-2019-02530

Jul 26, 2019

Bruce A and B, Quarterly Field Inspection Report for Quarter 1, FY 2019-2020

Report number: BRPD-AB-2019-03635

Sep 3, 2019

Bruce A and B, Quarterly Field Inspection Report for Quarter 2, FY 2019-2020

Report number: BRPD-AB-2019-03968

Nov 18, 2019

Bruce A and B, Quarterly Field Inspection Report for Quarter 3, FY 2019-2020

Report number: BRPD-AB-2019-05184

Jan 29, 2020

Bruce B Unit 5 Planned Maintenance Outage

Report number: BRPD-B-2019-04429

Jan 29, 2020

Bruce A Unit 2 2019 Planned Outage

Report number: BRPD-A-2019-05312

Jan 31, 2020
Fitness for service

Bruce A, System Inspection – Low Pressure Service Water

Report number: BRPD-A-2019-04073

Sep 9, 2019

Bruce A, System Inspection – Vacuum Building & Emergency Filtered Air Discharge System

Report number: BRPD-A-2019-04423

Oct 1, 2019

Bruce A, System Inspection – Negative Pressure Containment

Report number: BRPD-A-2019-04725

Dec 18, 2019

Bruce A and B, Field Inspection – Structure Systems and Components Monitoring

Report number: BRPD-A-2019-FIR-04292

Sep 24, 2019

Bruce B, MCR Desktop Inspection – Bruce B, Unit 6, DTI-07-01, Radiation Protection Program to Protect Health and Safety of Workers and to Monitor and Control Radiation Hazards (Including Alpha) During Refurbishment

Report number: BRPD-MCR-2019-04984

Nov 6, 2019

Bruce B, MCR Desktop Inspection – Bruce B, Unit 6, DTI-07-02, Radiation Protection Source Term and ALARA Program

Report number: BRPD-MCR-2019-05407

Dec 11, 2019
Environmental protection

Bruce A and B, Effluent Control and Monitoring Inspection

Report number: BRPD-AB-2019-04792

Dec 9, 2019
Emergency management and fire protection

Bruce A and B, Huron Resilience Corporate Drill

Report number: BRPD-AB-2019-03799

Jan 14, 2020
Security

Bruce A and B Field Inspection – Security FI #9 NSO Qualifications

Report number: BRPD-AB-2019-FIR-01933

Mar 5, 2019

Bruce A and B Field Inspection – Security FI #15 NSO Minimum Required Training

Report number: BRPD-AB-2019-FIR-01934

Mar 5, 2019

In addition to the inspections listed, CNSC staff considered various other sources of information in their assessment of the safety and control areas (SCAs). They rated all SCAs at Bruce A and B as “satisfactory” in 2019. Although CNSC staff did identify various examples of excellent safety performance, and instances of meeting and/or exceeding regulatory requirements in 2019, they did not assign “fully satisfactory” ratings at the SCA level. (This contrasts with the regulatory oversight report for 2018, where Bruce A and B received multiple “fully satisfactory” ratings.) This was strictly because of a lack of opportunity (due to the COVID-19 pandemic) for CNSC staff to assure the consistent application of criteria for “fully satisfactory” ratings across all SCAs – it does not reflect, in itself, a decline in safety at Bruce A and B in 2019.

#### 3.5.1 Management system

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the management system SCA at Bruce A and B in 2019.

##### Management system

CNSC staff identified numerous findings from several compliance inspections in 2019 at Bruce A and B that confirmed the overall compliance of Bruce Power’s management system with the applicable regulatory requirements.

##### Organization

CNSC inspections and compliance assessments in 2019 confirmed that Bruce Power had adequately defined organizational structure, roles and responsibilities in its governance. In 2019, Bruce Power adequately addressed CNSC staff’s comments on changes to its organization chart.

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

Based on findings from 3 inspections in 2019, CNSC staff confirmed that Bruce Power continued to meet the applicable regulatory requirements for performance assessment, improvement and management review.

##### Operating experience

In 2019, CNSC staff conducted several inspections that touched on Bruce Power’s OPEX (operating experience) program and confirmed its overall compliance with the applicable regulatory requirements. As an example, CNSC staff noted during an MCR inspection of supply management that Bruce Power appropriately managed the OPEX associated with a CNSC recommendation for Bruce Power to implement good reviewing practices of all MCR suppliers [BRPD-MCR-2019-2098]. The same inspection also identified areas for improvement in the quality of some of the records produced by suppliers. CNSC staff requested that Bruce Power ensure that records issued by the suppliers are reviewed by Bruce Power inspectors to verify the quality of the records.

##### Change control

An MCR inspection of engineering change control in 2019 [BRPD-MCR-2019-04078] identified minor areas for improvement in the documentation of temporary changes related to the MCR. CNSC staff recommended that Bruce Power provide clearer guidance for MCR monitoring. Bruce Power took into consideration CNSC staff recommendations and implemented corrective actions.

In 2019, Bruce Power started to significantly change and simplify its management system documentation. CNSC staff planned to review the changes, including the effectiveness of the change management process, in 2020.

##### Configuration management

In 2019, CNSC staff inspected temporary configuration changes (TCCs) at Bruce A [BRPD-A-2019-FIR-4174]. CNSC staff requested that Bruce Power develop and implement a corrective action plan with target implementation dates to ensure that TCCs are always identified on Bruce Power’s master flow sheets and that the configuration of TCC processes is effective. CNSC staff were satisfied with the corrective actions for Bruce A. In response to CNSC staff’s request, Bruce Power was taking similar corrective actions for Bruce B at the end of 2019.

##### Safety culture

CNSC staff continued to monitor safety culture at Bruce A and B in 2019. Field inspections, which were used to oversee Bruce Power’s activities, confirmed that the licensee met the applicable regulatory requirements related to safety culture. Specifically, CNSC staff conducted a field inspection of Bruce Power’s safety culture monitoring. CNSC staff identified various compliant findings and found no non-compliances.

##### Management of contractors

CNSC staff identified some findings in 2019 related to elements of contractor/supply management processes. For example, an MCR inspection of project and contractor management at Bruce B [BRPD-MCR-2019-1971] identified the need to ensure that contracts are updated, based on the most recent requirements, and that a graded approach is taken to documentation of quality assurance plans and verification plans. CNSC staff were satisfied with the corrective actions Bruce Power took by the end of 2019 to address the issues.

UPDATE: In April 2020, Bruce Power sent additional information to address the issue, which satisfied CNSC staff.

CNSC staff observed that, overall, Bruce Power continued to improve its oversight of contractors in 2019. Issues were resolved as they were identified, with many being resolved before the MCR activities began. In 2020, CNSC staff plan to further review Bruce Power’s management of MCR contractors.

Onsite observations in 2019 confirmed that Bruce Power had adequate contingency plans to maintain or restore critical safety and business functions in the event of disabling circumstances, such as a pandemic, severe weather, or labour actions at Bruce A and B. Onsite staff also observed how these measures also supported the minimum shift complements for Bruce A and B.

#### 3.5.2 Human performance management

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the human performance management SCA at Bruce A and B in 2019.

##### Human performance program

In 2019, Bruce Power continued to develop the initiative “You Can Count on Me. Every Step. Every Time. Every Day” to improve human performance programs at Bruce A and B.

##### Personnel training

CNSC compliance verification activities identified 43 findings relevant to training at Bruce A and B in 2019, many of which were compliant or of negligible safety significance. For example, CNSC staff inspected Bruce Power’s authorized nuclear operator training program for Bruce A and B [BRPD-AB-2019-04830] and identified minor procedural issues of negligible safety significance. CNSC staff were satisfied with Bruce Power’s progress in correcting all minor deviations in 2019.

##### Personnel certification

CNSC staff reviewed the staffing reports for certified personnel, as well as the applications for initial certification and renewal of certification, and confirmed that Bruce Power had a sufficient number of personnel at both Bruce A and B in 2019 for all certified positions.

##### Initial certification examinations and requalification tests

In 2019, CNSC staff performed a desktop inspection of the design, development and grading of a simulator-based certification examination for a control room operator at Bruce A [BRPD-A-2019-02183]. CNSC staff identified a non-compliance with the grading assessment documentation. All of their recommendations from the inspection targeted continuous improvement of the grading of simulator-based certification examinations and marking of written certification examinations. Bruce Power submitted a corrective action plan to address the recommendation, which CNSC staff found satisfactory. CNSC staff also performed a desktop inspection of the development and marking of a supplementary station-specific certification examination for a control room shift supervisor, which identified only compliant findings [BRPD-AB-2019-03077].

##### Fitness for duty

CNSC staff determined, through field inspections and other observations, that Bruce Power met the applicable regulatory requirements for minimum shift complement at Bruce A and B in 2019. In 2019, Bruce A and B promptly reported 1 violation of minimum shift complement. CNSC staff confirmed that the violation had minimal to no impact on safe operation of the stations.

In 2019, Bruce Power had to exceed the hours-of-work (HOW) limits at Bruce A and B for certified staff in order to maintain the minimum shift complement. Bruce A had 6 exceedances of the HOW limit of 16 hours worked in a 24-hour period. Bruce B had 3 exceedances of the 16-hour limit. CNSC staff observed a general decreasing trend in the number of exceedances of this limit during 2019. This was the result of Bruce Power’s improvements to the management of worker fatigue in the second half of the year, including the addition of a tool to send bulk text messages to certified workers when replacements are needed due to illness.

Bruce Power completed the implementation of CNSC REGDOC-2.2.4, Fitness for Duty: Managing Worker Fatigue, in 2019. Bruce Power also made a commitment to fully implement CNSC REGDOC-2.2.4, Fitness for Duty, Volume III: Nuclear Security Officer Medical, Physical and Psychological Fitness, in 2020.

Bruce Power’s implementation of the new regulatory document on managing alcohol and drug use was on hold, pending the development and publication of version 3 of REGDOC-2.2.4, Fitness for Duty, Volume II, Managing Alcohol and Drug Use. Bruce Power planned to implement all REGDOC-2.2.4, Volume II requirements, other than random alcohol and drug testing, 6 months from the publication of version 3. Bruce Power planned to implement random alcohol and drug testing 12 months from the publication of version 3.

#### 3.5.3 Operating performance

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the operating performance SCA at Bruce A and B in 2019.

In 2019, CNSC staff noted that Bruce Power’s operating practices were adequate and, in several cases, were highly effective and carried out with a high regard for safety. Bruce Power achieved a high level of compliance with the applicable operational requirements and adequately addressed operational situations that were identified. For example, all issues identified in CNSC staff’s field inspections were promptly and adequately addressed before CNSC staff issued the quarterly inspection report.

##### Procedures

Various CNSC inspection findings and onsite observations confirmed that Bruce Power complied with the applicable regulatory requirements related to procedural use and adherence, and procedural adequacy.

##### Reporting and trending

CNSC staff determined that Bruce Power complied with the applicable regulatory reporting requirements in 2019. All scheduled reports required by REGDOC-3.1.1 were submitted in a timely manner. The information provided in Bruce Power’s scheduled quarterly reports exceeded CNSC staff’s expectations. Bruce Power submitted 87 event reports in 2019. The CNSC’s onsite monitoring confirmed that Bruce Power reported events in a timely manner. However, there was 1 late submission of an event report at Bruce A about a change of status of certified personnel in 2019. CNSC staff confirmed that Bruce Power promptly addressed the issue. There were also 2 late submissions of event reports at Bruce B. One was about a damaged transportation package and the other about unavailability of the emergency water system. CNSC staff confirmed that Bruce Power promptly addressed the reporting issues.

Bruce Power followed up all reported events and supported the reports with adequate root cause analysis, when appropriate.

##### Outage management performance

In 2019, 2 planned outages took place at Bruce A and 2 took place at Bruce B. Bruce Power submitted all its final outage reports in a timely manner. CNSC inspections of all planned outages confirmed that Bruce Power performed all outage-related undertakings safely. Bruce A and B complied with the applicable requirements for the management of heat sinks and reactor shutdown guarantees. Bruce Power also promptly and adequately addressed CNSC staff recommendations and requests stemming from the inspections.

In 2019, Bruce A experienced 5 forced outages (3 at Unit 2 and 2 at Unit 4). Bruce B experienced 4 forced outages (2 at Unit 5 and 2 at Unit 6). All forced outages were manual and were mainly caused by events related to equipment and affected production rather than safety. Fewer forced outages occurred than in 2018, and CNSC staff observed that Bruce Power followed up all of them appropriately in 2019. There were no process failures at Bruce A or Bruce B in 2019, including during the outages.

##### Safe operating envelope

In 2019, CNSC staff reviewed a sample of Bruce Power’s updated operating safety requirements documents and were satisfied with the progress of SOE implementation at Bruce A and B. SOE documents were found to be more closely aligned with station design, operations and maintenance practices. Bruce Power planned to complete its updates of SOE documents (SOE governing documents, operational safety requirements, instrument uncertainty calculations and compliance table) in 2020.

##### Severe accident management and recovery

In 2019, CNSC staff began a review of Bruce Power’s integrated accident management program. At the end of 2019, CNSC staff were reviewing the severe accident management guidelines (SAMGs) and emergency mitigating equipment guidelines (EMEGs). CNSC staff planned to issue a report of their findings by the end of 2020. They also inspected the Huron Resilience Corporate Drill in 2019 and identified a number of positive observations. They determined that Bruce Power complied with the applicable regulatory requirements for adequacy of procedures [BRPD-AB-2019-03799].

#### 3.5.4 Safety analysis

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safety analysis SCA at Bruce A and B in 2019.

##### Deterministic safety analysis

CNSC staff determined that Bruce Power had a well-managed program for conducting deterministic safety analysis and that the existing deterministic safety analysis remained adequate during the continued implementation of REGDOC-2.4.1, Deterministic Safety Analysis. In the process of REGDOC-2.4.1 implementation, Bruce Power submitted updates of part 1 and part 2 of its safety report for both Bruce A and B in February 2019. CNSC staff determined that the updates met the applicable regulatory requirements; that the safety analyses for both Bruce A and B predicted adequate margins; and that Bruce Power met the CNSC’s acceptance criteria for safe operation.

In 2019, CNSC staff completed their review of Bruce Power’s threshold break-size assessment in support of the composite analytical approach (CAA) for LBLOCAs. CNSC staff found sufficient justification to accept the predicted low frequency for a break size larger than the threshold break size (TBS), which is a critical premise in the assessment. Bruce Power’s work on the CAA, including incorporation of the results of the threshold break-size assessment, was ongoing at the end of 2019. Section 2.4 provides background information on the CAA.

Overall, Bruce Power’s submissions in 2019 related to deterministic safety analysis exceeded CNSC staff’s expectations.

UPDATE: In January 2020, Bruce Power submitted a revised LBLOCA analysis and requested that LBLOCA events above the TBS be reclassified as beyond-design-basis accident events. The January 2020 submission analyzes LBLOCA events above the TBS under more realistic operating conditions.

##### 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 the course of implementing its updated replacement of the same name, REGDOC‑2.4.2, by the end of 2020. Bruce Power completed its PSA submissions in April 2019 for REGDOC-2.4.2 compliance. CNSC staff completed reviews for Bruce Power’s external hazard assessment and external flood assessment, and determined that they complied with REGDOC-2.4.2. CNSC staff plan to review the remaining submissions by the end of 2020. One of these submissions is the update on the internal fire PSA [RIB14761].

UPDATE: As of June 1, 2020, Bruce Power was addressing CNSC staff comments on the internal fire PSA and applying its policy for the treatment of PSA results that range between its safety goals and administrative safety goals. Bruce Power identified the main contributors from the fire PSA to the large-release frequency for Bruce A. The next step according to the policy is to identify proposed mitigation strategies, which would be evaluated per Bruce Power’s process for business risk management.

