Darlinnton NGS 'A' - Application for Renewal of Darlinnton Nuclear Generatinq Station Power Reactor Operating Licence

Transcription

1 GENERATION S.A. Seedhouse Senior Vice President Darlington Nuclear P.O. Box 4000, Bowmanville, ON L1C 328 Tel: Fax: stuseed June 28,201 1 NK P NK38-CORR P Mr. M. Leblanc Commission Secretary Canadian Nuclear Safety Commission 280 Slater Street P.O. Box 1046, Station B Ottawa, ON K1P 5S9 Dear Mr. Leblanc: Darlinnton NGS 'A' - Application for Renewal of Darlinnton Nuclear Generatinq Station Power Reactor Operating Licence Further to Reference 1, the purpose of this letter is to apply for a Power Reactor Operating Licence (PROL) renewal for Darlington Nuclear Generating Station (NGS). The current PROL 13.15/2013 expires on February 28, This application is being submitted in accordance with the applicable Regulations under the Nuclear Safety and Control Act by Ontario Power Generation Incorporated, a Canadian corporation located at 700 University Avenue, Toronto, Ontario, M5G 1x6. As previously communicated in Reference 1, Ontario Power Generation () is currently preparing for the refurbishment of the Darlington NGS facility. Studies are in progress to determine the regulatory scope of the refurbishment outage, including an Environmental Assessment and an Integrated Safety Review. The scope and schedule of required activities will be documented in an Integrated Implementation Plan. A renewal of the Darlington PROL up until December 31, 2014 would provide the time required to complete the studies and submit the necessary information to support a licence renewal application for the period encompassing the refurbishment outages. The Darlington NGS facility consists of four nuclear reactors and their associated equipment, designed, constructed, and operated to produce electrical power. Darlington NGS also includes the Tritium Removal Facility (TRF). The TRF is designed, constructed, and operated to reduce the tritium levels in 's Nuclear Generating Station's heavy water inventories. 8 Ontario Power Generation Inc., This document has been produced and distributed for Ontario Power Generation Inc. purposes only. No part of this document may be reproduced, published, converted, or stored in any data retrieval system, or transmitted in any form or by any means (electronic, mechanical, photocopying, recording, or otherwise) without the Drior written Dermission of Ontario Power Generation Inc. CIO-TMP-CS-009-ROO0 (Microsoft@ XP)

2 Mr. M. Leblanc NK38-CORR P June 28,201 1 The management and control of operation of the Darlington NGS facility and the nuclear substances, prescribed equipment, and prescribed information associated therewith is the overall responsibility of Mr. Stu Seedhouse, Senior Vice-president, Darlington Nuclear. As documented in Reference 2, provided a list of persons authorized to act on behalf of in dealings with the CNSC. In the CNSC Annual Industry Reports issued during the current licensing period, Darlington NGS was assessed to be operating safely, with adequate provisions to protect the health and safety of Canadians and the environment, as well as to ensure Canada continues to meet its international obligations on the peaceful use of nuclear energy. The CNSC integrated plant rating for Darlington NGS for 2009 and was Fully Satisfactory and all safety areas and programs were rated either Satisfactory or Fully Satisfactory. As confirmed by in Reference 3 and accepted by CNSC staff in Reference 4, as of December 31, 2010, Darlington NGS is compliant with the CSA standard N and Update No. 1, Environmental Qualification of Equipment for CANDU Nuclear Power Plants, The applicable Regulations under the Nuclear Safety and Control Act require specific information to be contained in an application for a licence renewal. The required information is provided in the attachments of this letter. To assist CNSC staffs review, Attachment 1 describes the location of the specific information found in Attachments 2 to 5. This application for a licence renewal up until December 31, 2014, reports on the status of programs for the 14 Safety and Control Areas (SCA), including areas not covered in detail in the 2007 submission (Reference 5): the Waste Management SCA including Decommissioning Planning and the Packaging and Transport SCA. CNSC approval of s application for Darlington NGS PROL renewal, up until December 31,2014 is hereby requested. Any questions or requests for further information should be directed to Mr. Doug Coleman, Acting Manager - Regulatory Affairs, at (905) ext SA. Seedhouse Senior Vice President Darlington Nuclear Ontario Power Generation Inc. Attach. cc: Mr. P.A. Webster, CNSC (Ottawa) Mr. A. Ling, CNSC (Darlington) CIO-TMP-CS-009-ROO0 (MicrosofiG3 XP) Page 2 of 3

3 Mr. M. Leblanc NK38-CORR P June 28,201 1 References: 1. letter, S.A. Seedhouse to M.A. Leblanc, Darlington NGS A- Request for Renewal of Power Reactor Operating Licence 13.13/2013, February 17,2011, CD# NK38-CORR letter, Richard MacEacheron to M. Santini, P.A. Webster and D. Howard, Persons Authorized to Act on Behalf of in Dealings with the CNSC, May 13,201 1, CD# N-CORR letter, S.A. Seedhouse to P.A. Webster, Darlington NGS A - Information Regarding the Environmental Qualification Program Requirements of PROL Licence Condition 7. I, October 1, 201 0, CD# NK38-CORR CNSC letter, P.A. Webster to S.A. Seedhouse, Darlington NGS A - Information Regarding the Environmental Qualification Program Requirements of PROL License Condition 7.1, November 25, 2010, E-DOCS # , CD# NK38-CORR letter, Wayne Robbins to M.A. Leblanc, Darlington NGS - Application for Renewal of Darlington Nuclear Generating Station Power Reactor Operating Licence, March 29, 2007, CD# NK38- CORR CIO-TMP-CS-009-RO00 (Microsoft@ XP) Page 3 of 3

4 ATTACHMENT 1 letter S.A. Seedhouse to M. Leblanc, Darlington NGS A -Application for Renewal of Darlington Nuclear Generating Station Power Reactor Operating Licence CD# NK38-CORR Licence Renewal Application Matrix