CNSC staff completed its review of the Bruce whole-site PSA and acknowledged that the submission provided a good characterization of the whole-site risk [RIB 14760]. See section 2.4 for additional discussion. Bruce Power also submitted the aggregated risk values for whole-site PSA for Bruce A and B [RIB 14759]. CNSC staff were continuing to review Bruce Power’s other PSA submission at the end of 2019, including the degree to which it supported the results of the whole-site PSA.

Bruce Power’s work on PSA exceeded CNSC staff’s expectations in 2019 because of the licensee’s proactive approach in addressing REGDOC-2.4.2 requirements, as well as its contributions to advancements in whole-site PSA and site risk aggregation.

##### Criticality safety

With respect to Bruce Power’s criticality safety program, both the booster fuel assemblies and demonstration fuel bundles for low-void reactivity fuel remained in safe storage. There were no events or issues related to criticality safety at Bruce A and B during 2019.

##### Severe accident analysis

In 2019, CNSC staff started reviewing the severe accident analysis for Bruce A and B that supported the PSA.

#### 3.5.5 Physical design

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the physical design SCA at Bruce A and B in 2019.

##### Design governance

In 2019, CNSC inspections confirmed compliance with the applicable requirements for environmental qualification at Bruce A and B, such as those related to maintaining the integrity of environmental qualification barriers.

##### System design

Bruce Power introduced a new safety measure in 2019 by revising its operating principles and policies to include testing of remaining available standby generators, when they are at the minimum allowed availability, to confirm that they are functional and capable of supporting safe operation.

In 2019, CNSC staff reviewed Bruce Power’s revised fire protection assessment reports for Bruce A and B. CNSC staff were satisfied with the results in the reports and with Bruce Power’s responses to review comments. CNSC staff concluded that Bruce Power’s fire protection program met the applicable regulatory requirements.

##### Component design

CNSC staff confirmed that Bruce Power operated its units within the applicable fuel power limits and managed fuel performance satisfactorily in 2019. The frequency of debris fretting at Bruce A remained high in 2019 but did not pose a significant risk to safety. The frequency of endplate cracks at Bruce B increased in 2019 as compared to 2018. CNSC staff noted the developments in Bruce Power’s long-term strategy to resolve this long-standing issue and continued to monitor progress.

#### 3.5.6 Fitness for service

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the fitness for service SCA at Bruce A and B in 2019.

##### Equipment fitness for service / equipment performance

All special safety systems at Bruce A met their unavailability targets in 2019.

For Bruce B, all special safety systems met their unavailability targets in 2019, except for emergency cooling injection (ECI) for Units 5–8. The ECI system for those units exceeded the unavailability target due to 2 separate events. In the first case, it was discovered that the number of aluminum tubes and planks stored in the central service area duct was larger than allowed. In the event of a LOCA, the reaction of aluminum with water at a high pH and temperature can produce aluminum hydroxide precipitate, which has the potential to plug the ECI strainers. Bruce Power declared the ECI to be unavailable when this field condition existed. Bruce Power prevented recurrence by relocating the scaffolding in the 3 affected units and created a training change request to include aluminum hydroxide awareness in certification training for operations. Bruce Power also planned to embed the training change request in the ECI course material.

The second event occurred in September 2019. While inspecting an instrument room, Bruce Power personnel found unsecured equipment that did not comply with the requirements in Bruce Power’s procedure for equipment in seismically qualified areas. Any impingement on the free area for passive ventilation of the instrumentation could impact the environmental qualification of the room that is being protected.

If there had been a seismic event and it had caused a secondary-side line break and caused significant damage to ductwork in the instrument rooms due to unsecured material, it could have impacted the environmental conditions inside the affected rooms and the ability of the equipment in those rooms to perform its intended safety function. Bruce Power declared the ECI unavailable while the condition persisted. CNSC staff concluded that Bruce Power’s response to maintain proper housekeeping in seismically qualified areas was acceptable. Bruce Power removed the unrestrained equipment promptly and initiated corrective actions to improve operational awareness of seismic requirements and reduce the likelihood of recurrence. CNSC staff conducted several field inspections after the preliminary report was released to confirm that the corrective actions were effective.

There was no significant impact on nuclear safety as a result of these instances of unavailability. CNSC staff continued to monitor all of Bruce Power’s corrective actions.

In 2019, Bruce Power implemented a relief-valve testing program to confirm that overpressure protection devices on pressure boundary systems would perform their intended function in the event of operating pressure transients. The number of relief-valve test failures reported for balance-of-plant pressure boundary systems trended downward in 2019.

CNSC staff also inspected the low-pressure service-water system at Bruce A [BRPD-A-2019-04073] and determined that Bruce Power complied with the applicable regulatory requirements for system monitoring.

##### Maintenance

The performance of Bruce Power’s maintenance program met CNSC staff’s expectations in 2019. The preventive maintenance completion ratios were improved to approximately 90% for Bruce A and B. The maintenance backlog results for Bruce A and B were acceptable and are provided in tables 22 and 23, respectively. For Bruce A, Bruce Power reduced its corrective critical maintenance backlogs and reached the range of industry best practices. For Bruce B, Bruce Power continued to reduce its corrective maintenance backlog and also reduced the deficient critical maintenance backlog in 2019.

###### Bruce A
Table 22: Trend of maintenance backlogs and deferrals for critical components for Bruce A, 2017 to 2019
Parameter Average quarterly work orders per unit Three-year trending Quarterly 2019 work orders Industry average for 2019
2017 2018 2019 Q1 Q2 Q3 Q4
Corrective maintenance backlog 3 0 1 Steady 1 0 0 0 1
Deficient maintenance backlog 100 13 10 Down 14 9 8 7 9
Deferrals of preventive maintenance 6 1 0 Down 0 0 0 0 2
###### Bruce B
Table 23: Trend of maintenance backlogs and deferrals for critical components for Bruce B, 2017 to 2019
Parameter Average quarterly work orders per unit Three-year trending Quarterly 2019 work orders Industry average for 2019
2017 2018 2019 Q1 Q2 Q3 Q4
Corrective maintenance backlog 2 0 0 Steady 1 0 0 0 1
Deficient maintenance backlog 127 19 11 Down 21 11 8 4 9
Deferrals of preventive maintenance 7 0 0 Down 0 0 0 0 2

CNSC staff inspected the negative pressure containment system at Bruce A in 2019 [BRPD-A-2019-04725] and confirmed that Bruce Power complied with the applicable regulatory requirements for preventive and corrective maintenance for the system. That inspection, and the inspection of the vacuum building and emergency filtered air discharge system [BRPD-A-2019-04423] at Bruce A, confirmed that Bruce Power complied with the applicable regulatory requirements for surveillance testing for those systems.

##### Periodic inspections and testing

CNSC staff reviewed Bruce Power’s inspection program results, quarterly operations reports, pressure boundary reports, and event reports in 2019 and concluded that structures, systems and components had the required structural integrity at Bruce A and B. In 2019, pressure boundary inspection results indicated that all inspected elements of the primary heat transport and auxiliary systems, steam generators, feeders and pressure tubes were fit for continued operation. Bruce Power evaluated all inspection findings to confirm that structural integrity margins were maintained. CNSC staff determined that appropriate corrective actions (such as repairs or replacement of components) were implemented to restore margins as required.

The results of CNSC staff’s assessments of Bruce Power’s final outage inspection reports and component dispositions confirmed that the pressure tubes at Bruce A and B remained fit for service in 2019.

##### Aging management

In 2019, CNSC staff reviewed Bruce Power’s updated deterministic fracture protection assessment for fuelled and defuelled pressure tubes in Unit 3 (up to a limit of 230,000 EFPH) and Unit 5 (up to a limit of 255,000 EFPH). CNSC staff found that Bruce Power’s updated assessments were acceptable for both units.

Bruce Power had predicted that some pressure tubes will reach the Heq validity limit (associated with key fracture toughness models) of 120 ppm before reaching the licensing limit of 300,000 EFPH of operation [RIB 14757, items i and iii]. Appendix C provides data for all units. Bruce Power made a commitment to submit a technical basis document for a new fracture toughness model in 2020. CNSC staff considered that, in the meantime, the existing regulatory process used to monitor the additional validation of the existing fracture toughness model was adequate and ensured that the pressure tubes would continue to meet the CSA Group’s acceptance criteria.

In 2019, CNSC staff continued to monitor issues related to the assessment of the potential for pressure tube to calandria tube (PT-CT) contact in Bruce B fuel channels. During the Unit 6 and Unit 8 outages, Bruce Power detected a small PT-CT gap in 2 channels – it was lower than the validity limit of the inspection tool. The erosion of margins for PT-CT contact prompted Bruce Power to develop novel approaches to meet fitness-for-service and disposition requirements, which CNSC staff recognized as challenging for small gaps. However, CNSC staff concluded that fuel channels were fit for service at Bruce A and B in 2019 and continued to monitor the PT-CT contact issue.

Bruce Power demonstrated that the integrity of the steam generator tubes and support structures was adequate in 2019 and that no active degradation mechanisms would challenge the integrity of the steam generator and preheater tubes over the requested operating period.

##### Chemistry control

CNSC staff determined that Bruce Power’s chemistry control met the applicable regulatory requirements during the planned outages of Units 2, 3, 5 and 7 in 2019. CNSC staff continued to monitor the low values for the safety performance indicator “chemistry compliance index” in 2019 due to lower moderator isotopic purity. Although low, Bruce Power has taken appropriate actions to maintain the chemistry control parameters within acceptable limits.

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the radiation protection SCA at Bruce A and B in 2019.

##### Application of ALARA

In 2019, CNSC staff confirmed that Bruce A and B implemented ALARA through post-job ALARA reviews, ALARA initiatives and oversight, and the use of engineering controls and specialized tooling to reduce exposures to workers.

Bruce Power achieved its collective dose targets for planned outages in 2019 for Bruce A and B. Similarly, online collective doses were lower than the dose targets for both stations.

In 2019, CNSC staff performed an MCR desktop inspection of the program for radiation protection source term and ALARA at Unit 6 [BRPD-MCR-2019-05407] and concluded that Bruce Power complied with the regulatory requirements for the development, monitoring, trending, assessment and reporting of dose goals and targets to drive continual improvement in performance. CNSC staff also confirmed that Bruce Power had processes to manage all radiological hazards during refurbishment activities in order to optimize occupational exposures.

CNSC staff concluded that Bruce Power’s performance met or exceeded applicable regulatory requirements in its application of ALARA.

##### Worker dose control

In 2019, Bruce Power maintained worker dose ALARA, in particular during the execution of outages. CNSC staff observed there were no adverse trends or safety-significant unplanned exposures at Bruce A and B. CNSC staff also noted that the number of workers in higher dose categories was decreasing. No action level exceedances occurred at Bruce A and B from unplanned exposures, and no exposures resulted in a worker dose over the annual regulatory effective dose limit (50 mSv).

In 2019, CNSC staff performed an MCR desktop inspection [BRPD-MCR-2019-04984] of the radiation protection program to protect health and safety of workers and to monitor and control radiation hazards (including alpha) during refurbishment at Unit 6. CNSC staff concluded that Bruce Power complied with the regulatory requirements for worker dose control (for example, tracking and trending of dose targets to ensure management oversight). CNSC staff also confirmed that Bruce Power had an effective process to control facility layout and the classification of areas with respect to radiation protection.

CNSC staff confirmed that Bruce Power continually measured the performance of its radiation protection program against industry-established objectives, goals and targets. In 2019, Bruce Power’s self-assessments identified improvements to its radiation protection program to protect health and safety of workers and to monitor and control radiation hazards (including alpha) during refurbishment.

CNSC staff determined that Bruce Power implemented effective controls for radiological hazards. There were no action level exceedances for surface contamination or personal contamination control at Bruce A and B in 2019. In addition, the total number of personal contamination events was less than Bruce Power’s target for Bruce A and B.

#### 3.5.8 Conventional health and safety

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the conventional health and safety SCA at Bruce A and B in 2019.

CNSC inspections in 2019 identified numerous compliant findings related to conventional health and safety at Bruce A and B. Additionally, all non-compliances identified were of negligible safety significance and were promptly and adequately addressed. CNSC staff’s onsite surveillance and monitoring also resulted in many positive observations related to awareness and practices associated with conventional health and safety. CNSC staff noted that Bruce Power had appropriate procedures to ensure the protection of workers from hazardous materials and that workers adequately identified workplace hazards in 2019.

In 2019, Bruce Power achieved the milestone of more than 7 million hours without a lost time accident (LTA). The safety performance indicator “accident frequency” for Bruce A and B continued to be low in 2019 (see section 2.8). However, a lost-time injury, resulting in a significant number of lost days, occurred at the fire training facility (not in the main station area) when a worker slipped and fell (at the same level) on ice on a roof. The potential for ice on the roof had been identified in advance and the employee was wearing appropriate footwear. The employee needed 5 months off work to recover. Subsequently, the safety performance indicator “accident severity rate” increased in 2019, but was still comparable to the industry average and data for previous years at Bruce A and B (see section 2.8). CNSC staff concluded that Bruce Power’s pre-work preparations, post-event response and corrective actions to prevent event recurrence were adequate.

#### 3.5.9 Environmental protection

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the environmental protection SCA at Bruce A and B in 2019.

In 2019, radiological releases to the environment from Bruce A and B were well below regulatory limits; Bruce Power did not exceed any DRLs or environmental action levels for airborne and waterborne emissions. Appendix D shows the actual values of the releases and DRLs. Based on the review of the 2019 environmental monitoring data, CNSC staff concluded that Bruce Power’s control, monitoring, analysis and reporting of environmental data and associated processes were consistently implemented and complied with the applicable regulatory requirements.

In 2019, CNSC staff inspected effluent control and monitoring at Bruce A and B [BRPD-AB-2019-04792] and confirmed that Bruce Power complied with the applicable regulatory requirements for effluent and emissions monitoring.

CNSC staff noted that there were no significant releases of hazardous substances at the Bruce site in 2019 that posed an unacceptable risk to the environment or the general public. The estimated maximum annual radiation dose to the public from the Bruce site remained very low, at 0.15% of the public dose limit.

Bruce Power had submitted a revised environmental risk assessment (ERA) in December 2018 and continued to implement CSA N288.6-12, Environmental Risk Assessments at Class I Nuclear Facilities and Uranium Mines and Mills, in 2019. In 2019, staff from both the CNSC and Environment and Climate Change Canada (ECCC) reviewed the revised ERA and concluded that it complied with N288.6-12 and that the majority of CNSC and ECCC comments had been adequately addressed. Bruce Power, the CNSC and ECCC met regularly in 2019 to discuss expectations for additional analysis and uncertainty assessment for the next ERA revision.

#### 3.5.10 Emergency management and fire protection

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the emergency management and fire protection SCA at Bruce A and B in 2019.

In 2019, Bruce Power continued its capital project for radio system replacement, which will enhance radio communication reliability for emergency response team members. The project includes the replacement of all handheld radios and hardware infrastructure (antennas, cabling, repeaters, networking, etc.); refurbishment of the distributed antenna system; and construction of a replacement radio tower and associated equipment. CNSC staff were satisfied with the project’s progress in 2019, which entailed completion of the design and work control packages for the whole site. The next steps planned were to move the necessary equipment onsite and begin construction. Bruce Power was on track to finish the project in 2022.

Bruce Power conducted the Huron Resilience corporate emergency exercise in 2019. It lasted 3 days and involved municipal, provincial and federal agencies. CNSC staff inspected the exercise [BRPD-AB-2019-03799] and concluded that Bruce Power demonstrated the ability to adequately respond to an emergency while ensuring the safety and protection of onsite personnel, the public and the environment.