5 ~ Attachment 1 Applicable Information Provided to Support Regulation Related Safety Where to find Regulations Requirements Control Area reference: G3. (1)(a) Applicant's name and business address NIA Letter (33.(1)(b) Facility and activity to be licensed NIA Letter Names of persons who have authority to act for the G15.(a) licensee in their dealings with the Commission NIA Letter Site plan and site description documentation and, C3'(a)' C3'(b) land ownership and control documentation NIA Attach men t 2 Evidence that the applicant is the owner of the site or C3.(c ) has authority from the owner of the site to carry out NIA Attach men t 3 1 the activity to be licensed Attachment 4 G3.(1)(k)' G1 5'(b) C3.(d) C6.(m), C6.(n) C6.(d) G3'(1)(i)' C6.(c), C6.(h) G3.( l)d, C6.(a), C6.(b), C6.(g) C6.(d) G3.(1)(7)' C6.(e 1 G3.(l)(f) I Action Levels c3.m C3.(e), C3.(g), C3.(j), C6.(h),C6.(i), Organizational structure; names and position titles of the persons who are responsible for the management and control of the licensed activity System Quality Assurance Program Section 2 Staffing and Training Programs Human Attachment 4 Performance Section 3 Management Operations Program Operating Attachment 4 Performance Section 4 Safety Program, Analysis and Risk Management Safety Analysis Attac hmen t 4 Section 5 Design Program, Engineering Change Control, Physical Attach m e n t 4 Pressure Boundary Design Section 6 Maintenance Program, Outage Management, Fitness for Attachment 4 Periodic Inspection Program, Reliability Program, Service Section 7 Environmental Qualification Program Radiation Protection Program Attach men t 4 Radiation Section 8 Attachment 4 Health and Safety Policies and Procedures I Protection I Section a Conventional Health and Safety Attachment Section 9 Environmental Protection Program, Effluent and Environmental Attachment 4 Environmental Monitoring Program Protection Section 10 I C6.(k) G3.(l)(j) G3.(1), G3.(k) Emergency Management Program, Fire Protection Emergency Management Attachment 4 Program and Fire Section 11 Protection Waste Management Program Attachment 4 Waste Section 12 Decommissioning Planning Management Attachment 4 Section 12 Page 1 of 2

6 . 1 Applicable 1 Information Provided to Support Regulation Regulations ~3.(i)(e), 1 G3'i1jigj' I Nuclear Security Program. I. G3.(l)(h), C3.(i), C6.(1) G3'(1)(y )I C6.(e C6.(f), G3.(l)(g), G3.( 1 )( h) C6.(e) Requirements Nuclear Substance Control Program Nuclear Safeguards Program Radioactive Material Transportation Program Related Safety I Where to find I Control Area Security Safeguards Packaging and Transport reference: Attachment 4 Section 13 Attachment 5 Attach men t 4 Section 14 Attachment 4 Section 15 G - General Nuclear Safety and Control Regulations N/A - Not Applicable C - Class I Nuclear Facility Regulations Page 2 of 2

7 ATTACHMENT 2 letter S.A. Seedhouse to M. Leblanc, "Darlington NGS 'A' -Application for Renewal of Darlington Nuclear Generating Station Power Reactor Operating Licence" CD# NK38-CORR Site Description and Plan This attachment provides references to a description of the Darlington NGS facility site, including the plan showing the location of the exclusion zone and structures within that zone.

8 Attachment 2 Site Description and Pian 1. The Darlington NGS facility site is described in the Darlington Nuclear Generating Station Safety Report, NK38-SR R003, (Reference [AI]): Part 1 - Plant/Site Description - Section 1 Introduction and Description of Plant Part 2 - Design Description - Structures, Systems and Components 2. The nuclear facility is located on the north shore of Lake Ontario in the township of Darlington, in the Municipality of Clarington, in the Regional Municipality of Durham, Province of Ontario, as showed in: i. ii. Ontario Hydro layout Drawing number NK38-DOH , Rev 9, November 1981, and Ontario Hydro layout Drawing number NK38-DOH , Rev 4, March The location of the exclusion zone and any structures within the zone are found in Drawing number LO4254 DZS , being a plan of survey dated June 7, 1999, prepared by J.D. Barnes Limited, Ontario Land Surveyors, and certified by S. E. Coons, O.L.S. Reference: [AI] Letter, S.A. Seedhouse to P.A. Webster, Darlington NGS A - Safety Report Update, Part 1 and 2, December 23,201 0, CD# NK38-CORR

9 ATTACHMENT 3 letter S.A. Seedhouse to M. Leblanc, "Darlington NGS 'A -Application for Renewal of Darlington Nuclear Generating Station Power Reactor Operating Licence" CD# NK38-CORR Land Ownership and Control This attachment provides evidence that Ontario Power Generation Inc. is the owner of the Darlington NGS facility site, and has the authority to carry on the activity to be licensed.

10 Attachment 3 Land Ownership and Control With reference to Ontario Power Generation Inc. () providing evidence of site ownership, or authority to carry on the activity to be licensed, as required by the Class I Nuclear Facilities Regulations, clause 3.(c), supporting material in that regard was previously submitted to the CNSC in Reference [Bl]. The latest revision of Volume 1, Parts 1 and 2, of the Darlington Safety Report, NK38-SR R003, submitted to CNSC staff (Reference [B2]) captures the information provided above. Furthermore, confirms that no change or amendment has taken place with respect to such material since the issue of the updated Safety Report. References: [BI] Letter, T. Mitchell to I. Grant and B. Howden, Ontario Power Generation lnc. - Articles of Amalgamation, February 19, 2007, CD# N-CORR [B2] Letter, S.A. Seedhouse to P.A. Webster, Darlington NGS A - Safety Report Update, Part 1 and 2, December 23, 2010, CD# NK38-CORR

11 ATTACHMENT 4 letter S.A. Seedhouse to M. Leblanc, Darlington NGS A - Application for Renewal of Darlington Nuclear Generating Station Power Reactor Operating Licence CD# NK38-CORR Station Programs and Performance 1.o Introduction Management System Human Performance Management Operating Performance Safety Analysis Physical Design Fitness for Service Radiation Protection Conventional Health and Safety Environmental Protection Emergency Management and Fire Protection Waste Management (including Decommissioning Planning) Security Safeguards Packaging and Transport