In response to a CNSC staff request per subsection 12(2) of the General Nuclear Safety and Control Regulations, Bruce Power performed a feasibility assessment to investigate options for automatic connectivity between its plant data systems and its disaster LAN (DLAN) electronic data management system in 2019. CNSC staff concluded that the DLAN system was consistent with their data transfer expectations. CNSC staff participated in a test trial of the system as part of the development phase during the Huron Resilience exercise and confirmed its workability. CNSC staff requested that Bruce Power provide quarterly updates on system implementation starting in April 2020 [RIB 14755].

CNSC staff determined that Bruce Power maintained a comprehensive fire response capability and fire protection program in 2019. Bruce Power had an extensive fire drill and training program, which included the Emergency and Protective Services Training Facility on the Bruce site, where live fire training was conducted.

#### 3.5.11 Waste management

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the waste management SCA at Bruce A and B in 2019.

In 2019, CNSC staff confirmed through a field inspection that Bruce Power complied with the applicable regulatory requirements for waste management practices associated with waste transfer documents. CNSC staff were satisfied with the values of the safety performance indicator “low- and intermediate-level radioactive solid waste generated,” for Bruce A and B in 2019. CNSC staff also identified non-compliances of negligible safety significance that Bruce Power adequately addressed. For example, in the area of radioactive waste control, CNSC staff noted that in some instances Bruce Power personnel had left containers of radioactive waste in areas that were not sanctioned by procedures.

#### 3.5.12 Security

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the security SCA at Bruce A and B in 2019.

CNSC staff conducted 2 field inspections in late in December of 2018 that identified minor non-compliances related to facilities and equipment. As a result of discussions about the findings with Bruce Power, inspection reports were formally sent to Bruce Power in March 2019. Bruce Power addressed these findings promptly. As part of the MCR, Bruce Power added facilities and equipment to handle the increased contractor foot and vehicle traffic in and out of the protected area.

In 2019, Bruce Power implemented the corrective actions needed to address issues identified during the force-on-force exercise in 2018. Bruce Power planned to validate the corrective actions during the force-on-force exercise that is part of its 2020 performance-testing program.

Bruce Power continued to update its cyber security program at Bruce A and B to be in full compliance with CSA N290.7-14, Cyber Security for Nuclear Power Plants and Small Reactor Facilities, by December 31, 2020. CNSC staff were satisfied with the implementation progress.

#### 3.5.13 Safeguards and non-proliferation

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safeguards and non-proliferation SCA at Bruce A and B in 2019.

With respect to nuclear material accountancy and control, and safeguards equipment, CNSC staff identified a minor procedural issue identified during a safeguards field inspection; that is, a discrepancy with Bruce Power’s fuel accounting system [BRPD‑AB‑2019-03968]. Bruce Power adequately addressed the finding.

CNSC staff concluded that all nuclear material at Bruce A and B remained available for IAEA verification in 2019.

In 2019, Bruce Power submitted its required monthly general ledgers on time.

CNSC staff confirmed that Bruce Power granted adequate access and assistance to the IAEA for safeguards activities, including inspections and the maintenance of equipment at both Bruce A and B. During the 2019 IAEA inspections, the nuclear material inventory was verified and the absence of undeclared nuclear material and activities was assured.

In 2019, the IAEA reviewed Bruce Power’s revised draft design information questionnaire and provided additional comments that were also reviewed by CNSC staff. Bruce Power’s response on these comments was expected in May 2020.

Bruce Power submitted its annual operational program with quarterly updates for both Bruce A and B in a timely manner. Bruce Power also submitted the annual update to the information pursuant to the IAEA Additional Protocol as required. All information submitted to the CNSC met the applicable regulatory requirements.

CNSC staff confirmed that Bruce Power adequately supported IAEA equipment operation and maintenance activities on IAEA equipment at Bruce A and B in 2019, including routine maintenance of surveillance equipment (cameras, seals and spent-fuel monitors).

#### 3.5.14 Packaging and transport

CNSC staff concluded that Bruce Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the packaging and transport SCA at Bruce A and B in 2019.

CNSC staff confirmed that the transport of nuclear substances to and from Bruce A and B was performed safely in 2019.

There were 4 transport and packaging events reported at Bruce A and B. Two of those events involved incoming shipments. Upon arrival of those shipments, Bruce Power noticed that the packages had sustained minor damage while in transport. In the third event, during package tightening done before shipping, a package received jack bolt damage on its lid. The fourth event was caused by improper draining prior to shipping. Bruce Power evaluated this event as not reportable, but the licensee submitted the event report as a precautionary measure and for consistency with OPG and CNL reporting. None of these events were safety significant and no radioactive materials were released to the environment.

### 3.6 Western Waste Management Facility

#### 3.6.0 Introduction

The WWMF and RWOS-1 are located at the site of the nuclear generating stations at Bruce A and Bruce B 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 waste facility operating licence (WFOL) and the RWOS-1 under a waste nuclear substance licence (WNSL). The WWMF and RWOS-1 are owned and operated by OPG.

At the WWMF, OPG processes and stores dry storage containers (DSCs) containing used nuclear fuel (high-level radioactive waste) generated solely at Bruce A and B. At this facility, OPG also manages the low- and intermediate-level radioactive wastes (L&ILW) generated from the operation of OPG-owned facilities. OPG also manages the L&ILW generated from the refurbishment of Bruce A at the WWMF.

The WFOL for the WWMF allows limited activities of import and export of nuclear substances, which occur primarily as contaminants in laundry, packaging, shielding or equipment.

The WFOL spans 2 separate areas – the L&ILW Storage Facility and the Western Used Fuel Dry Storage Facility (WUFDSF) – within the overall boundary of the Bruce site. The L&ILW Storage Facility consists of the Waste Volume Reduction Building; the Transportation Package Maintenance Building; 14 above-ground, low-level storage buildings, 2 above-ground, refurbishment-waste storage buildings; and, various in-ground containers, trenches and tile holes for the storage of ILW. The WUFDSF 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 WUFDSF contains 1 DSC processing building and 4 DSC storage buildings (Storage Buildings #1, #2, #3 and #4). The WWMF currently has the capacity to store 2,000 DSCs. The transfer of loaded DSCs from Bruce A and B to the WWMF is conducted on property controlled by Bruce Power and OPG.

Under the WFOL for the WWMF, OPG is authorized to construct 4 additional DSC storage buildings (Storage Buildings #5, #6, #7 and #8), 11 additional low-level storage buildings, 270 additional in-ground containers, 30 in-ground containers for heat exchangers, 1 large-object processing building, and 1 waste-sorting building. The new structures will provide additional storage for used nuclear fuel and additional storage and processing facilities to manage L&ILW.

At RWOS-1, OPG stores L&ILW generated at the Douglas Point Nuclear Generating Station and PNGS Units 1–4. The RWOS-1 site comprises a number of in-ground waste storage structures, including concrete-lined trenches and steel-lined concrete holes.

##### Licensing

In 2017, the Commission renewed the WFOL for a 10-year period, valid from June 1, 2017 to May 31, 2027. It was not amended in 2019. The WNSL for RWOS‑1 was amended by the designated officer in 2019. The WNSL is valid for 10 years and expires on October 31, 2029.

##### Licence conditions handbook

CNSC staff did not revise the WWMF LCH in 2019. However, OPG implemented several CNSC regulatory documents (new publications or new versions of existing publications) in 2019. Future revisions of the LCH will reflect them as sources of compliance verification criteria for the WWMF.

CNSC staff were drafting an LCH for RWOS-1 in 2019.

##### Event initial reports

No event initial reports pertaining to the WWMF or RWOS-1 were submitted to the Commission for the period covering January 1, 2019 to June 1, 2020.

##### Compliance program

The compliance program included numerous activities in 2019 to confirm OPG’s compliance with the licensing basis for the WWMF. Appendix B lists the publications that provided compliance verification criteria for those activities for the WWMF.

Table 24 lists the inspections conducted at the WWMF that CNSC staff considered in their safety assessments in this regulatory oversight report.

Table 24: List of inspections at the WWMF
Safety and control area Inspection title Inspection report sent date
Operating performance

Type II Compliance Inspection – General

Report number: OPG-WWMF-2019-02

Nov 26, 2019
Environmental protection

Type II Environmental Protection Focused Compliance Inspection

Report number: OPG-WWMF-2019-03

Dec 19, 2019
Packaging and transport

Type II Compliance Inspection

Report number: OPG-WWMF-2019-01

Jul 18, 2019

In addition to the inspections listed, CNSC staff considered various other sources of information in their assessment of the safety and control areas (SCAs). Those activities identified numerous examples of compliance with regulatory requirements and excellent safety performance, as well instances of non-compliance and opportunities for improved performance. For 2019, CNSC staff rated all SCAs at the WWMF as “satisfactory” in 2019.

#### 3.6.1 Management system

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the management system SCA at the WWMF in 2019.

CNSC staff inspections in 2019 identified numerous compliant findings that confirmed the effectiveness of the management system framework at the WWMF, including the following:

• Work-related documentation/checklists were properly filled out and complete (transfer dossiers of DSCs, maintenance inspection check sheets, etc.) [OPG-WWMF-2019-01].
• Waste inventory records were maintained [OPG-WWMF-2019-02, OPG-WWMF-2019-03].

CNSC staff identified a finding of low safety significance; that is, an OPG testing and sampling operator did not have the proper training records [OPG-WWMF-2019-03]. CNSC staff were satisfied with OPG’s corrective actions.

#### 3.6.2 Human performance management

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the human performance management SCA at the WWMF in 2019.

Overall, CNSC staff did not identify any major non-compliant findings with regard to human performance in 2019. Their reviews of the quarterly and annual operational reports for the WWMF in 2019 did not identify any issues or concerns related to training or other specific areas under human performance management.

CNSC staff continued to monitor and assess OPG’s implementation of REGDOC‑2.2.4, Fitness for Duty: Managing Worker Fatigue, and planned to perform compliance verification activities in 2020.

#### 3.6.3 Operating performance

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the operating performance SCA at the WWMF in 2019.

In 2019, OPG:

• processed 102 DSCs
• received 982 m3 of L&ILW
• operated the WWMF incinerator for 103 days on solids and 121 days on liquids
• conducted caretaking activities at the RWOS-1

In 2019, CNSC staff identified non-compliances related to procedures involving inconsistency of work forms for material transportation at the WWMF [OPG-WWMF-2019-01]. CNSC staff were satisfied with OPG’s corrective measures.

CNSC staff’s review of OPG’s operational reports did not identify any issues or situations which suggested that licensed activities at the WWMF were unsafe. The reviews also confirmed that OPG’s reporting and trending, and its responses to comments and requests for follow-up information/clarification, met CNSC staff’s expectations.

#### 3.6.4 Safety analysis

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safety analysis SCA at the WWMF in 2019.

OPG did not submit any significant updates to the safety analysis report in 2019; the next revision is expected in 2022.

#### 3.6.5 Physical design

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the physical design SCA at the WWMF in 2019.

In 2019, OPG submitted its construction notification package for future storage buildings (Storage Building #5 and #6) at the WWMF site. CNSC staff reviewed the package and found that it met their expectations for site characterization.

#### 3.6.6 Fitness for service

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the fitness for service SCA at the WWMF in 2019.

As part of the aging management activities for DSCs, OPG submitted the aging management report for the OPG WMFs. CNSC staff reviewed the submission and found that it complied with OPG’s aging management program.

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the radiation protection SCA at the WWMF in 2019.

CNSC staff noted the following positive trends for radiation protection at the WWMF in 2019:

• OPG met the overall ALARA performance objectives in terms of collective dose targets.
• No action levels for worker dose control were exceeded, and annual effective doses for all workers were well below the regulatory limit of 50 mSv.
• OPG’s quarterly dose rate measurements at the RWOS-1 and WWMF perimeter fences confirmed that the average gamma dose rates at all locations remained within target.
• There were no recordable radiological exposures for OPG staff performing caretaking duties at RWOS-1.
• There was no reportable dose from work completed in the construction island around the Spent Solvent Treatment Facility.
• OPG did not exceed any action levels for loose surface contamination.
• There were no reported events related to radiological hazard control.

CNSC staff identified a non-compliance of low safety significance related to a legacy issue; that is, the majority of the LLW and ILW containers in storage did not comply with the labelling requirements of the Radiation Protection Regulations [OPG-WWMF-2019-02]. CNSC staff directed OPG to submit a plan to achieve compliance for all remaining LLW and ILW containers.

UPDATE: In March 2020, OPG provided a corrective action plan in response to this directive, which CNSC staff found acceptable.

#### 3.6.8 Conventional health and safety

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the conventional health and safety SCA at the WWMF in 2019.

CNSC inspections identified multiple compliant findings in 2019 [OPG-WWMF-2019-02/03]. These involved observations of:

• workers wearing appropriate PPE
• comprehensive safety briefings
• first aid kits and eyewash stations readily available

However, CNSC staff also identified non-compliances. For example, they noted the use of an extension cord and coat hanger to keep an entrance hatch on the wall open at the WUFDSF. CNSC staff confirmed that OPG adequately addressed the non-compliances.

#### 3.6.9 Environmental protection

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the environmental protection SCA at the WWMF in 2019.

CNSC staff noted the following positive trends for environmental protection at the WWMF in 2019:

• There were no documented exceedances of release limits for hazardous substances.
• The WWMF and RWOS-1 did not exceed any DRLs or environmental action levels.
• There were no environment-related events.

The estimated maximum dose to the public (per Bruce Power’s annual environmental reports) have been very low (<10 µSv for the past decade, compared to the regulatory limit of 1 mSv (1,000 µSv), for which the WWMF represents a small fraction of the total dose calculation for the Bruce site.

However, CNSC staff also identified a finding of low safety significance involving an absence of samples from sample station (SS) #2 for waterborne effluents [OPG-WWMF-2019-03].

UPDATE: In May 2020, OPG provided a satisfactory corrective action plan to CNSC staff.

#### 3.6.10 Emergency management and fire protection

CNSC staff confirmed that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the emergency management & fire protection SCA at the WWMF in 2019.

In 2018, CNSC staff had determined that OPG was not performing an annual fire response drill per the applicable regulatory requirements. In May 2019, CNSC staff observed OPG’s fire response drill at the WWMF and did not note any non-compliances.

However, CNSC staff identified a finding of low safety significance at the WWMF in 2019 involving fire hoses that were all past their due date for replacement (every 5 years). All 13 fire hoses were still in their cabinets in the Waste Volume Reduction Building. OPG had made this finding while performing the annual inspection of the fire hose cabinets. OPG implemented appropriate corrective actions, and immediately procured and installed new fire hoses. OPG also immediately implemented a fire impairment plan that remained in place until the hoses were replaced. In addition, OPG updated and simplified its procedural requirements as part of the corrective actions. CNSC staff were satisfied with OPG’s corrective actions.

#### 3.6.11 Waste management

CNSC staff confirmed that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the waste management SCA at the WWMF in 2019.

CNSC staff noted multiple compliant findings and good practices at the WWMF in 2019 [OPG-WWMF-2019-02], including the following:

• segregation of radioactive waste at its point of generation; segregation bins in strategic locations throughout the facility for active incinerable, active compactable, active non-processible and likely clean waste
• equipment that allows for the safe placement and removal of the storage containers
• good waste minimization in the low-level storage buildings
• package labels on waste containers in accordance with requirements
• comprehensive waste acceptance criteria for the facility

In 2019, CNSC staff reviewed the latest revision of OPG’s decommissioning program and also reviewed OPG’s standard for the management of waste and other environmentally regulated materials. The documents met the applicable regulatory requirements and CNSC staff’s expectations.

#### 3.6.12 Security

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the security SCA at the WWMF in 2019.

Bruce Power maintains an onsite nuclear response force and a drill and exercise program that serves the WWMF.

CNSC staff did not identify any major non-compliant findings with regard to security at the WWMF in 2019. CNSC staff confirmed that performance information from quarterly reports and the inspection met their expectations.