12 1.o INTRODUCTION 1.I Application for Licence Renewal The Power Reactor Operating Licence (PROL 13.15/2013, as amended) for Darlington Nuclear Generating Station (NGS) issued to Ontario Power Generation Inc. () will expire on February 28, is applying to the CNSC for a renewal of the Darlington PROL to December 31, 2014, which is 22 months beyond the end date of the current licence. The application provided for the licence renewal is in accordance with the requirements of the Nuclear Safety and Control Act (NSCA) and its associated Regulations. The purpose of this application is to demonstrate that is: qualified to operate the facilities, and will, in operating the facilities, make adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed. This attachment includes pertinent information on the status of programs and station performance in the Safety and Control Areas (SCA). The material is generally grouped and presented in the same order as defined in the CNSC Regulatory Instruments Index (RII): Management System Human Performance Management Operating Performance Safety Analysis Physical Design Fitness for Service Radiation Protection Conventional Health and Safety Environmental Protection Emergency Management and Fire Protection Waste Management (including Decommissioning Planning) Security Safeguards Packaging and Transport Page 1 of 54

13 For most SCAs, a thorough assessment of programs and station performance was presented in support of the 2008 Darlington NGS Licence Renewal review process, and during the mid-term review Darlington NGS Status Report on New Licence Conditions and 3-Year Outage Cyde (Commission Member Document (CMD) 10-M22) presented during an April 8, Public Commission Meeting. Darlington NGS continues to perform well during the current licensing period. There have been no serious process system failures. No worker or member of the public received a radiation dose in excess of regulatory limits and all environmental emissions have been well below regulatory limits and station action levels. This application for a licence renewal, which extends the licence end date by 22 months, builds on the submissions supporting the current licence (listed in the table below), and briefly reports on the status of programs for each of the fourteen SCAs. For further assurance of compliance with the SCAs, additional information is provided in the areas of Radiation Protection and Conventional Health and Safety, and the SCAs not covered in detail during previous submissions; Le., Waste Management (including Decommissioning Planning), and Packaging and Transport. 1.I.I Key Submissions Supporting the 2008 Darlington NGS Licence Renewal s key submissions to support the 2008 Darlington NGS Licence Renewal review process, including responses to CNSC staff requests for clarifications, updates or additional information, are listed in the following table: Darlington NGS - Application for NK38-CORR Renewal of Darlington Nuclear Generating Station Power Reactor Operating Licence Darlington NGS Application for N-CORR Renewal of Operating License - Updated Information on Large Break LOCA (LBLOCA) Safety Margins Action Item # Darlington NGS - Licence NK38-CORR Renewal - Additional Information and Clarification Required for the Review of the Darlington Fire Protection Proaram Darlington NGS- Application for NK38-CORR Renewal of Operating Licence - Update of Information on Reactor Core Nuclear Design - Action Item # Darlington NGS - Licence Renewal - Status of Additional Information Requests and Reauests for New Information Staffing Levels and Organization Structure at the Darlington Nuclear Generating Station NK38-CORR N-CORR NIA NIA NIA NIA NIA NIA ~~ Page 2 of 54

14 I Document Number Revision # Effective Date Darlington NGS - Licence Renewal - Darlington Orqanization Chart Darlington NGS - Licence Renewal Application - Supplementary Material for Day 1 Hearing - November 1,2007 Darlington NGS Licence Renewal Day 2 Hearing - Nuclear Security Submission - December IO Darlington NGS Application for Renewal of Operating Licence - Updated Information on Large Break LOCA (LBLOCA) Safety Margin Darlington NGS - Licence Renewal - Submission of Further Information Requested at Day 1 Public Hearing NK38-CORR Note 1 NK38-CORR NK38-CORR (protected) N-CORR NIA N/A N/A N/A NK38-CORR NIA I I All documents listed on the following pages have been submitted to the CNSC. Corporate governing documents are routinely submitted as they are revised. Revisions listed herein are current as of June 17, Note 1 - Updated annually pursuant to Licence Condition 2.2: latest version Darlington NGS A- Organizational Changes - Annual Update Report for 2010, NK38-CORR , January 26,2011 Page 3 of 54

15 2.0 MANAGEMENT SYSTEM 2.1 Nuclear Management System 2.1.I Objectives The Nuclear Management System fosters nuclear safety as the overriding priority. The objective of the Management System is to ensure Nuclear facilities are operated and maintained using sound nuclear safety and defence-in-depth practices to ensure radiological risks to workers, the public, and environment are as low as reasonably achievable, and in keeping with the Nuclear Safety Policy and the best practices of the international nuclear community. The Nuclear Management System fulfills the requirements of Canadian Standards Association (CSA) N285 and N286 standards, International Organization for Standardization (ISO) series of standards, and the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Nuclear Code Article NCA The Nuclear Management System Charter, N-CHAR-AS-0002, and the supporting documents identified in the CSA N to N Governance Cross Matrix, demonstrate compliance with CSA N286-05, Management System Requirements for Nuclear Power Plants. The Nuclear Management System further assures that safety-related Systems, Structures, and Components (SSCs) and nuclear fuel are designed, procured, fabricated, installed, operated, and maintained in accordance with applicable regulations, standards, and fuel performance limits, using rigorous processes to ensure all work activities are planned and controlled to maintain plant configuration and condition within the design basis. Changes that could impact nuclear safety are assessed and implemented in a controlled manner. Nuclear Management System deficiencies or deviations are managed through the Nuclear Corrective Action Program. Every employee in the organization is responsible and held accountable for complying with the expectation of N-CHAR-AS-0002 and referenced programs, and for ensuring their actions are deliberate and consistent with protecting worker health and safety, the health and safety of the public, and the environment. The Nuclear Management System principles are communicated and reinforced by all levels of management in the organization Nuclear Safety Policy N-POL-0001, Nuclear Safety Policy, establishes guiding principles for Nuclear employees and those working on Nuclear s behalf. The policy states that nuclear safety shall be the overriding priority in all activities performed in support of nuclear facilities. Nuclear safety shall have clear priority over schedule, cost and production. The requirements of the policy are set out below. Everyone shall demonstrate respect for nuclear safety by: Page 4 of 54