#### 3.6.13 Safeguards and non-proliferation

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safeguards and non-proliferation SCA at the WWMF in 2019.

CNSC staff confirmed that OPG submitted its required monthly general ledgers on time and that the site met the requirements of the IAEA’s physical inventory verifications and design information verifications.

OPG submitted the required annual operational program with quarterly updates, as well as the annual update to the Additional Protocol, to the CNSC in a timely manner. CNSC staff determined that the documents met the applicable regulatory requirements and staff’s expectations.

#### 3.6.14 Packaging and transport

CNSC staff concluded that OPG met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the packaging and transport SCA at the WWMF in 2019.

CNSC staff conducted a focused inspection of packaging and transport at the WWMF in 2019 and identified 11 compliant findings [OPG-WWMF-2019-01]. During the same inspection, CNSC staff also identified a finding of medium safety significance. The finding was about a label that was covered and non-visible on a package containing residual material. The package was onsite awaiting for annual maintenance and the covering was an indication not to use that package. OPG addressed the situation to the satisfaction of CNSC staff.

### 3.7 Point Lepreau Nuclear Generating Station

#### 3.7.0 Introduction

The Point Lepreau site is located on the Lepreau Peninsula, 40 kilometres southwest of Saint John, New Brunswick. The facilities are owned and operated by New Brunswick Power Corporation (NB Power) and include the Point Lepreau Nuclear Generating Station (PLNGS) – a single CANDU reactor with a rated capacity of 705 megawatts electrical (MWe). The Point Lepreau site also includes the Solid Radioactive Waste Management Facility (SRWMF), which is a short distance from the power reactor and within the exclusion zone. The CNSC regulates PLNGS and the SRWMF under a single power reactor operating licence (PROL).

Radioactive waste storage includes short-term storage in the service building prior to transfer of the waste to the SRWMF for long-term storage. The SRWMF is used for the storage of solid radioactive waste, including used nuclear fuel that is produced solely at PLNGS.

The SRWMF comprises the following Phase I, II and III sites:

• Phase I of the facility is used to store operational waste.
• Phase II is a dry storage facility for used fuel.
• Phase II Extension is an additional area prepared in 2006 to allow for dry storage of used fuel. Approval is required in accordance with the PROL prior to commissioning and use.
• Phase III of the facility stores waste from fuel channel replacement and other operations completed during the refurbishment outage.
##### Licensing

In 2017, the Commission renewed the PROL for a period of 5 years, authorizing NB Power to operate PLNGS and the SRWMF until June 2022. The PROL was not amended in 2019.

##### Licence conditions handbook

CNSC staff issued a new licence conditions handbook (LCH) when the PROL was issued on June 30, 2017. The first revision of the LCH came into effect on December 20, 2019, to update the compliance verification criteria in various sections of the LCH and to include new or revised CNSC regulatory documents, CSA Group standards and licensee documents.

##### Fisheries Act authorization

According to the provisions of the Fisheries Act, NB Power submitted, for CNSC staff review, a preliminary self-assessment of serious harm to fish from cooling-water intake. In April 2016, CNSC staff reviewed the assessment and met with NB Power to discuss the need for additional information.

NB Power submitted a revised Fisheries Act self-assessment to the CNSC in January 2017. CNSC staff completed their technical review of the self-assessment and concluded that an authorization was required in accordance with subsection 35(1) of the Fisheries Act. Fisheries and Oceans Canada concurred with the CNSC’s recommendation. NB Power submitted a partial draft Fisheries Act application to the CNSC on March 27, 2018, followed by another draft application in December 2018.

##### Periodic safety review

The PROL requires NB Power to perform a PSR in accordance with REGDOC‑2.3.3, Periodic Safety Reviews. In 2017, NB Power submitted a high-level project execution plan and a PSR basis document in support of a 10-year licensing period covering 2022 to 2032. In December 2018, NB Power submitted an updated PSR basis document which was accepted by CNSC staff. NB Power submitted safety factor reports 4, 5, 6, 7, 9, 11, 12, 13 and 14 in December 2018. Safety factor reports 1, 2, 3, 8, 10 and 15 were submitted to the CNSC in March 2019. CNSC staff completed the review of all 15 safety factor reports in October 2019.

UPDATE: NB Power submitted the Global Assessment Report in February 2020, which was under review by CNSC staff as of June 1, 2020.

##### Event initial reports

No event initial reports pertaining to Point Lepreau were submitted to the Commission for the period covering January 1, 2019 to June 1, 2020.

##### Compliance program

The compliance program included numerous activities in 2019 to confirm NB Power’s compliance with the licensing basis for Point Lepreau. Appendix B lists the publications that provided compliance verification criteria for those activities for Point Lepreau.

Table 25 lists the inspections at Point Lepreau that CNSC staff considered in their safety assessments in this regulatory oversight report. (Inspection reports were included if they were sent to NB Power by January 31, 2020.)

Table 25: List of inspections at the Point Lepreau site
Safety and control area Inspection title Inspection report sent date
Management system

Supply Management

Report number: GPLRPD-2019-05229

Dec 23, 2019

Retention of Records Supporting Initial and Renewal of Certification (field inspection)

Report number: GPLRPD-2018-FIR-01245

Dec 21, 2018
Human performance management

Human Performance Program

Report number: GPLRPD-2019-02486

May 22, 2019

Health Physics Training Program (desktop inspection)

Report number: GPLRPD-2019-04203

Aug 19, 2019
Operating performance

Quarterly Field Inspection Third Quarter FY 2018/19

Report number: GPLRPD-2019-001

Mar 11, 2019

Quarterly Field Inspection Fourth Quarter FY 2018/19

Report number: GPLRPD-2019-004

Jun 7, 2019

Planned Outage

Report number: GPLRPD-2019-03014

Jul 19, 2019

Quarterly Field Inspection First Quarter FY 2019/20

Report number: GPLRPD-2019-03257

Aug 23, 2019

Operations, Testing and Maintenance Procedures

Report number: GPLRPD-2019-04221

Oct 11, 2019

Quarterly Field Inspection Second Quarter FY 2019/20

Report number: GPLRPD-2019-04104

Nov 4, 2019

Quarterly Field Inspection Third Quarter FY 2019/20

Report number: GPLRPD-2019-05144

Feb 13, 2019
Physical design

Human Factors in Design (desktop inspection)

Report number: GPLRPD-2019-04452

Oct 16, 2019
Fitness for service

System Inspection – Containment

Report number: GPLRPD-2019-04225

Aug 23, 2019

System Inspection – Emergency Core Cooling

Report number: GPLRPD-2019-04018

Oct 21, 2019

Chemistry Control

Report number: GPLRPD-2019-05301

Jan 28, 2020

Worker Dose Control and Worker Hazard Control Field Inspection

Report number: GPLRPD-2019-FIR-03039

Apr 26, 2019

Application of ALARA

Report number: GPLRPD-2019-04312

Dec 13, 2019
Environmental protection

Environmental Monitoring

Report number: GPLRPD-2019-04383

Nov 28, 2019
Emergency management and fire protection

Emergency Management and Fire Protection Field Inspection

Report number: GPLRPD-2019-FIR-03015

Apr 16, 2019
Waste management

Report number: GPLRPD-2019-003

Jun 14, 2019

In addition to the inspections listed, CNSC staff considered various other sources of information in their assessment of the safety and control areas (SCAs). They rated all SCAs at Point Lepreau as “satisfactory” in 2019. Although CNSC staff did identify various examples of excellent safety performance, and instances of meeting and/or exceeding regulatory requirements in 2019, they did not assign “fully satisfactory” ratings at the SCA level. (This contrasts with the regulatory oversight report for 2018, where Point Lepreau received multiple “fully satisfactory” ratings.) This was strictly because of a lack of opportunity (due to the COVID-19 pandemic) for CNSC staff to assure the consistent application of criteria for “fully satisfactory” ratings across all SCAs – it does not reflect, in itself, a decline in safety at Point Lepreau in 2019.

#### 3.7.1 Management system

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the management system SCA at Point Lepreau in 2019.

##### Management system

In 2019, CNSC staff conducted 5 inspections that verified compliance of NB Power’s management systems with various applicable regulatory requirements. An inspection of the human performance program indicated that NB Power adhered to its management system governance in processes such as the control of program documents [GPLRPD-2019-02486]. However, CNSC staff also found that NB Power did not adequately adhere to information requirements in 5 documents related to the human performance program. CNSC staff were satisfied with NB Power’s corrective actions taken to address the finding.

During an inspection of the human performance program, CNSC staff concluded that NB Power’s practices that contribute to excellence in human performance had begun integration with aspects of the management system. Furthermore, CNSC staff noted that NB Power went beyond the expected implementation of human performance tools, as well as observation and coaching in the field. Efforts for continual improvement included trend analysis, self-assessments, consideration of a range of performance metrics, and benchmarking with other NPPs.

##### Organization

Several inspections in the area of organization confirmed that NB Power properly defined various roles and responsibilities. However, in 3 instances during these inspections, the responsibilities were either not clearly defined or not clearly communicated. Following the conclusion of NB Power’s corrective action plans, CNSC staff confirmed that the documented roles and responsibilities had been clarified.

##### Change management

In 2019, CNSC staff identified some minor non-compliances regarding change management within the health physics training program [GPLRPD-2019-04203]. CNSC staff requested that NB Power ensure that all change management documents for health physics training are accurate, complete and in accordance with NB Power’s governance documents. CNSC staff were satisfied with NB Power’s corrective actions taken to address the finding.

##### Safety culture

CNSC staff continued to monitor safety culture at Point Lepreau in 2019. NB Power provided an implementation plan for REGDOC-2.1.2, Safety Culture, in May 2019. NB Power updated its process documents for conducting nuclear safety culture assessments, as well as for nuclear safety culture monitoring panels, to close gaps with REGDOC-2.1.2 before it conducts its planned self-assessment of safety culture in 2021.

##### Configuration management

Five CNSC inspections in 2019 confirmed that NB Power complied with the applicable regulatory requirements for configuration management. One inspection determined that not all fire equipment was easily identifiable [GPLRPD-2019-004]. CNSC staff directed NB Power to appropriately identify all fire response equipment placed in the field so that control and traceability of each item could be maintained.

UPDATE: CNSC staff were satisfied with NB Power’s corrective action, as of April 2020.

##### Records management

All CNSC inspections in 2019 verified compliance of some elements of records management, and the overall conclusion was that this area was generally compliant with the applicable regulatory requirements. However, CNSC staff identified 4 non-compliances of negligible safety significance and 2 non-compliances of low safety significance. These conclusions resulted from CNSC inspections involving records related to initial certifications for shift supervisors and control room operators, and to renewals of examinations, as well as from CNSC staff’s reviews of NB Power’s reviews/updates of pre-fire plans. For the 2 non-compliances of low safety significance, CNSC staff concluded that NB Power was addressing the issues adequately by the end of 2019.

In 2019, CNSC staff concluded a field inspection of fitness for duty and concluded that NB Power’s process to manage fatigue met the applicable requirements for records management.

#### 3.7.2 Human performance management

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the human performance management SCA at Point Lepreau in 2019.

##### Human performance program

CNSC staff identified more than 20 findings in 2019 that confirmed compliance with the applicable regulatory requirements for NB Power’s human performance program. These findings covered both the definition of the program and the assessment of its effectiveness. Most findings were related to the appropriate use of human performance tools, including procedure use and adherence, while other topics included communications, resource planning and worker support. For example, the inspection of the human performance program identified 4 compliant findings [GPLRPD-2019-02486].

##### Personnel training

CNSC staff concluded that, in 2019, Point Lepreau had a well-documented and robust training system based on a systematic approach to training, based on numerous compliant findings from various compliance verification activities. However, there were a few minor non-compliances (1 of negligible safety significance and 2 of low safety significance) for the training programs at Point Lepreau [GPLRPD-2019-04203].

##### Personnel certification

During a field inspection in 2018, CNSC staff identified several non-compliant findings in the area of personnel certification records. CNSC staff were satisfied with the corrective action plan proposed by NB Power in January 2019. NB Power was continuing to implement the plan at the end of 2019.

##### Fitness for duty

In 2019, 3 minimum shift complement (MSC) violations took place at Point Lepreau. All 3 events involved emergency response team (ERT) members calling in as “unavailable” for their scheduled shift while replacements could not be found. Two ERT members worked 16-hour shifts but there were two 4-hour periods below MSC. Quiet mode was enacted for these two 4-hour periods. NB Power proposed adding ERT members to its MSC LCH table. This addition is an improvement and adds clarity. The numbers proposed by NB Power (8 ERT members and 1 ERT leader) are in line with its procedure and reflect the numbers of ERT members that were validated. Thus, the change met CNSC staff’s expectations.

CNSC field inspections related to managing worker fatigue identified 2 compliant findings in 2019. NB Power made a commitment to implement REGDOC-2.2.4, Fitness for Duty: Managing Worker Fatigue, by March 1, 2021 (except during outages), and to fully implement it by June 30, 2022. In December 2019, NB Power reaffirmed that its implementation was on track.

NB Power had planned to implement the first version of CNSC REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use, by December 2019. In the meantime, CNSC staff accepted several of NB Power’s requests for amendments to version 2 of REGDOC-2.2.4, Volume II. NB Power made a commitment to implement the new version 3 of REGDOC-2.2.4, Volume II, 6 months after its publication (for all areas other than random testing) and to implement the requirements for random testing 12 months after the publication.

NB Power became fully compliant with CNSC REGDOC-2.2.4, Volume III: Nuclear Security Officer Medical, Physical and Psychological Fitness, as of November 2019.

#### 3.7.3 Operating performance

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the operating performance SCA at Point Lepreau in 2019.

CNSC staff identified over 30 findings through Type II system and outage inspections and field inspections in 2019 that confirmed NB Power’s compliance with requirements for the general conduct of licensed activities. For example, CNSC staff confirmed that NB Power verified that activities such as operator surveillance, surveillance testing and performance of work were completed in accordance with the applicable requirements.

##### Procedures

CNSC staff identified 7 compliant findings in 2019 related to NB Power’s procedures during numerous verification activities. For example, during a planned outage inspection, CNSC staff confirmed that aspects of procedural adequacy and adherence complied with the applicable regulatory requirements [GLPRPD-2019-03014].

##### Reporting and trending

NB Power submitted all scheduled reports in 2019 as required and within the appropriate timelines. Although there were no significant issues related to NB Power’s reporting and trending, there was an instance where NB Power did not submit a required notice of document change to the CNSC. The notice was about a change related to the frequency of water lancing in the steam generator management plan, which is a “prior-notification document” listed in the LCH.

##### Outage management performance

During its planned outage inspection in 2019, CNSC staff identified 18 compliant findings [GPLRPD-2019-03014]. CNSC staff noted that no process or equipment failures occurred during the outage and that NB Power had:

• met all of the regulatory undertakings and commitments for the outage
• appropriately met the scope of the outage
• effectively planned the work

CNSC staff also noted the actions taken by NB Power during the 3 forced outages in 2019 were appropriate and in the conservative direction. In all cases, NB Power manually shut down the reactor and completed the repairs systematically. There were no concerns identified by site inspectors during their monitoring of the forced outages.

##### Severe accident management and recovery

In 2019, CNSC site staff conducted 2 field inspections of the emergency mitigating equipment [GPLRPD-2019-05144]. They confirmed that the equipment was properly maintained and that it was poised and ready for use if needed for managing a severe accident.

#### 3.7.4 Safety analysis

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safety analysis SCA at Point Lepreau in 2019.

##### Deterministic safety analysis

In 2019, CNSC staff completed their review of NB Power’s basis document for the analysis of loss-of-flow accidents. The purpose of the basis document was to align the expectations of NB Power and CNSC staff for the analysis to follow. While CNSC staff found the basis document to be well structured and well written, they made some recommendations related to the approach of the analysis and to a code validation issue.

In 2019, CNSC staff reviewed NB Power’s safety analysis update for fast loss of reactivity control and found that it was generally consistent with the expectations and requirements outlined in CNSC REGDOC-2.4.1, Deterministic Safety Analysis. For some sections, CNSC staff determined that additional information was needed.

In 2019, CNSC staff provided comments on NB Power’s revised implementation plan for REGDOC-2.4.1. They found NB Power’s disposition of comments on the graded approach to analysis of anticipated operational occurrences acceptable. NB Power continued to carry out safety analyses in a staged manner, as part of REGDOC‑2.4.1 implementation. CNSC staff were satisfied with NB Power’s progress on REGDOC-2.4.1 implementation at the end of 2019.

During a system inspection [GPLRPD-2019-04018], CNSC staff observed that the technical operability evaluations for the system reviewed during the inspection complied with the requirements for deterministic safety analysis.

##### Probabilistic safety assessment

NB Power submitted new and revised methodologies in 2018 for performing the next periodic PSA update in 2021 [2]. CNSC staff concluded that the new methodologies met the applicable regulatory requirements and found them acceptable. However, they made some recommendations for improvements in areas such as documentation of changes, and sensitivity and uncertainty analyses.

#### 3.7.5 Physical design

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the physical design SCA at Point Lepreau in 2019.

##### Design governance

In 2019, CNSC staff accepted NB Power’s plan for compliance by 2022 with CSA N393‑13, Fire Protection for Facilities That Process, Handle, or Store Nuclear Substances.

In 2019, CNSC staff completed field inspections that verified various aspects of design governance, and identified 5 compliant findings that confirmed NB Power met the applicable requirements for seismically qualified component design. They also identified that NB Power met the requirements for seismic component design under the broader category of structure design in 2019 [GPLRPD-2019-001].

CNSC staff identified 3 non-compliances of low safety significance during a desktop inspection of human factors in design [GPLRPD-2019-04452]. In the first case, NB Power did not meet all of the applicable requirements concerning the criteria and process used for grading. The grading criteria used in the human factors engineering activities were incomplete – 2 of the 4 modifications examined could not be graded using the documented process. In the second case, NB Power met the applicable regulatory requirements but NB Power did not comply with its own process – the requirements for human factors engineering were incompletely specified in all of the engineering packages that CNSC staff examined. Lastly, the evaluation of the designs was not performed systematically in a way that demonstrated that the recommendations of the design reviewers were addressed.

UPDATE: In February 2020, NB Power provided, to the satisfaction of CNSC staff, a detailed corrective action plan with target completion dates in response to the non-compliances identified during the desktop inspection of human factors in design.

As follow-up to NB Power’s revision of its battery-testing program, to test the batteries in the “as found” condition, CNSC staff reviewed and found acceptable the revised procedure for conducting the performance test. The first use of the revised procedure was planned for the 2020 outage.

##### System design

In September 2018, CNSC staff had conducted an inspection of electrical power systems that identified some non-compliances in the cable aging management program. They found that NB Power’s detailed corrective action plan to establish a cable aging management program was acceptable. In 2019, NB Power developed the qualification stream for the role of cable program specialist, which addressed one of CNSC staff’s concerns. CNSC staff were satisfied with the progress made in 2019 and expected that the remaining documentation-related items would be addressed in 2020.

While reviewing a station event, CNSC staff noted that an electrical fault on the secondary cable of the station service transformer (SST) was due to a degraded splice and termination, and subsequent failure, of the cable. NB Power submitted an apparent-cause evaluation report that identified the lack of an effective cable aging management program as a contributing cause. NB Power staff repaired the cable and inspected all SST cables. Furthermore, NB Power conducted additional maintenance and testing of SST cables during the 2019 outage.

##### Component design

CNSC staff found that NB Power’s 2019 annual report on fuel monitoring and inspection complied with the applicable regulatory requirements. However, CNSC staff noted a negative trend in the fuel defect rate for Point Lepreau, which has remained elevated for multiple years and continued to be above the expected rate of 1 defect per unit per year. The fuel defects were caused by foreign material introduced by outage work on the primary heat transport system. CNSC staff were satisfied that the elevated defects stemmed from an isolated event for which NB Power took effective corrective action. CNSC staff concluded that overall fuel performance remained safe at Point Lepreau but continued to monitor the defect rate trends.

#### 3.7.6 Fitness for service

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the fitness for service SCA at Point Lepreau in 2019.

##### Equipment fitness for service / equipment performance

CNSC staff identified 5 compliant findings during Type II and field inspections in 2019 related to fitness for service and performance of equipment at Point Lepreau in that year. To address the findings of the CNSC inspection of the service water system in 2018 [2], NB Power updated several documents, developed a preventive maintenance strategy for flow meters and updated the testing strategy for load-shedding valves. CNSC staff were satisfied with NB Power’s corrective actions in 2019.

In 2019, CNSC staff reviewed the 2018 annual reliability report for Point Lepreau and confirmed that it met the applicable regulatory requirements.

For 2019, CNSC staff noted that all the special safety systems at Point Lepreau met their unavailability targets, except for negative pressure containment (NPC). The NPC system exceeded the unavailability target because 2 of the isolation valves were found to be leaking. Upon discovery, NB Power repaired the valves. Containment isolation was unavailable for 1,083 hours. There was no significant impact on nuclear safety as a result of these instances of unavailability. CNSC staff continued to monitor NB Power’s corrective action in 2019.

##### Maintenance

NB Power kept both the critical corrective maintenance backlog and the number of critical PM deferrals very low in 2019. The critical deficient maintenance backlog was trending downward but still above industry average (which also improved in 2019). The preventive maintenance completion ratio was around 92%. No safety-significant findings were identified in the maintenance area during CNSC inspections and event reviews in 2019. Table 26 shows the trends of the corrective critical maintenance backlog, deficient critical maintenance backlog, and the number of deferrals of preventive maintenance critical components.

Table 26: Trend of maintenance backlogs and deferrals for critical components for Point Lepreau, 2017 to 2019
Parameter Average quarterly work orders per unit Three-year trending Quarterly 2019 work orders Industry average for 2019
2017 2018 2019 Q1 Q2 Q3 Q4
Corrective maintenance backlog 2 1 1 Steady 1 1 3 0 1
Deficient maintenance backlog 71 27 15 Down 13 16 15 15 9
Deferrals of preventive maintenance 1 0 1 Down 1 1 0 1 2
##### Periodic inspections and testing

As part of its periodic inspection program, NB Power removed a steam generator tube to perform a metallurgical examination. NB Power’s technical service provider concluded that no additional degradation had occurred since the last surveillance examination in 2010 during the Point Lepreau refurbishment outage. In 2019, CNSC staff reviewed the submission from NB Power and concluded that the analysis satisfied the applicable regulatory requirements. Overall, the results of visual and metallurgical examinations indicated that the lifecycle management strategies for Point Lepreau steam generators were effective and that no changes were required. Noting that the technical service provider planned to continue examining the removed tube using focused ion beam and transmission Kikuchi diffraction analyses, CNSC staff requested that NB Power submit the final report after the additional analysis.

##### Aging management

In 2018, CNSC staff had inspected the aging management program at Point Lepreau [2]. Non-compliances included discrepancies in the aging management process implementation compared to the governance documents. The inspection also revealed minor non-compliances in the obsolescence program and in the conduct of condition assessments. In 2019, NB Power provided 5 submissions to address the non-compliances. CNSC staff concluded that the responses were acceptable and that there were no fundamental gaps.

##### Chemistry control

A CNSC inspection of chemistry control identified 3 compliant findings and verified various aspects, such as maintenance of chemistry in accordance with specifications, monitoring of chemistry parameters and data trending [GPLRPD-2019-05301]. Several other field inspections in the area of chemistry control recorded multiple compliant findings; the quarterly data for the chemistry index safety performance indicators were also satisfactory.

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the radiation protection SCA at Point Lepreau in 2019.

##### Application of ALARA

In 2019, CNSC staff conducted a Type II inspection and multiple field inspections on the application of ALARA, and identified 6 compliant findings. CNSC staff verified that NB Power used ALARA initiatives, work planning, and dose monitoring and control to work towards the ALARA targets established by NB Power.

Inspection activities verified that NB Power was implementing several long-term station ALARA initiatives, including a tritium mitigation strategy, to further reduce station collective dose.

In 2019, NB Power performed better than its collective radiation exposure (CRE) target, with a collective dose of 596 p-mSv versus the planned target of 783 p‑mSv. Most of the CRE was due to outage activities.

CNSC staff concluded that NB Power’s performance met or exceeded all applicable regulatory requirements in the application of ALARA specific area.

##### Worker dose control

CNSC staff identified 15 compliant findings during inspections in 2019 related to worker dose control.

CNSC staff determined that NB Power met or exceeded the applicable regulatory requirements to ascertain and record doses received by workers at Point Lepreau in 2019.

Radiation doses to workers at Point Lepreau were below the regulatory dose limits (50 mSv), and no action level exceedances were reported. CNSC staff observed that there were no adverse trends or safety-significant unplanned exposures at Point Lepreau in 2019.

During the outage inspection in April 2019 [GPLRPD-2019-03014], CNSC staff found that NB Power complied with the Radiation Protection Regulations for radiological hazard control, worker dose control and application of ALARA.

The inspections conducted in 2019 in the area of radiological hazard control identified 7 compliant findings and 1 non-compliant finding. The non-compliant finding was associated with radiological hazard posting, specifically alpha classification; posting did not always follow the applicable procedures. CNSC staff were satisfied with NB Power’s corrective actions.

CNSC staff determined that Point Lepreau implemented effective controls for radiological hazards. There were no action level exceedances for surface contamination or contamination control at Point Lepreau in 2019.

#### 3.7.8 Conventional health and safety

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the conventional health and safety SCA at Point Lepreau in 2019.

In 2019, CNSC identified 30 compliant findings related to conventional health and safety during Type II and field inspections.

CNSC staff observed that the safety performance indicators “accident severity rate” (ASR) and “industrial safety accident rate” (ISAR) for Point Lepreau were 0.0 in 2019 – no lost time injuries were reported. The safety performance indicator “accident frequency” (AF) increased to 0.77 in 2019, from 0.3 in 2018 due to the higher number of medically treated injuries (8) that did not result in lost time. CNSC staff found the ASR, ISAR and AF values at Point Lepreau acceptable. Section 2.8 provides additional ASR, ISAR and AF data.

#### 3.7.9 Environmental protection

CNSC staff concluded from their observations that all airborne and waterborne radiological releases from the Point Lepreau site remained below the regulatory limits and environmental action levels in 2019. Appendix D shows the absolute values for releases and derived release limits (DRLs) for Point Lepreau.

In addition, NB Power’s environmental monitoring data for 2019 showed that the public and the environment in the vicinity of the Point Lepreau site were protected.

In 2018, NB Power revised its DRL document in order to comply with updated requirements [2]. CNSC staff assessed the revised DRLs in 2019 and noted that they were, in general, more restrictive (95.6% of airborne DRLs and 89.1% of waterborne) than the previous DRLs. They concluded that the implementation of DRLs at the Point Lepreau site indicated that the environment and the public were protected from the radiological impacts of radionuclides.

The estimated dose to the public from the Point Lepreau site for 2019 was 1.12 μSv for airborne releases and 0.8 μSv for liquid releases. This was an increase from the estimated dose of 0.72 μSv in 2018, but still well below the annual dose limit of 1 mSv (1,000 μSv). See section 2.9 for additional information.

CNSC staff reviewed the 2019 annual environmental report on industrial waste treatment systems at the Point Lepreau site and noted that no discharge limits were exceeded for those systems.

CNSC field inspections confirmed that NB Power took all reasonable precautions to protect the environment, and the health and safety of persons. One of the field inspections also confirmed that NB Power complied with the hazardous waste management requirements for the areas inspected.

CNSC staff also inspected the operation of waste management facilities in 2019 and concluded that NB Power complied with the applicable regulatory requirements for effluent and emissions control (releases) [GPLRPD-2019-003].

NB Power reported a few spill events in 2019 at the Point Lepreau site, but they were not safety significant, and the public and environment remained protected.

During an inspection of environmental monitoring in 2019, CNSC staff concluded that NB Power complied with the applicable regulatory requirements for environmental assessment and monitoring [GPLRPD-2019-04383].

In 2017, NB Power submitted a revised environmental risk assessment (ERA). CNSC staff completed a detailed technical review of the ERA in 2019 and found that the methodology was generally consistent with the applicable regulatory requirements. However, they recommended that future revisions to the ERA include an assessment of the magnitude and extent of the thermal plume from discharged cooling water and a broad risk assessment for the inter-tidal and near-surface zones that could be affected by the thermal plume.

To address this recommendation, NB Power submitted the thermal plume monitoring report for Point Lepreau in 2019, and staff from the CNSC and ECCC provided initial comments on it. NB Power is expected to submit a revised ERA in June 2020 that also includes an updated thermal risk assessment.

#### 3.7.10 Emergency management and fire protection

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the emergency management and fire protection SCA at Point Lepreau in 2019.

In January 2019, NB Power completed its work to establish the capacity for direct plant data transfer from Point Lepreau to the CNSC’s Emergency Operating Centre (EOC) during nuclear emergencies.

CNSC staff conducted field inspections and an outage inspection [GPLRPD-2019-03014] related to nuclear emergency preparedness and response in 2019. As a result, CNSC staff identified 5 compliant findings and 3 non-compliances of low safety significance. In one case, non-compliances concerning the offsite emergency operations centre, equipment and procedures were identified. Two other minor non-compliances were related to the emergency drills. CNSC staff were satisfied with how NB Power addressed these non-compliances.

CNSC staff also identified 19 compliant findings related to fire emergency preparedness and response. The areas verified included the availability of fire protection equipment emergency notification, fire doors and exits; and the performance of fire drills. However, there was an instance where CNSC staff could not fully verify the availability of fire equipment because the pre-fire plan document was not up to date [GPLRPD-2019-004].

UPDATE: In February 2020, NB Power updated its document. CNSC staff were satisfied with the update.

#### 3.7.11 Waste management

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the waste management SCA at Point Lepreau in 2019.

In 2019, CNSC staff conducted 1 inspection of SRWMF operations [GPLRPD-2019-003] and 3 field inspections related to waste management. CNSC staff identified 6 compliant findings in the areas of practices, waste characterization, segregation and minimization.

The PROL for Point Lepreau requires that NB Power submit a quarterly report on the SRWMF. CNSC staff were satisfied with all reports and additional information submitted by NB Power for the SRWMF in 2019.

#### 3.7.12 Security

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the security SCA at Point Lepreau in 2019.

In 2019, CNSC staff conducted 2 field inspections related to security facilities and equipment, and concluded that NB Power met the applicable regulatory requirements and continued to sustain the equipment through lifecycle management. However, some minor equipment failures were observed. CNSC staff were satisfied with NB Power’s response.

NB Power conducted a force-on-force security exercise in 2019 as part of its performance testing program and submitted its self-assessment report to the CNSC. The corrective measures proposed by NB Power to address identified issues met CNSC staff’s expectations. CNSC staff concluded that the format of the drills and exercises had significantly improved at Point Lepreau. CNSC staff concluded that, overall, in the context of the design-basis threat, NB Power deployed authorized, suitably equipped and trained nuclear security officers, and maintained an onsite nuclear response force, and drill and exercise program, which meet regulatory requirements.

CNSC staff identified minor non-compliances related to security practices during 3 field inspections in 2019. They confirmed that NB Power effectively addressed the non-compliances. They concluded that, overall, NB Power had procedures to provide guidance to security personnel at Point Lepreau.

#### 3.7.13 Safeguards and non-proliferation

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safeguards and non-proliferation SCA at Point Lepreau in 2019.