16 Knowing how your work impacts on Control the power, Cool the fuel and Contain radioactivity (3C's). Applying Event-Free tools and defences to prevent events. Reporting adverse conditions so they can be corrected. Everyone shall conduct themselves in a manner consistent with the principles for a strong nuclear safety culture, set out in the policy Key Governing Documents 's key documents for the Management System SCA are listed in the table presented below. Nuclear Management System N-CHAR-AS-0002 R014 CSA N to N N-LIST ROO2 Governance Cross Matrix Nuclear Safetv Policv N-POL-0001 ROO I Managed Systems I N-PROG-AS-0001 I R013 I Records and Document Control N-PROG-AS-0006 ROO Corrective Action N-PROG-RA-0003 ROO Letter "Persons Authorized to Act N-CORR N/A on Behalf of in Dealings with the CNSC" I Nuclear Safety Oversight I N-STD-AS-0023 ROO I Conventional Safety [ N-PROG-HR-0004 I ROO2 I Shift Manager, Darlington Nuclear N-MAN ROOO CNSC-006 Control Room Shift Supervisor, N-MAN ROOO Darlington Nuclear CNSC-008 Unit 0 Control Room Operator N-MAN ROOO CNSC-025 Authorized Nuclear Operator N-MAN ROOO CNSC Performance Radiation Protection N-RPP ROO Requirements - Nuclear Facilities Nuclear implemented CSA N286-05, Management System Requirements for Nuclear Power Plants in accordance with station PROLs in March, The Quality Page 5 of 54

17 Program is reflected by the Management System requirements set out in N-CHAR-AS In particular, the CSA N to N Governance Cross Matrix, N-LIST , is referenced in the Charter. This document was initially created during gap analysis to the newer standard, and has proved to be a useful communication tool for the organization. N-LIST is being maintained as an active cross reference between N requirements and N governance. In some cases, N requirements are met in lower level governance, such as procedure or instruction level documents. Over the normal review cycle for program level documents, is ensuring that the requirements of N are captured in the higher tiered document level of N-CHAR-AS-0002 or associated Nuclear programs (N-PROG). Where necessary, lower level documents will continue to capture more detailed instructions on how to carry out the requirements. Audits of N-CHAR-AS-0002 and the related activities are performed by the Nuclear Oversight organization in accordance with N-PROG-RA-0010, "Independent Assessment". The program includes prescribed frequencies for audits: with the exception of those programs which require annual audits to be performed in accordance with specific standards, the managed processes are subject to audit once every three years. 's Corrective Action Program ensures deficiencies, non-conformances or conditions that adversely impact, or may adversely impact operations, personnel, nuclear safety, the environment, or equipment and component reliability, are promptly identified and corrected. The Corrective Action Program also provides the processes to ensure in-house and external Operating Experience (OPEX) is evaluated, distributed to appropriate personnel, and applied to implement actions that improve plant safety and reliability. Alliances with a number of industry peer groups have enabled the participation of employees on external assessments, thus creating good opportunities for growth and benchmarking. Peers from other utilities have had similar opportunities in. These relationships and external experiences are important in ensuring that Nuclear remains abreast of best industry practices in all areas of operation. Pursuant to Licence Condition 2.2 of the current Darlington PROL, Darlington submits an annual summary of all organizational changes carried out during the year, and an annual update of the nuclear organization chart including certified staff. The latest updates were submitted to CNSC staff on January 26,201 1 in NK38-CORR , "Darlington NGS 'A' - Organizational Changes - Annual Update Report for 201u. Page 6 of 54

18 3.0 HUMAN PERFORMANCE MANAGEMENT 3.1 Human Performance Program Objectives The objective of the Human Performance Program is to continually reduce the frequency and severity of events, through the systematic reduction of human error, and the management of defences in pursuit of zero events of consequence. The Human Performance Program additionally focuses on the requirement to proactively identify and address latent organizational weaknesses, which are hidden deficiencies in management control processes (e.g., strategy, policies, work control, training, and resource allocation) or values (shared beliefs, attitudes, norms, and assumptions) creating workplace conditions that can provoke error (precursors) and degrade the integrity of defences (flawed defences). Self-assessments are conducted to achieve continuous improvement. Current performance is compared to management expectations, industry standards of excellence, and regulatory requirements. The Human Performance Program integrates these principles with supporting tools and techniques into all activities. Human Performance Strateaies s human resources management strategy focus is to: 0 Support business planning needs and continued availability of trained and qualified staff to operate maintain and support Darlington NGS performance. 0 Retain, develop and plan the succession of employees to ensure continued capability of key resources. Support the business to drive improvement in employee engagement. has ongoing integrated workforce development strategies that consider various business needs, as follows: 0 works with educational institutions across the province to secure a sustained pool of candidates for Engineering, Operations and Maintenance positions. For example, collaborative partnerships have been established with the University of Ontario Institute of Technology and Durham College to support program development. 0 Working relationships have been established with local Trade Union Halls to secure augmented staff for outage and project work. 0 Qualification training programs have been implemented for Engineering, Operations and Maintenance staff as well as developmental programs for Engineering new graduates and Maintenance apprentices. Page 7 of 54

19 ~ Key Governing Documents s key documents for the Human Performance Management SCA are listed in the table presented below. The Human Performance Management Framework, which lays the groundwork for improving and sustaining performance, is set out in the program document. Document Num HUMAN PERFORMANCE I Human Performance I N-PROG-AS-0002 I R012 I Continuous Behaviour N-CMT ROO1 Observation Program (CBOP) - Participants Materials - Workbook Components Leadership and Management N-TQD R013 Training and Qualification Description Station Shift Complement D-PROC-OP-0009 Nuclear Pandemic Plan N-PROG-RA-0018 ROO ROO Training N-PROG-TR-0005 R012 Systematic Approach to Training N-PROC-TR-0008 R Written and Oral Initial N- I NS Certification Examination for Shift Personnel Simulator-Based Initial N-INS Certification Examinations for Shift Personnel ROO ROO Requalification Testing of N-INS Certified Shift Personnel ROO Performance At Darlington Nuclear, human performance continues to be a major focus area of the station improvement plan. The methodology used is based on the Institute of Nuclear Power Operations (INPO) Performance Model that established the feedback loop based on the four quadrants of Job Site Conditions, Worker Behaviours, Organizational Factors, and Plant Results under a central driver of Leadership. Page 8 of 54