Pursuant to the Canada/IAEA safeguards agreements, NB Power granted adequate access and assistance to the IAEA for safeguards activities, including inspections and the maintenance of equipment at Point Lepreau. In 2019, the IAEA conducted 2 announced, 1 short-notice and 5 unannounced inspections at Point Lepreau. The results from IAEA inspections were all satisfactory. Details on other IAEA activities are provided in section 2.13.

NB Power implemented CNSC REGDOC-2.13.1, Safeguards and Nuclear Material Accountancy, by the end of 2019.

During field inspections in 2019, CNSC staff confirmed that NB Power complied with the applicable safeguards requirements for the safeguards electrical panels that were observed, and also for access and assistance to the IAEA.

#### 3.7.14 Packaging and transport

CNSC staff concluded that NB Power met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the packaging and transport SCA at Point Lepreau in 2019.

There were no reportable events at Point Lepreau in 2019 related to packaging and transport of nuclear substances.

### 3.8 Gentilly-2 Facilities

#### 3.8.0 Introduction

The Gentilly-2 Facilities are located on the south shore of the St. Lawrence River in Bécancour, Quebec, around 15 km east of the city of Trois-Rivières and are owned and operated by Hydro-Québec.

The Gentilly-2 CANDU reactor had a nominal capacity of 675 MWe (megawatts electrical). It went into commercial operation in 1983, was permanently shut down on December 28, 2012, and was completely defuelled by September 3, 2013. In December 2014, the reactor completed the transition to a safe storage state, meaning that its fuel is stored in used fuel pools (wet storage) or in CANSTOR modules (dry storage).

##### Licensing

In 2016, the Commission issued a power reactor decommissioning licence to Hydro-Québec for the Gentilly-2 Facilities. The licence is valid from July 1, 2016, to June 30, 2026.

##### Licence conditions handbook

The licence conditions handbook (LCH) for the Gentilly-2 Facilities was issued at the same time as the licence in 2016.

The LCH was revised in February 2019 to reflect changes to the Gentilly-2 Facilities.

##### Fisheries Act authorization

Hydro-Québec conducted a self-assessment under the Fisheries Act prior to the issuance of its licence in 2016. CNSC staff reviewed the self-assessment and concluded that authorization under the Act was not required.

##### Event initial reports

The Commission received no event initial reports pertaining to the Gentilly-2 Facilities between January 1, 2019, and June 1, 2020.

##### Compliance program

The compliance program included numerous activities in 2019 to confirm Hydro-Québec’s compliance with the licensing basis for the Gentilly-2 Facilities. Appendix B lists the publications that provided compliance verification criteria for those activities for the Gentilly-2 Facilities.

Table 27 lists the inspections of the Gentillly-2 Facilities that were considered in the safety assessments used in this regulatory oversight report.

Table 27: List of inspections at the Gentilly-2 Facilities
Safety and control area Inspection title Date inspection report sent
Security

Security Personnel Training Program at Gentilly-2 Facilities

Report number: DPRGPL-2019-001

Jun 7, 2019
Environmental protection

Effluent Monitoring Program at Gentilly-2 Facilities

Report number: GPLRPD-2019-FIR-05297

Nov 20, 2019

Environmental Monitoring Program at Gentilly-2 Facilities

Report number: GPLRPD-2019-FIR-05298

Nov 20, 2019
Waste management

Waste Management – Observation of Irradiated Fuel Transfer Activities

Report number: GPLRPD-2019-FIR-03496

May 14, 2019

Hazardous Waste Monitoring Program at Gentilly-2 Facilities

Report number: GPLRPD-2019-FIR-05299

Nov 20, 2019
Emergency management and fire protection

Fire Drill at Gentilly-2 Facilities

Report number: GPLRPD-2019-FIR-03215

May 14, 2019

In addition to the inspections listed, CNSC staff considered various other sources of information in their assessment of the safety and control areas (SCAs). Those activities identified numerous examples of compliance with regulatory requirements and excellent safety performance, as well as some instances of non-compliance and opportunities for improved performance. For 2019, CNSC staff assigned “satisfactory” ratings for all SCAs at the Gentilly-2 Facilities.

#### 3.8.1 Management system

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the management system SCA at the Gentilly-2 Facilities in 2019.

In February 2019, CNSC staff examined a new revision to Hydro-Québec’s Quality Management Manual (QMM). CNSC staff’s comments focused on the independence of the quality assurance (QA) function since the organization chart in the revised QMM did not demonstrate how the QA function was independent of other functions (such as engineering or radiation protection). In response, Hydro-Québec submitted a new version of the QMM in July 2019. CNSC staff examined that version and concluded that the new organization chart properly demonstrated the independence of the QA function at the Gentilly-2 Facilities, as the audit and inspection functions would now report directly to the Facility director.

CNSC staff reviewed the reports on corrections and improvements issued in 2019 and noted that Hydro-Québec had identified the problems, taken corrective action and conducted a follow-up [DPRGPL-2019-FIR-05299].

In January 2019, the CNSC sent Hydro-Québec a request for an implementation plan for REGDOC-2.1.2, Safety Culture. Hydro-Québec submitted its implementation plan in September 2019 along with revisions to its ongoing monitoring program. CNSC staff concluded that Hydro-Québec met the applicable requirements of REGDOC-2.1.2. The Gentilly-2 Facilities met CNSC staff’s expectations with respect to safety culture.

The records verified at the Gentilly-2 Facilities during the 2019 inspections were legible, traceable and controlled, in compliance with requirements [DPRGPL-2019-FIR-05298, DPRGPL-2019-FIR-05299 and DPRGPL-2019-FIR-05297].

#### 3.8.2 Human performance management

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the human performance management SCA at the Gentilly-2 Facilities in 2019.

In 2019, CNSC staff completed an inspection of the nuclear security officer training program [DPRGPL-2019-001].

CNSC staff conducted 3 additional inspections of personnel training, which was found to meet regulatory requirements. More specifically, CNSC staff found the following:

• Hydro-Québec personnel met the qualification requirements set out in the program. The worker training records consulted were up to date, and the workers interviewed demonstrated that they had the skills required to perform their duties under the hazardous waste monitoring program [DPRGPL-2019-FIR-05299].
• Hydro-Québec personnel met the training requirements of the environmental monitoring plan. The workers interviewed as part of the inspections demonstrated that they had the knowledge required to perform their duties [DPRGPL-2019-FIR-05298].
• In the context of the environmental monitoring program, the workers interviewed met the qualification requirements, their training records were up to date, and they had the skills required to perform their duties [DPRGPL-2019-FIR-05297].

On the basis of the inspection results, CNSC staff concluded that Hydro-Québec had implemented a training program that was based on a systematic approach to training, in accordance with regulatory requirements.

The individuals serving as senior health physicists (SHPs) are the only ones still certified at the Gentilly-2 Facilities. The CNSC received no SHP certification or certification renewal requests in 2019. The Gentilly-2 Facilities no longer offer initial certification examinations or requalification tests for certified personnel since SHPs are assessed directly by CNSC staff.

With respect to fitness for duty, Hydro-Québec made a commitment to implement the following documents:

• REGDOC-2.2.4, Fitness for Duty, Volume II: Managing Alcohol and Drug Use, before January 1, 2019
• REGDOC-2.2.4, Fitness for Duty: Managing Worker Fatigue, before July 1, 2019

In 2019, CNSC staff examined the additional information and clarification provided by Hydro-Québec about its implementation plan. CNSC staff confirmed that Hydro-Québec had completed and implemented all measures included in its transition plan.

In November 2019, Hydro-Québec wrote to the CNSC to confirm its compliance with REGDOC-2.2.4, Fitness for Duty, Volume III: Nuclear Security Officer Medical, Physical and Psychological Fitness. The CNSC reviewed the letter and confirmed in December 2019 that Hydro-Québec was in compliance with REGDOC-2.2.4, Volume III.

CNSC staff concluded that the implementation of the new fitness-for-duty requirements met their expectations in 2019.

#### 3.8.3 Operating performance

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the operating performance SCA at the Gentilly-2 Facilities in 2019.

The quarterly, semi-annual and annual reports submitted by Hydro-Québec in 2019 documenting the activities carried out demonstrated compliance with licence requirements. CNSC staff reviewed the reports and found no shortcomings or situations that would indicate that the activities conducted at the Gentilly-2 Facilities were unsafe or below staff expectations. Hydro-Québec provided the CNSC staff reviewing the reports with satisfactory responses within an acceptable time frame. In addition, Hydro-Québec reported events that occurred at the Gentilly-2 Facilities in 2019 to the CNSC and took corrective action, to the satisfaction of CNSC staff.

#### 3.8.4 Safety analysis

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safety analysis SCA at the Gentilly-2 Facilities in 2019.

CNSC staff reviewed an update to the safety report on the Gentilly-2 Facilities, which it received from Hydro-Québec in August 2019. CNSC staff were satisfied with the update. Hydro-Québec's approach was consistent with REGDOC-2.4.1, Deterministic Safety Analysis. The information and analysis submitted by Hydro-Québec showed that the changes made to the Gentilly-2 Facilities since 2014 did not increase the risk and that the current safety report adequately covered the risks that would be present up to the achievement of a safe dry storage state. However, Hydro-Québec is required to submit, in 2021, a complete update of the safety report for the Gentilly-2 Facilities in order to reflect the risk associated with the new state (safe dry storage).

#### 3.8.5 Physical design

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the physical design SCA at the Gentilly-2 Facilities in 2019.

The performance information from technical reviews and quarterly and annual reports met CNSC staff’s expectations with respect to electrical systems. For example, no major concerns were identified in relation to the following reviews:

• analysis of significant events – forced outage of a gas turbine at the Bécancour plant
• work on line equipment connecting the Gentilly-2 Facilities to the electrical grid

#### 3.8.6 Fitness for service

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the fitness for service SCA at the Gentilly-2 Facilities in 2019.

CNSC staff completed a field inspection of the environmental monitoring program in 2019 [GPLRPD-2019-FIR-05298]. All verified equipment was correctly labelled and identified and had been calibrated according to requirements. CNSC staff were satisfied with the preventive maintenance completion ratio, which was 90% in 2019.

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the radiation protection SCA at the Gentilly-2 Facilities in 2019.

In 2019, CNSC staff conducted a field inspection on the transfer of irradiated fuel [GPLRPD-2019-FIR-03496], which resulted in findings related to radiation protection. See section 3.8.11 for more details.

CNSC staff’s review of safety performance indicators (SPIs) in 2019 did not identify any problems. Indeed, the SPI for collective radiation exposure identified no abnormalities. Moreover, at no point in 2019 did the Gentilly-2 Facilities exceed the regulatory limits for doses to workers. There were also no reports that regulatory action levels had been exceeded.

The SPI for personnel contamination events identified a few minor events, but no significant events were reported in 2019. The SPI for unplanned dose and the SPI for loose contamination events were both “0” for all quarters in 2019. This would indicate that Hydro-Québec experienced no problems in these areas in 2019.

#### 3.8.8 Conventional health and safety

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the conventional health and safety SCA at the Gentilly-2 Facilities in 2019.

The field inspections carried out by CNSC staff in 2019 always took conventional health and safety into account, although it was not formally covered in the inspection reports. In general, CNSC staff found during these inspections that health and safety practices were adequate. In addition, CNSC staff noted that no reports had been submitted identifying health and safety events in 2019.

The information submitted by Hydro-Québec with respect to conventional health and safety indicated that the calculated accident frequency rate and industrial safety accident rate were both “0” in 2019.

#### 3.8.9 Environmental protection

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the environmental protection SCA at the Gentilly-2 Facilities in 2019.

In 2018, Hydro-Québec completed the transition to REGDOC-2.9.1, Environmental Protection: Environmental Principles, Assessments and Protection Measures (2013 version), and confirmed its compliance with that regulatory document. Furthermore, in 2019, Hydro-Québec conducted a review of its QMM, which included documentation on the environmental management system.

During the field inspection carried out in November 2019 [DPRGPL-2019-FIR-05299], CNSC staff made 2 findings with respect to the environmental management system: a negligible finding in relation to the environmental monitoring program, and a compliant finding in relation to the hazardous waste monitoring program. The negligible finding stemmed from the fact that the wording on the forms for recording thermoluminescent dosimeter (TLD) readings in the laboratory and in the field did not match. However, Hydro-Québec corrected this issue quickly and adequately.

In 2018, Hydro-Québec extended the line for the release of liquid effluents by approximately 800 metres from the edge of the discharge channel, further into the St. Lawrence River [2]. This change required a downward review of the liquid derived release limits (DRLs), resulting in more restrictive DRLs.

In 2019, all radiological emissions were well below regulatory limits and represented only a small fraction of their DRL. Only 1 spill was recorded, in the fourth quarter of 2019, with no harm to the environment.

In 2019, the estimated annual radiation dose to individuals representative of the public was 3 µSv, well below the regulatory public dose limit (1 mSv) and below the 2018 dose.

During a 2019 field inspection on hazardous waste [DPRGPL-2019-FIR-05299], it was found that the physical inventory of certain types of hazardous waste stored at the Gentilly-2 Facilities did not match the inventory entries in the database. However, this discrepancy was deemed to have a very low impact on the protection of the public. Furthermore, CNSC staff found that Hydro-Québec had taken adequate measures to correct the situation.

#### 3.8.10 Emergency management and fire protection

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the emergency management and fire protection SCA at the Gentilly-2 Facilities in 2019.

In May 2019, CNSC staff observed a joint fire drill between Hydro-Québec and the Bécancour fire service (SSIB) [GPLRPD-2019-FIR-03215]. The agreement between Hydro-Québec and the SSIB stipulates that Hydro-Québec must hold 2 joint fire drills with the SSIB each year. While the drill focused primarily on fire response, it also included a radiological component (rescuing an injured person from a radiological zone). CNSC staff were satisfied with Hydro-Québec’s performance with respect to its fire and radiological response during the drill.

CNSC staff reviewed the SPIs for the emergency response organization drill participation index and the emergency response resources completion index, and were satisfied with the results presented by Hydro-Québec in 2019. In addition, CNSC staff validated that, in 2019, Hydro-Québec had organized the 2 required training and familiarization tours for SSIB members and that the nuclear safety officers were trained on fire extinguisher use.

#### 3.8.11 Waste management

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the waste management SCA at the Gentilly-2 Facilities in 2019.

In 2019, CNSC staff carried out a field inspection on the transfer of irradiated fuel [GPLRPD-2019-FIR-03496]. During the inspection, CNSC staff identified 3 compliances. For example, workers conducted a pre-work verification. However, there were 2 non-compliances. For example, although the personnel interviewed all wore the appropriate dosimetry devices, workers were seen wearing them on the inside of their work clothes. Hydro-Québec submitted a response to the inspection report, and CNSC staff were satisfied with the action taken.

CNSC staff examined the 2 semi-annual reports on the management of the Gentilly-2 radioactive solid waste and irradiated fuel facilities for 2019. These reports satisfied regulatory requirements, and CNSC staff had no comments to make.

In 2019, CNSC staff reviewed the plans and specifications for the failed fuel encapsulation project. CNSC staff were satisfied with this new method, which will have no impact on the safety of facilities and which is compliant with Hydro-Québec’s licence requirements.

#### 3.8.12 Security

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the security SCA at the Gentilly-2 Facilities in 2019.

#### 3.8.13 Safeguards and non-proliferation

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the safeguards and non-proliferation SCA at the Gentilly-2 Facilities in 2019.

Hydro-Québec submitted its monthly general ledgers on time.

The majority of licensees were required to submit an implementation plan to satisfy the requirements of REGDOC-2.13.1, Safeguards and Nuclear Material Accountancy. CNSC staff found that the Gentilly-2 Facilities were compliant with the new regulatory document; no other measures were required.