20 Improvements are based on the Accountability Model of Say It, Do It. Accountability at means we deliver committed actions that achieve the desired results. The Accountability Model is comprised of three focused areas: 0 Leadership Courage - speaking up when something is not right. 0 Leadership Presence - being present in the workplace; seeing what people are doing and knowing that things are being done right. 0 Managerial Effectiveness - making sure people know expectations about doing work right, safely and right the first time. Nuclear uses Site Event Free Day Resets (EFDRs) as an indicator of human performance effectiveness. Events that exceed an internal threshold documented in governance reset the event free day count. Figure 1 shows an improving trend in human performance. Figure 1 - Darlington Site Event Free Day Resets I I I I good EZEDActual +Target Year Nuclear set a target of 8 Site-EFDRs beginning in Achieving these targets has brought Darlington in line with the best performers in the industry. The industry is moving towards a Site-EFDR rate metric. Note that rate and Site-EFDR targets are not in exact alignment given the different nature of the two metrics. Figure 2, the 18-month rolling average number of human performance (HU) events per 10,000 worker-hours worked, shows that Darlington is entering upper q uartile perform an ce. The EFDR target for Nuclear sites is currently HU events per 10,000 worker-hours worked. The EFDR industry benchmark for upper quartile performance is at or below HU events per 10,000 worker-hours. Darlington s current performance is approximately HU events per 10,000 worker-hours. Page 9 of 54

21 Figure 2 - Darlington Site-EFD Resets and Event Rate Event rate = 18-month rolling average number of HU events per 10,000 worker- hou rs worked O.OI2 : o!z e Darlington S-EFDR + Darlington Event Rate +EFD Rate Target Workforce Recruitins and Development A number of proactive initiatives are underway across Nuclear to strengthen staffing and recruitment, as described below. Maintenance Staffinq The Trades Apprenticeship program within Maintenance provides an opportunity for Darlington to hire new employees to meet future business needs. Recruitment of trades has included a mix of skill levels and takes into account work program demands. Experienced hires are also recruited who hold provincial Certificates of Qualification and are familiar with large industrial settings. Enaineerins Staffinq A Nuclear Engineering Graduate Training and Development Program is currently in place for the new graduates hired into engineering organizations. The objective of the program is to provide a means of developing and assessing the capabilities of new graduate engineers and scientists. Operations Staffinq The current licence period has seen an increase in the total number of certified staff. Ongoing reviews of the staffing plan ensure that non-licenced and certified operators are available in adequate qualified numbers to support safe operation of the station. Evaluation of the hiring, initial training and continued development of operator staff is continuous to ensure a sustainable program that will establish and maintain all operations staff at a high level of operator fundamentals, knowledge and skill. Page 10 of 54

22 4.0 OPERATING PERFORMANCE 4.1 Conduct of Operations Program 4.1.I Objectives The objective of the Conduct of Operations Program is to ensure the safety of the public, environment, plant personnel, and plant equipment. This program establishes safe, uniform and efficient operating practices within Nuclear facilities that provide s nuclear professionals the ability to ensure the facilities are operated in such a manner that the PROL, Operating Policies and Principles, and other applicable regulations and standards are complied with. maintains public safety through execution of the defence-in-depth concept which is achieved by a set of multiple, overlapping barriers: (a) (b) (c) Engineered barriers, consisting of the five physical barriers, reliable process systems and poised systems important to safety. Administrative barriers, consisting of managed programs, administrative processes, and procedures governing safe operation of the station. People-based barriers, comprised of trained and qualified staff, with a sound safety culture and ability to detect and correct failures of equipment and processes. The effectiveness of the physical barriers, reliability of the process systems, and readiness of the systems important to safety are reflected in and tracked by the following public safety indicators: 0 Dose to the public. Unplanned automatic reactor trips while critical. Systems important to safety unavailability. 0 Serious process failures. 0 Fuel reliability. Tritium Removal Facilitv The purpose of the Tritium Removal Facility (TRF) is to remove tritium contamination from reactor grade heavy water and to safely immobilize and store the tritium. By maintaining lower tritium levels in the moderator and primary heat transport systems, staff radiation exposure and emissions to the environment are reduced significantly. Page 11 of 54

23 4.1.2 Key Governing Documents s key documents for the Operating Performance SCA are listed in the table presented below. The hierarchy of governing documents that implement the Operations Program are tabulated in the relevant program documents. Source Effective Document Title Document Number Revision # Date OPERATIONS PROGRAM (INCLUDING OPERATING POLICIES AND PRINCIPLES) I ODeratina Policies and Princbles I NK38-OPP R024 I I Conduct of Operations I N-PROG-OP ROO2 I I Plant Status Control I N-PROG-OP-0003 ROO Chemistrv I N-PROG-OP-0004 ROO Operations Performance I N-STD-OP-0011 I Reactivity Management N-STD-OP-0009 ROO I I Ouerational Decision Making I N-STD-OP-0036 I ROO I I I Monitoring I Heat Sink Manaaement N-STD-OP-0025 ROO I I Response to Transients I N-STD-OP-0017 I ROO6 I I Control of Fuelling Operations Reactor Shutdown Guarantee Management N-STD-OP-0021 N-STD-OP-0024 ROO2 ROO Processing Station Conditions Records N-PROC-RA-0022 R Corrective Action N-PROG-RA-0003 ROO OPERATING LIMITS I Safe ODeratina EnVelODe I N-STD-MP-0016 I ROO1 I I Response to Transients 1 N-STD-OP-0017 ROO6 I I I Conduct of Regulatory Affairs I N-PROG-RA-0002 I ROO Performance This SCA was rated Fully Satisfactory for Darlington in the 2010 Annual CNSC Staff Report on the Safety Performance of Canadian Nuclear Power Plants. Throughout the year, CNSC staff conducted numerous inspections, including field and control room inspections. There were no significant operations-related issues identified. Darlington continues to demonstrate a high degree of compliance in this area. Public Dose operates a Radiological Environmental Monitoring Program to realistically estimate public dose. Environmental media are monitored for a number of potential critical groups of members of the public that live near each site. The radiological impact on a member of the public is maintained at very low levels. The regulatory effective dose limit for members of the public is 1 millisievert per year (msv/year) and Darlington s target is msv/year. Page 12 of 54

24 The 2010 Darlington site annual public dose of 0.6 microsievert (~SV) or msv is 0.06% of the legal limit for a member of the public. The dose for 2010 is about the same as the site public dose of 0.7 psv reported in As can be seen in Figure 3, the radiological impact on a member of the public continues to remain at very low leve Is. Figure 3 - Dose to Public L m B I r 1 I Legal Limit = 1 rnsv/year \ > VI E I I good EZi3 Actual +Target Actual +Target The Darlington site public dose is 0.04% of the total public background dose. The estimated average background public dose around Darlington from naturally occurring and anthropogenic (man-made) radiation is about 1.4 msv/year (1,400 psv/year), excluding medical doses. Unplanned Automatic Reactor Trips Monitoring the number of unplanned automatic reactor trips while critical is a measure of process system reliability and more generally, the quality and care taken in operating and maintaining process systems and shutdown systems. The measure for unplanned automatic reactor trips can be compared with the performance of most commercial reactors. Automatic means that the initial signal that caused actuation of the reactor protection system logic was provided from one of the sensors monitoring plant parameters and conditions, rather than the manual trip switches (e.g., provided in the main control room). The industry benchmark is 0.50 unplanned automatic reactor trips per 7,000 hours of critical operation. At Darlington, the rate of unplanned automatic trips while the reactor is critical remains below the industry benchmark, as shown in Figure 4. One unplanned automatic reactor trip occurred during the licensing period: Station Condition Record (SCR) D Spurious Shutdown System 2 (SDS2) Trip - occurred during start-up following the planned 2010 Unit 4 outage when backfilling the moderator level transmitter lines, resulting in a hydraulic interaction that tripped the moderator low level parameter. Page 13 of 54

25 The shutdown system (SDS2) responded as per design to trip the reactor. The event was the subject of an Early Notification Report and presented by CNSC staff to the CNSC Commission at a public meeting under CMD 10-M29. Corrective action plans are in place to prevent recurrence. Figure 4 - Unplanned Automatic Reactor Trips good I 0.23 EEZl Actual --t Industry Benchmark Year Svstems ImDortant to Safetv Unavailability The unavailability models for the Systems Important to Safety (SIS) were updated as reported in the 2010 S-99 Annual Reliability Report for Darlington NGS. During the licensing period all SIS met their availability targets, except for the Shutdown Cooling (SDC) system. On April 22, 2009, while all the units were in the Guaranteed Shutdown State for the station's Vacuum Building Outage, a procedure was executed on Unit 1 in preparation for declaring the SDC system in service as an outage heat sink. While executing the procedure, it was discovered that the service water to each of the pump motor coolers (bearing cooling low flow) was below the minimum flow requirements due to zebra mussel fouling. The zebra mussels were removed and flows were restored to acceptable levels for all three pump motors, prior to placing SDC in service. A number of inspections have been planned to characterize the extent of zebra mussel growth in the Powerhouse Upper Level Service Water (PULSW) system that supplies the SDC system. A PULSW outage was completed during the Unit 1 planned spring outage, involving inspections and cleaning in various locations. Results demonstrated that the system continues to be susceptible to zebra mussel fouling. PULSW outages are planned for the upcoming Units 2, 3 and 4 outages. Page 14 of 54

26 Corrective actions are in progress to resolve this biological fouling issue, including: 0 Actions to re-evaluate the station zebra mussel abatement program for improvements to both the process of chlorination and surveillance of process equipment. 0 Actions to initiate a design change to install strainers on the service water supply to the SDC system pump motor coolers to allow for online cleaning of zebra mussels blocking the SDC system pump motor cooling lines. Serious Process Failures Another measure of public risk is the number of serious process failures. These are process system failures that in the absence of Special Safety System action could result in systematic fuel failures or a significant release of radioactivity. To date there has never been a serious process failure or a near miss serious process failure at Darlington. Fuel Reliabilitv Fuel reliability is a direct measure of the effectiveness of the first two of five physical barriers to the release of radioactivity. These five barriers are the ceramic fuel matrix, the fuel sheath, the primary heat transport boundary, containment and the exclusion zone. The fuel performance at Darlington during 2010 was strong, and is consistent with previous years. Post-discharge fuel inspections and post-irradiation hot cell examinations of a sample of fuel discharged in the last five years of operation indicate that the fuel condition remains within the design basis compliance envelope for wear and deformation. During 2010, there was one defect indication which was later confirmed through fuel inspections. Over the last five years, there have been a total of four defect indications at Darlington with two defects confirmed by fuel inspections. Iodine levels remained well below station shutdown limits during the licensing period. In-core fuel operating conditions have been well controlled to within the CANDU design basis compliance envelope and licence operating limits. There were no abnormal operating conditions that degraded in-core fuel performance. An improved gaseous fission product monitoring system has been installed to help identify and locate failed fuel for timely removal from the core. Tritium Removal Facilitv As the sole provider of tritium capture and storage in Canada, the TRF provides immobilization services to other utilities and research establishments; thus, substantially reducing worker dose and environmental impact throughout the jurisdiction. Page 15 of 54

27 Ontario Power Generation continues to invest in the maintenance and upgrades to the TRF. Plant life extension studies are underway looking at near term extension to 2025, and requirements to extend life to These plans include provision for improved vapour phase capture of tritium oxide in the Heavy Water Management Building stacks to further reduce the emissions from the plant. Over the past five years the TRF has significantly improved tritium immobilization performance, resulting in a 55% increase in curies of tritium immobilized, as compared with the total tritium stored in the previous five years. Page 16 of 54

28 5.0 SAFETY ANALYSIS 5.1 Program Overview Objectives Nuclear Safety Analysis is comprised of two complementary programs, the Reactor Safety Program, and the Risk and Reliability Program, described below. Reactor Safetv Program The Reactor Safety Program defines organizational responsibilities and key program elements for the management of issues related to Nuclear Safety Analysis, in particular the following major components of safe operation: Safety Analysis Basis (Safety Report and Analysis of Record). Safe Operating Envelope (SOE). 0 Severe Accident Management (SAM). This program and implementing procedures and standards govern management of issues related to Nuclear Safety Analysis and their impact on safe operation. Risk and Reliability Program The objective of the Risk and Reliability Program is to provide organizational accountabilities, interfaces, and key program elements to ensure risks from nuclear accidents are identified, monitored, and controlled. Probabilistic Risk Assessment (PRA) is used to assess the magnitude of radiological risks to the public from accidents due to operation of nuclear reactors. Operational reliability monitoring and reporting ensures reliability during operation is monitored and managed. This program consists of safety goals, station-specific PRAs, associated risk models, unavailability models of systems important to safety and software applications, and Nuclear governing documents. The PRA is a comprehensive model of the plant incorporating knowledge about plant design, operation and response to abnormal events. The major task of a nuclear plant PRA is to identify the various sequences of events, and to calculate their frequencies of occurrence and consequences. Page 17 of 54