In 2019, the IAEA carried out a physical inventory verification, a design information verification, and 2 unannounced inspections at the Gentilly-2 Facilities, the results of which the IAEA found satisfactory. CNSC staff did not take part in these verification and inspection activities.

Hydro-Québec submitted, on time, the required annual operational program with quarterly updates, as well as the annual update of the Additional Protocol to the CNSC. CNSC staff reviewed these documents and concluded that they met requirements and expectations. Hydro-Québec submitted an updated design information questionnaire in 2019. CNSC staff reviewed the document and concluded that it met requirements and expectations. The CNSC submitted the revised document to the IAEA in 2019.

Hydro-Québec responded to the IAEA’s 5 requests regarding repairs to IAEA equipment.

#### 3.8.14 Packaging and transport

CNSC staff concluded that Hydro-Québec met the applicable regulatory requirements, and that its performance met CNSC staff’s expectations, for the packaging and transport SCA at the Gentilly-2 Facilities in 2019.

## 4 Conclusions

CNSC staff concluded that the NPPs and the WMFs on their sites operated safely in 2019. This conclusion was based on detailed staff assessments of findings from compliance verification activities for each facility in the context of the 14 CNSC safety and control areas. The conclusion was supported by safety performance measures and other observations.

Important performance measures and observations include the following:

• The NPP and WMF licensees followed approved procedures and took appropriate corrective action for all events reported to the CNSC.
• NPPs and WMFs operated within the bounds of their operating policies and principles.
• No serious process failures occurred 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 also below the regulatory limits.
• The frequency and severity of non-radiological injuries to workers were low.
• No radiological releases to 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.

CNSC staff’s assessments for 2019 concluded that the licensees complied with the applicable requirements and also met CNSC staff’s expectations for all SCAs at all the NPPs and WMFs.

## 5 References

1. http://nuclearsafety.gc.ca/eng/resources/publications/reports/regulatory-oversight-reports/general-description-of-regulatory-framework-for-NPGS.cfm
2. CMD 19-M30, Regulatory Oversight Report for Canadian Nuclear Power Generating Sites: 2018.
3. CMD 17-M64, Presentation from CNSC Staff on Whole Site Probabilistic Safety Assessment (PSA).
4. CMD 19-H104, Ontario Power Generation Request to Revise the Darlington NGS Integrated Implementation Plan.
5. CMD 15-H111, Modification au permis de Gentilly-2 pour inclure le REGDOC-3.1.1.
6. Minutes of May 15, 2019 Commission Meeting.
7. CMD 20-M14, IAEA EPREV Mission to Canada 2019 Mission Findings and Canada’s Response.
8. CMD 19-H104, Record of Decision – OPG – Request to Revise the Integrated Implementation Plan for the Darlington NGS.

## Appendices

### A. Rating definitions and methodology

#### A.1 Definitions

The assessments of safety and control areas (SCAs) provided in this regulatory oversight report were developed by applying the following definitions to assess the specific areas that comprise the SCAs. CNSC staff rated certain specific areas for certain facilities in 2019 as “fully satisfactory.” However, due to the additional workload caused by the COVID-19 pandemic, CNSC staff did not assign “fully satisfactory” ratings at the SCA level in 2019 because of the limited opportunity to ensure the consistent application of criteria for this rating level across all SCAs.

Fully satisfactory (FS)
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)
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)
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)
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.

#### A.2 Rating methodology – General approach

The methodology for rating licensees relies on multiple sources of input and involves the judgment of CNSC staff. Both the specific areas and SCAs are rated. At the level of specific area, CNSC staff apply the above definitions by assessing both of the following:

• the licensee’s level of compliance with the requirements associated with the specific area
• the degree to which the licensee’s performance met CNSC staff’s expectations associated with the specific area

To obtain a certain rating category (such as “satisfactory”) for a specific area, the licensee must meet the criteria in the definition for both level of compliance and degree of performance.

After rating all the specific areas applicable to the licensee, CNSC staff combine them into composite ratings for the SCAs.

#### A.3 Detailed description of steps in rating methodology

##### Step 1: Identifying the findings

Findings are comparisons of observed facts with the applicable regulatory requirements. Findings are identified from CNSC staff inspections and other assessments. Each finding is assigned to the most applicable specific area under an SCA.

##### Step 2: Assessing the findings

CNSC staff evaluate the significance of each finding and assign it to the appropriate category: high, medium, low, negligible or compliant. The significance is determined in the context of the compliance verification criteria for the activity that generated the finding and depends on the degree to which a specific area’s effectiveness is negatively affected. The 5 categories of safety significance for findings are defined as follows:

High
The licensee’s measures are absent, completely inadequate or ineffective in 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: Assessing the level of compliance of the specific area

CNSC staff consider the safety significance of all relevant findings and assess the overall level of compliance with the applicable regulatory requirements for that specific area. In the absence of findings from regulatory activities in the year in question, CNSC staff may rely on findings from previous years if those findings are still considered applicable. CNSC staff choose one of the following statements, which are aligned with the definitions of the rating categories, to summarize the level of compliance for the specific area:

• effectively meets or exceeds all requirements
• meets requirements
• significant non-compliance
• unacceptable state of compliance
##### Step 4: Identifying additional performance information

CNSC staff identify additional information that, while not necessarily an indicator of compliance, does indicate the degree to which the licensee’s performance met CNSC staff’s expectations for the specific area. Examples of regulatory activities that yield performance information include surveillance and monitoring, and CNSC staff reviews of events, data (for example, safety performance indicators), licensees’ quarterly and annual reports, licensees’ corrective actions and document changes, and various other licensee submissions, such as those related to design and analysis.

##### Step 5: Assessing the level of performance of the specific area

CNSC staff consider all the performance-related information available and choose one of the following statements, which are aligned with the definitions of the rating categories, to summarize the level of compliance for the specific area:

• exceeds expectations
• meets expectations
• does not meet expectations
• unreasonable risk, high probability of hazards
##### Step 6: Rating the specific area

CNSC staff combine the 2 summary statements – for compliance and performance – and determine the specific area rating, using table A.1.

Table A.1: Minimum compliance and performance criteria for each rating category
Two criteria necessary Specific area rating
Compliance Performance
Effectively meets or exceeds all requirements Exceeds expectations FS
Meets requirements Meets expectations SA
Significant non-compliance Does not meet expectations BE
Unacceptable state of compliance Unreasonable risk, high probability of hazards UA

The criteria in both columns (for compliance and performance) must be met, in order to receive the rating indicated in the right-hand column. CNSC staff then fine-tune the rating for the specific area (high, medium and low, for the assigned criterion category) to allow finer delineation of how well the licensee met the requirements and/or expectations, within the category, for that specific area.

CNSC staff then convert the performance rating to a numerical value between 0 and 10, using the grid in table A.2. No values are identified for “unacceptable” ratings since that rating has not occurred in practice for NPPs and WMFs and would warrant special CNSC attention if it did occur.

Table A.2: Numerical values for rating categories for specific areas
Rating Specific area values
High FS 9.6
Medium FS 9.0
Low FS 8.3
High SA 7.6
Medium SA 7.0
Low SA 6.3
High BE 5.6
Medium BE 5.0
Low BE 4.3
##### Step 7: Rating the SCA

CNSC staff average the ratings of the applicable specific areas as a guide for determining the rating of the SCA.

Table A.3: Numerical ranges (guidance) for SCA rating categories
Average of specific area values Suggested rating
8–10 FS
6–8 SA
4–6 BE

In the final decision for the SCA rating, CNSC staff use judgment in conjunction with the category suggested by the arithmetic average of the specific area ratings.

As mentioned, CNSC staff did not assign “fully satisfactory” ratings at the SCA level in 2019, so “satisfactory” was the suggested rating when the average of the specific area ratings was above 6.

### B. List of regulatory requirements at the end of 2019

The following table lists published CNSC regulatory documents and CSA Group standards that contain compliance verification criteria used by CNSC staff for the safety and control areas covered in this regulatory oversight report. The information was compiled from the various facility LCHs as they existed in December 2019. Also, the main body of this report may include additional information related to the implementation of some of these documents, as well as more-recently published documents, which were not used for compliance verification purposes in 2019.

In the table, a check mark indicates that the publication was included as compliance verification criteria for the facility at the end of 2019, a dash indicates that the publication was not included as compliance verification criteria, and a date indicates the year when the licensee indicated it plans to fully implement the requirements in the publication.

Source Number Title Year SCA Bruce DNGS DWMF PNGS PWMF PLNGS Gentilly2 WWMF
CSA N286 Management system requirements for nuclear power plants, Update 1, 2007 2005 1 - - - - - -
CSA N286 Management system requirements for nuclear facilities 2012 1
CNSC REGDOC-2.2.2 Personnel Training 2014 2
CNSC REGDOC-2.2.2 Personnel Training, version 2 2016 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-2.1.2 Safety Culture 2018 2 1 1 1 1 - 1
CNSC REGDOC-2.2.4 Fitness for Duty Volume I: Managing Worker Fatigue 2017 2 2022 2019
CNSC REGDOC-2.2.4 Fitness for Duty Volume II: Managing Alcohol and Drug 2017 2 TBD2 TBD2 TBD2 TBD2 TBD2 TBD2 2019 TBD2
CNSC REGDOC-2.2.4 Fitness for Duty Volume III: 2018 2 TBD TBD TBD TBD TBD TBD TDB
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 3 - - - - -
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 - - -
CNSC REGDOC-2.4.2 Probabilistic Safety Assessment (PSA) for Nuclear Power Plants 2014 4 2020 - 2020 - - -
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 N289.2 Ground motion determination for seismic qualification of CANDU nuclear power plants 2010 5 - - - - - - -
CSA N289.3 Design procedures for seismic qualification of CANDU nuclear power plants 2010 5 - - - - - - -
CSA N289.4 Testing procedures for seismic qulaification of nuclear power plants structures, systems, and components 2012 5 - - - - - - -
CSA N289.5 Seismic instrumentation requirements for nuclear power plants and nuclear facilities 2012 5 - - - - - - -
CSA N290.13 Environmental Qualification of Equipment for CANDU Nuclear Power Plants (2005/R2015) 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 nuclear 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 - - - -
CSA N291 Requirements for safety related structures for CANDU nuclear power plants 2015 5 - - - - - - -
CNSC RD/GD-98 Reliability Programs for Nuclear Power Plants 2012 6 - - - - - -
CNSC REGDOC-2.6.1 Reliability Programs for Nuclear Power Plants 2017 6 - - - - -
CNSC RD/GD-210 Maintenance Programs for Nuclear Power Plants 2012 6 - - - - - -
CNSC REGDOC-2.6.2 Maintenance Programs for Nuclear Power Plants 2017 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 2015 6 - - - - - -
CSA N285.8 Technical requirements for in-service evaluation of zirconium alloy pressure tubes in CANDU reactors 2010 6 - - - - √ upd2 - -
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 airborne 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 airborne and liquid effluents for normal operation of nuclear facilities 2014 9 2021 - - -
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 - -
CNSC REGDOC-2.9.1 Environmental Principles, Assessments and Protection Measures, version 1.1 2017 9 2020 - 2022 - 2020 - - 2021
CSA N288.4 Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills 2010 9 -
CSA N288.5 Effluent monitoring programs at Class I nuclear facilities and uranium mines and mills 2011 9 -
CSA N288.6 Environmental risk assessments at Class I nuclear facilities and uranium mines and mills 2012 9 2020 -
CSA N288.7 Groundwater protection programs at Class I nuclear facilities and uranium mines and mills 2015 9 2020 2022 2022 2020 2020 2020 2021
CNSC RD-353 Testing and Implementation of Emergency Measures 2008 10 - - - - -
CNSC REGDOC-2.10.1 Nuclear Emergency Preparedness and Response 2014 10 2019
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 - - 2022 -
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 - √ upd1
CSA N290.7 Cyber Security 2014 12 2020 - 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 REGDOC-2.13.1 Safeguards and Nuclear Material Accountancy 2018 13 2019 2021 2021 2021 2021 2021
CNSC RD/GD-99.3 Public Information and Disclosure 2012 15

* CNSC staff documents (not published as regulatory documents)

### C. Current and predicted status of key parameters and models for pressure tubes in Canadian power reactor

Unit Status as of January 1, 2020 Future situation
EFPH Peak Heq concentration, ppm Existing fracture toughness model valid? Key date Anticipated EFPH Predicted maximum Heq conc., ppm Existing fracture toughness model valid?
Darlington Unit 1 212,718 114 Yes

Refurbishment

(February 2022)

229,000 ~120 No2
Darlington Unit 2

Refurbishment in progress

(started October 2016)

N/A – fuel channels replaced

during refurbishment

Darlington Unit 3 207,632 112 Yes

Refurbishment

(September 2020)

213,000 114 Yes
Darlington Unit 4 202,458 102 Yes

Refurbishment

(September 2023)

233,000 115 No2
Unit Status as of January 1, 2020 Future situation
EFPH Peak Heq concentration, ppm Existing fracture toughness model valid? Key date Anticipated EFPH Predicted maximum Heq conc., ppm Existing fracture toughness model valid?
Pickering Unit 1 151,116 67.4 Yes Dec 2024 192,100 88.2 No1
Pickering Unit 4 122,911 55.7 Yes Dec 2024 167,500 68.3 Yes
Pickering Unit 5 243,485 84.3 Yes Dec 2024 287,500 97.4 Yes
Pickering Unit 6 250,731 77.6 Yes Dec 2024 295,000 90.7 Yes
Pickering Unit 7 242,546 81.1 Yes Dec 2024 287,000 94.2 Yes
Pickering Unit 8 229,586 74.2 Yes Dec 2024 274,500 87.3 Yes
Unit Status as of January 1, 2020 Future situation
EFPH Peak Heq concentration, ppm Existing fracture toughness model valid? Key date Anticipated EFPH Predicted maximum Heq conc., ppm Existing fracture toughness model valid?
Bruce Unit 1 49,964 46.5 Yes

Time to reach 120 ppm Heq

(beyond EOL*)

>231,200 < 120 Yes
Bruce Unit 2 49,280 46.6 Yes

Time to reach 120 ppm Heq

(beyond EOL*)

>231,600 < 120 Yes
Bruce Unit 3 222,280 97.5 Yes MCR (2023) 247,400 < 120 Yes
Bruce Unit 4 217,067 94.8 Yes MCR (2025) 256,100 < 120 Yes
Bruce Unit 5 245,906 106.8 Yes December 2023 – first pressure tube reaches 120 ppm 275,000 120 ppm Yes – until December 20232
Bruce Unit 6 243,411 110.5 Yes N/A N/A N/A N/A
Bruce Unit 7 237,946 104.8 Yes

August 2024 – first pressure tube reaches

120 ppm

272,100 120 ppm Yes – until August 20242
Bruce Unit 8 225,388 88.0 Yes January 2027– first pressure tube reaches 120 ppm 275,400 120 ppm Yes – until January 20272

* EOL = end of life.

Unit Status as of January 1, 2020 Future situation
EFPH Peak Heq concentration, ppm Existing fracture toughness model valid? Key date Anticipated EFPH Predicted maximum Heq conc., ppm Existing fracture toughness model valid?
Point Lepreau 51108 54.3 Yes March 2045 235000 99 ppm Yes
1. The current fracture toughness model has been restricted to 80 ppm Heq for front end pressure tube material per CSA N285.8-15, Technical Requirements for In-Service Evaluation of Zirconium Alloy Pressure Tubes in CANDU Reactors, Update #1. Pickering Unit 1 contains 50% of tubes oriented with front end material at the outlet location.
2. Industry anticipates issuing a revised fracture toughness model by end of 2020.

### D. Derived release limits and radiological releases to the environment

#### Derived release limits

Licence release limits known as derived release limits (DRLs) are site-specifically calculated 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. DRLs are calculated using CSA N288.1-14, Guidelines for Calculating Derived Release Limits for Radioactive Material in Airborne and Liquid Effluents for Normal Operation of Nuclear Facilities.