29 5.1.2 Key Governing Documents s key documents for the Safety Analysis Safety and Control Area are listed in the table presented below. Source Document Title Document Number Revision # REACTOR SAFETY PROGRAM Reactor Safety Program DN 1-4 Safety Report: Part 3 - Accident Analysis Effective Date N-PROG-MP-0014 ROO NK38-SR ROO Darlington Analysis of Record NK38-REP R RISK AND RELIABILITY PROGRAM 1 Risk and Reliability Program N-PROG-RA-0016 ROO Reliability Monitoring and Reporting of Systems Important to Safety N-STD-RA-0033 ROO S-99 Annual Reliability NK38-REP ROO Report Table 1.1: List of Systems Important to Safety and Targets Preparation, Maintenance and N-STD-RA-0034 ROO Application of Probabilistic Risk Assessment I 5.2 Performance Highlights from Darlington s performance in the Reactor Safety Program and the Risk and Reliability Program areas are discussed below, including the status of SOE Implementation, PRA, and projects which are being expedited to address aspects of SAM following the Fukushima Daiichi Nuclear Power Plant (NPP) event. Safe Operatincl Envelope Implementation Significant work on Safe Operating Envelope (SOE) program implementation has progressed through 2009 and Work progressing in includes completion and issuing of SOE Compliance Tables, implementation of SOE Limits and Conditions in station operating documents, and the identification and resolution of any minor gaps found between CSA N I 0, Requirements for the Safe Operating Envelope of Nuclear Power Plants, and SOE implementation. provides CNSC staff with routinely scheduled updates. The next progress update on SOE implementation is targeted for November 201 1, prior to the next annual CNSC-Industry meeting scheduled for December Probabilistic Risk Assessment Darlington has had a working Probabilistic Risk Assessment (PRA) since it was placed in service. The Darlington NGS Probabilistic Safety Evaluation (DPSE) was completed as a design verification tool in 1987, and the first draft Darlington Probabilistic Risk Page 18 of 54

30 Assessment (DARA) was issued in April Darlington is transitioning to compliance with CNSC Standard S-294, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants, published in April Eight PRA methodology documents covering the full range of PRA hazards have been submitted to the CNSC for acceptance, five of which have been accepted to date. The Level 1 PRA for internal events for high power units was submitted to the CNSC in February The screening analysis for low frequency internal and external events was submitted to the CNSC in April All required submissions are expected to be made by September This will complete the transition to S-294 Probabilistic Safety Assessment (PSA) for Nuclear Power Plants PRA project for Darlington NGS. Severe Accident Management Guidelines Initial Severe Accident Management Guidelines (SAMG) implementation at in 2010 put in place SAMG technical response capability at the Corporate Emergency Operating Facility (CEOF) using draft documentation. The CEOF response is activated automatically when an Abnormal Incident, On-site, or General Emergency notification is declared. The CEOF Technical Support Director procedure was revised and approved for issue May The Darlington SAMG implementing suite of procedures was issued in May By December 201 1, the remainder of the Emergency Response Organization procedures will be reviewed and revised as necessary, and authorized staff is scheduled to receive training by year end on Severe Accident Control Room Guidelines 1 and 2. A project approach is being utilized to complete implementation of SAMG. The Project Charter is scheduled to be approved by October and will include preliminary completion dates for these activities. This charter will include the closure of any issues identified during implementation, staging materials as necessary for the enabling instructions, issuing the SAMG background documents, and implementation of any approved design changes. Passive Autocatalytic Recombiners Installation Hydrogen Igniter availability has been confirmed and is pursuing the installation of additional hydrogen mitigation in the form of Passive Autocatalytic Recombiners (PARs). The PARs units provide an additional line of defence (above and beyond current design basis) to the existing Hydrogen Ignition System for hydrogen mitigation. In response to the Fukushima event, is expediting the installation of PARs across its fleet. The supply of PARs for the first stage installation has been secured, with a targeted completion date of October for installation in online accessible areas and May 2012 in the Unit 3 vault. Installation of PARs in remaining Unit vaults is expected to be completed in respective planned outages with a targeted completion date of July 2014, and implementation in remaining online accessible locations also targeted by July Page 19 of 54

31 will communicate the outcomes of the first stage installation work to the CNSC and provide a status update on the PARS implementation plan by February Fukushima Daiichi Nuclear Power Plant Event has provided the CNSC with progress updates on the response to events at the Fukushima Daiichi NPP, including assessments requested by the CNSC, and reports on the progress of additional nuclear industry actions undertaken. has progressed reviews based on the lessons learned from the Fukushima event, including re-examination of the safety cases for its stations, in particular the underlying defence-in-depth concepts with respect to: (a) (b) (c) External hazards such as seismic, flooding and extreme weather events. Measures for the prevention and mitigation of severe accidents (SAMG). Emergency preparedness. has concluded that there are no significant safety issues requiring immediate corrective or compensatory measures. continues to affirm that the risk related to s NPP operation is low as documented in the licensing basis. As is often the case with any broad rigorous review, potential improvement opportunities have been identified. These improvement opportunities are being prioritized and addressed per normal station processes. Significant progress has been made in both evaluating the lessons learned from the events at Fukushima Daiichi NPP, as well as, conducting a rigorous review of the preparedness of the stations to deal with beyond design basis events., in concert with Canadian Industry partners, is keeping abreast of operating experience and working aggressively on follow-up actions related to the events at Fukushima Daiichi NPP. A Canadian nuclear utility working group (including, Bruce Power, Hydro Quebec, NB Power and AECL) was formed in March and is working on common issues for the CANDU reactor fleet. Page 20 of 54