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 based on factors such as physicochemical properties and method of monitoring. DRLs can then be established for the radionuclide group by applying a number of simplifying and conservative (that is, protective) assumptions such as the assumption that the group is composed entirely of the most restrictive radionuclide representative of the group. The most restrictive radionuclide can differ among nuclear facilities depending on releases, local conditions and the choice of the representative 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; the most common for liquid releases are beta/gamma and alpha emitters.

Licensees are required to demonstrate that their releases are not only below their respective DRLs but that the sum of their releases is below 1 mSv/year, the regulatory dose limit for the public. To ensure that these limits are respected, licensees are also required to develop action levels significantly below their DRLs as a means of detecting elevated releases meriting follow-up investigations and actions to ensure that releases are adequately controlled. For nuclear power plants, the action levels are applied to weekly and monthly monitoring results for emissions to the atmosphere and for effluent to surface waters, respectively.

Note that the DRLs shown in the tables of this appendix are applicable for 2019 and may not be applicable for previous years.

#### Total annual release of relevant radionuclides to the environment

CNSC staff have started publishing annual releases of radionuclides to the environment from nuclear facilities on the CNSC Open Government Portal.

The following tables provide the annual load of key radionuclides directly released to the atmosphere or to surface waters from licensed facilities along with the relevant DRL for the reporting period of 2011 to 2019. In 2012,  the CNSC published a report on radionuclide releases, which reported the radionuclide release data from Canadian nuclear generating stations covering the years 2001 to 2010. Over the current reporting period (2011 to 2019), there have been no exceedances of licence-derived release limits.

Facilities differ with respect to their onsite nuclear activities (such as presence of a tritium processing facility), life-stage activities (such as safe shutdown), or operations (such as maintenance or rates of power production). For this reason, the relevant radionuclides specifically monitored and reported on, as well as the actual quantities released, will vary. Nuclear facilities monitor and report on a wide range of radionuclides, and the standardized reporting provided here is based on the key radionuclides associated with public dose and the facilities’ DRLs. Therefore, direct comparisons between facilities are not possible, since one facility’s release quantities of radioactive materials may differ from another’s.

For the facilities associated with this regulatory oversight 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 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, bequerels-million electron volts (Bq-MeV). A becquerel is an SI (International System of Units) unit of radioactivity defined as the activity of a quantity of radioactive material in which 1 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 significant figures. For example:

100 = 1.0 X 102

1,260,000 = 1.2 X 106

4,445,758,748 = 4.4 X 109

#### D.1 Darlington site

In addition to the standard suite of radionuclides reported for nuclear power plant releases (tables D.1 and D.2), the Darlington site (DNGS and DWMF) also reports on atmospheric elemental tritium releases associated with the Tritium Removal Facility that is onsite. Note: The applicable DRLs for 2019 are also presented.

##### Releases to the atmosphere

Note: The DRL for elemental tritium is applicable to the Tritium Removal Facility.

Table D.1: Darlington site annual radionuclide releases to the atmosphere, 2011 to 2019
Year Elemental tritium (HT: Bq) Tritium: (HTO: Bq) Carbon-14 (Bq) Noble gas (Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/gamma) (Bq) Gross alpha (Bq)
2019 DRL 8.2 X 1017 4.9 X 1016 1.2 X 1015 3.8 X 1016 1.7 X 1012 6.1 X 1011 1.1 X 1011
2019 2.3 X 1013 2.0 X 1014 9.7 X 1011 5.0 X 1013 1.4 X 108 2.6 X 107 1.3 X 106
2018 4.7 X 1013 2.1 X 1014 8.4 X 1011 4.7 X 1013 1.4 X 108 2.5 X 107 1.0 X 106
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 1.8 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 D.2: Darlington site annual radionuclide releases to surface waters, 2011 to 2019
Year Tritium: (HTO: Bq) Gross beta/gamma (Bq) Carbon-14 (Bq) Gross alpha (Bq)
2019 DRL 6.4 X 1018 3.5 X 1013 7.0 X 1014 4.4 X 1014
2019 1.0 X 1014 2.3 X 1010 3.8 X 108 5.4 X 105
2018 2.2 X 1014 2.6 X 1010 1.2 X 109 <3.5 X 105
2017 5.6 X 1014 2.6 X 1010 1.7 X 109 <1 X 106
2016 3.5 X 1014 4.9 X 1010 2.2 X 109 1.2 X 106
2015 2.4 X 1014 4.9 X 1010 7.3 X 109 2.3 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

#### D.2 Pickering site

Releases at the PNGS are monitored and reported on separately for Pickering Units 1 and 4 and Pickering Units 5–8 (tables D.3 to D.7). Data on the PWMF is also rolled into the release information on Pickering Units 5–8. Note: The applicable DRLs for 2019 are also presented.

##### Releases to the atmosphere
Table D.3: Pickering Units 1 and 4, Pickering Units 5–8 and PWMF combined total annual radionuclide releases to the atmosphere for 2019
Year Tritium: (HTO: Bq) Carbon-14 (Bq) Noble gas (Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/gamma) (Bq) Gross alpha (Bq)
2019 DRL 1.0 X 1017 2.7 X 1015 2.7 X 1016 2.8 X 1012 4.3 X 1011 7.5 X 1010
2019 5.6 X 1014 2.6 X 1012 1.3 X 1014 1.4 X 107 5.7 X 106 1.1 X 106
Table D.4: Pickering Units 1 and 4 annual radionuclide releases to the atmosphere, 2011 to 2018
Year Tritium: (HTO: Bq) Carbon-14 (Bq) Noble gas (Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/gamma) (Bq) Gross alpha (Bq)
2018 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
2018 3.0 X 1014 2.3 X 1012 1.2 X 1014 7.0 X 106 4.2 X 106 4.3 X 105
2017 3.1 X 1014 1.3 X 1012 1.5 X 1014 9.6 X 106 6.9 X 106 4.7 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 D.5: Pickering Units 5–8 and PWMF annual radionuclide releases to the atmosphere, 2011 to 2018
Year Tritium: (HTO: Bq) Carbon-14 (Bq) Noble gas (Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/gamma) (Bq) Gross alpha (Bq)
2018 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
2018 3.2 X 1014 1.4 X 1012 5.0 X 1012 4.7 X 106 3.5 X 106 7.5 X 105
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 1–4 are included in the Unit 5–8 reporting as the radioactive liquid waste management system is discharged through the outfall for units associated with Units 5–8.

Table D.6: Pickering Units 1–4, Pickering Units 5–8 and PWMF combined total annual radionuclide releases to surface water for 2019
Year Tritium: (HTO: Bq) Gross beta/gamma (Bq) C-14 (Bq) Gross alpha (Bq)
2019 DRL 7.9 X 1017 3.8 X 1013 3.8 X 1013 2.4 X 1010
2019 4.3 X 1014 7.8 X 1010 3.4 X 109 2.3 X 106
Table D.7: Pickering Units 1 and 4, Pickering Units 5–8 and PWMF annual radionuclide releases to surface waters, 2011 to 2018
Year Units 1–4 Units 5–8 and PWMF
Tritium: (HTO: Bq) Gross beta/ gamma (Bq) Tritium: (HTO: Bq) Gross beta/ gamma (Bq) C-14 (Bq) Gross alpha (Bq)
2018 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
2018 1.4 X 1014 9.3 X 109 2.8 X 1014 3.4 X 1010 1.1 X 109 1.8 X 106
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 1.2 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 107

#### D.3 Bruce A and B

Bruce Power reports releases from Bruce A and Bruce B (tables D.8 to D.11). The releases for the WWMF, which is on the same site, are reported by OPG (section D.4, below). Note: The applicable DRLs for 2019 are also presented.

##### Releases to the atmosphere
Table D.8: Bruce A annual radionuclide releases to the atmosphere, 2011 to 2019
Year Tritium: (HTO: Bq) Carbon-14 (Bq) Noble gas (Bq-MeV) Iodine-131 (Bq) Particulate (beta/gamma) (Bq) Gross alpha (Bq)
2019 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
2019 4.63 X 1014 1.34 X 1012 7.07 X 1013 4.17 X 107 1.97 X 106 2.43 X 104
2018 6.08 X 1014 1.14 X 1012 8.46 X 1013 6.57 X 106 1.28 X 106 1.10 X 104
2017 7.32 X 1014 1.89 X 1012 9.48 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 10 14 3.15 X 1012 5.62 X 1013 5.15 X 107 1.06 X 107 1.23 X 106
2014 7.51 X 10 14 1.64 X 1012 5.30 X 1013 3.94 X 108 3.13 X 106 8.02 X 105
2013 5.04 X 10 14 2.53 X 1012 6.66 X 1013 <4.94 X 107 <4.84 X 106 <6.67 X 105
2012 4.50 X 10 14 2.30 X 1012 6.82 X 1013 2.18 X 108 <7.45 X 106 <6.40 X 105
2011 6.00 X 10 14 1.36 X 1012 6.68 X 1013 3.58 X 107 <7.06 X 106 <5.99 X 105
Table D.9: Bruce B annual radionuclide releases to the atmosphere, 2011 to 2019, with weekly releases provided for 2019
Year Tritium: (HTO: Bq) Carbon -14 (Bq) Noble gas (Bq-MeV Iodine-131 (Bq) Particulate (gross beta/ gamma) (Bq) Gross alpha (Bq)
2019 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
2019 3.30 X 1014 1.08 X 1012 3.39 X 1013 4.40 X 105 4.76 X 106 2.63 X 104
2018 3.86 X 1014 1.13 X 1012 4.24 X 1013 3.43 X 106 2.21 X 106 2.37 X 104
2017 7.14 X 1014 1.23 X 1012 4.82 X 1013 1.41 X 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 106 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 5.25 X 1013 4.02 X 107 1.53 X 107 2.26 X 106
2013 2.63 X 1014 1.10 X 1012 3.71 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 D.10: Bruce A annual radionuclide releases to surface waters, 2011 to 2019
Year Tritium: (HTO: Bq) Gross beta/gamma (Bq) Carbon-14 (Bq) Gross alpha (Bq)
2019 DRL 2.30 X 1018 4.58 X 1013 1.03 X 1015 1.12 X 1014
2019 2.12 X 1014 2.13 X 109 8.17 X 108 <LDa
2018 1.96 X 1014 1.20 X 109 9.73 X 108 <LDa
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 9.08 X 108 9.95 X 108 2.12 X 106
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 D.11: Bruce B annual radionuclide releases to surface waters for 2011 to 2019
Year Tritium: (HTO: Bq) Gross beta/gamma (Bq) Carbon-14 (Bq) Gross alpha (Bq)
2019 DRL 1.84 X 1018 5.17 X 1013 1.16 X 1015 1.21 X 1014
2019 8.82 X 1014 2.26 X 109 4.68 X 109 <LDa
2018 5.60 X 1014 2.55 X 109 1.38 X 109 <LDa
2017 7.15 X 1014 2.04 X 109 2.39 X 109 <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 109 8.91 X 106
2012 1.14 X 1015 3.35 X 109 4.63 X 109 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

#### D.4 Western Waste Management Facility

The Western Waste Management Facility is located on the Bruce site. Data on the RWOS-1 are also rolled into the release information tables (D.12 and D.13). Note: The applicable DRLs for 2019 are also presented in the tables.

##### Releases to the atmosphere
Table D.12: Western Waste Management Facility annual radionuclide releases to the atmosphere, 2011 to 2019
Year Tritium: (HTO: Bq) Carbon -14 (Bq) Iodine-131 (Bq) Particulate (gross gamma) (Bq)
2019 DRL 2.96 X 1017 1.09 X 1015 1.90 X 1012 2.34 X 1012
2019 1.03 X 1013 2.62 X 109 0 6.52 X 102
2018 3.25 X 1012 1.57 X 109 7.23 X 104 2.41 X 104
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 1.57 X 109 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 D.13: Western Waste Management Facility annual radionuclide releases to surface waters, 2011 to 2019
Year Tritium: (HTO: Bq) Gross beta (Bq)
2019 DRL 7.70 X 1015 4.46 X 1011
2019 1.60 X 1011 7.08 X 107
2018 3.64 X 1011 1.69 X 108
2017 2.59 X 1011 2.84 X 108
2016 6.12 X 1011 4.62 X 108
2015 4.29 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

#### D.5 Point Lepreau site

The Point Lepreau Nuclear Generating Station, consisting of a single reactor unit, 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 have been combined as total noble gases and total particulate in the tables below (tables D.14 and D.15). Note: The applicable DRLs for 2019 are also presented.

##### Releases to the atmosphere
Table D.14: Point Lepreau annual radionuclide releases to the atmosphere, 2011 to 2019
Year Tritium: (HTO: Bq) Carbon-14 (Bq) Noble gas (Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/gamma) (Bq)
2019 DRL 2.4 X 1017 1.2 X 1016 a 6.3 X 1013 a
2019 2.5 X 1014 2.8 X 1011 2.9 X 1013 2.7 X 107 <1.1 X 108
2018 1.4 X 1014 3.3 X 1011 2.5 X 1013 1.3 X 106 <2.2 X 106
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 --- --- ---
1. a. Specific DRLs are calculated for a range of noble gas and particulate categories. None of these individual DRLs were exceeded.
##### Releases to surface waters
Table D.15: Point Lepreau annual radionuclide releases to surface waters, 2011 to 2019
Year Tritium: (HTO: Bq) Gross beta (Bq) Carbon-14 (Bq) Gross alpha (Bq)
2019 DRL 4.5 x 1019 a 3.7 x 1014 a
2019 3.4 X 1014 8.4 X 107 7.6 X 109 1.3 X 107
2018 2.4 X 1014 9.7 X 107 4.9 X 109 1.7 X 107
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. Specific DRLs are calculated for a range of noble gas and particulate categories.

#### D.6 Gentilly-2 Facilities

The Gentilly-2 Nuclear Generating Station (now called Gentilly-2 Facilities) was permanently shut down in December 2012. Since then, activities conducted by Hydro-Québec have been to stabilize and transition the facility to safe storage. Note: The applicable DRLs for 2019 are also presented in tables D.16 and D.17).

##### Releases to the atmosphere
Table D.16: Gentilly-2 Facilities annual radionuclide releases to the atmosphere, 2011 to 2019
Year Tritium: (HTO: Bq) Carbon-14 (Bq) Noble gas (Bq-MeV) Iodine-131 (Bq) Particulate (gross beta/ gamma) (Bq)
2019 DRL 1.7 x 1017 1.2 x 1015 NA1 NA1 8.0 x 1011
2019 7.21 X 1013 2.70 X 1010 <LDa <LDa 9.49 X 105
2018 9.17 X 1013 4.63 X 1010 <LDa <LDa 2.15 X 106
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

1. Not applicable as facility is in safe shutdown.

a = less than analytical detection limit.

##### Releases to surface waters
Table D.17: Gentilly-2 Facilities annual radionuclide releases to surface waters, 2011 to 2019
Year Tritium: (HTO: Bq) Gross beta (Bq) Carbon-14 (Bq)
2019 DRL 1.1 x 1019 5.3 x 1013 7.3 x 1014
2019 8.22 X 1013 3.47 X 107 1.90 X 108
2018 5.46 X 1013 2.51 X 107 1.71 X 108
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

## Footnotes

Footnote 1

Bruce A and B are operated by Bruce Power, while the WWMF is operated by OPG under a separate licence.

Footnote 2

Setbacks and stepbacks are automated power reductions (setbacks are slower; stepbacks are faster) intended to eliminate potential risks to plant operations. Trips that are included as “unplanned” include reductions initiated by any of a reactor’s safety circuits to rapidly shut down the reactor. Manual reactor trips or trips during commissioning testing are excluded.

Footnote 3

New, compared to requirements in S-294.