32 6.0 PHYSICAL DESIGN 6.1 Program Objectives Design Program Conduct of Engineering Proqram The Conduct of Engineering Program implements a series of programs, standards and procedures for performing engineering in a consistent manner across Nuclear. The program establishes the following practices for engineering: (a) (b) (c) (d) Ensures each plant configuration is maintained in accordance with the design and licensing bases, and operated within its Safe Operating Envelope (SOE). Ensures essential plant equipment performs safely and reliably. Complies with relevant legal, statutory, and regulatory requirements. Encourages continuous improvement in the conduct of engineering targeted at achieving safe, reliable and competitive operation of Nuclear power generating stations. Enqineerinn Change Control Proqram The Engineering Change Control (ECC) Program ensures all modifications to Nuclear plant Systems, Structures, and Components (SSCs), including software and station engineered tooling, are planned, designed, installed, commissioned, decommissioned, placed into service, or removed from service within the SOE, design basis, and plant licensing conditions. Confiauration Manaqement Proqram The Configuration Management program ensures Nuclear facilities are operated, maintained, and modified in accordance with their design and licensing bases. The program objectives assure the physical plant matches the configuration documentation, and that configuration information is accurate, consistent, and readily available. Desian Manaqement Proaram The Design Management Program provides the framework for establishment of assurance that changes to plant design are controlled in a manner consistent with the plant design and licensing bases. This program provides assurance that the design basis, design outputs and design process documentation are prepared, reviewed, approved and implemented in accordance with approved procedures and applicable regulatory requirements, standards and industry practices. Page 21 of 54

33 6.1.2 Fuel Program The primary objective of the Fuel Program is to establish a formal and systematic process to ensure fuel performs safely and reliably over the life of the stations, maintaining the fuel design basis and licensing basis. The Fuel Program also takes responsibility for integrating and reviewing fuel channel data which may impact safety analysis or the safety report. Responsibilities for fuel channel Life-Cycle Management and Fitness for Service are covered by N-PROG-MA-0025, Major Components, discussed in Section 7.0 Fitness for Service Design and Analysis Computer Codes and Software The Software Program identifies the processes and overall requirements for classification of software, and identifies governing standards for each software classification, defining requirements for software development, maintenance, procurement, qualification and retirement Pressure Boundary Program The Pressure Boundary (PB) Program provides a managed process for performing repairs, replacements and modifications on pressure retaining systems and components. It reflects those requirements of the Pressure Boundary Quality Assurance program related to the performance of PB fieldwork activities. The N-MAN , Pressure Boundary Program Manual, describes the system used to control the quality of PB activities at Nuclear facilities and stations. It complies with CSA N285.0, General Requirements for Pressure Retaining Systems and Components in CANDU Nuclear Power Plants, and ASME Section 111, NCA-4000, Quality Assurance. Pressure boundary requirements for all states of work, from design through to installation and testing, are implemented through supporting Nuclear governing documents. The CNSC has regulatory jurisdiction over PB requirements, including approval of any deviations from those requirements. Authorization for to perform PB activities is granted by the Technical Standards and Safety Authority (TSSA), on behalf of the CNSC Key Governing Documents s key documents for the Physical Design SCA are listed in the table presented below. Source Effective Document Title Document Number Revision # Date Conduct of Engineering N-PROG-MP-0007 ROIO Engineering Change Control N-PROG-MP-0001 ROIO Configuration Management N-PROG-MP-0005 ROO Design Management N-PROG-MP-0009 ROO Page 22 of 54

34 Source Effective Document Title Document Number Revision # Date Darlington Safety Report, Parts 1 NK38-SR ROO and 2 1 DESIGN AND ANALYSIS COMPUTER CODES AND SOFTWARE I Software I N-PROG-MP ROO PRESSURE BOUNDARY PROGRAM I I Pressure Boundaw Program I N-PROG-MP-0004 I ROO9 I I 6.2 Performance System and Item Classification N-PROC-MP-0040 ROO6 ] Desian Reaistration N-PROC-MP-0082 ROO8 A Pressure Boundary Program I N-MAN I R012 I ~ Manual The health of the Design and ECC programs is monitored using the ECC Site Index. The index incorporates modifications implemented by the field, the quality of Design ECC packages, ECC process compliance, and the timely filing of records. Darlington performance in the ECC Site Index has historically been strong. Engineering Change Control governance undergoes continual review and evaluation by members of the Design Authority Peer team. Based on operating experience, the ECC procedure was revised in 2010 to provide clarification regarding the risk assessment which is performed during the scoping phase of a modification. The procedure was revised to ensure the required rigour was being applied to the risk ranking, to better control the application of the Non-Identical Component Replacement (NICR) process, and to introduce a simplified modification process for modifications that are confirmed to be low risk and of low complexity. The simplified modification process (Reduced Risk and Approval Modification) provides an alternative to using the NICR process for simple changes that do not meet all the criteria for a NICR. In addition to revising the ECC procedure, the training program has been upgraded and a requalification requirement for Modification Team Leaders and Design Team Leaders has been approved by the Technical Procedure Review Committee (TPRC). In response to the recent discovery of legacy changes in the field that did not properly apply the ECC process, Darlington implemented corrective actions, using field walkdowns and Technical Change Record (TCR) reviews, to identify potential unapproved modifications and correct ECC non-compliances. A training program has been implemented to improve Operations and Maintenance staffs knowledge of the ECC process. All Operations and Maintenance staff have received rollouts, to identify ECC requirements, and to provide examples specific to the roles they perform. In addition all Authorized Operators, Maintenance First Line Managers, and Maintenance First I Page 23 of 54

35 Line Manager Assistants are being given a 3 hour training session, delivered by the Design Authority, to make them aware of the ECC requirements. This training will be completed by September The ECC process continues to use the existing electronic data system, Passport, to control and document Engineering Controlled Changes. All documentation associated with the modification is scanned into Passport and can be easily retrieved. Throughout 201 0, Darlington adequately confirmed that SSCs important to nuclear safety and security, continued to meet their design basis in all operational states until the end of their design life. has also converted major process systems to digital control at Darlington, and updated the control computer and shutdown system computer hardware and software. Improvements to plant surveillance hardware and software were also implemented, to improve component and system surveillance and trending capabilities. Darlington obtained a renewal of the TSSA Pressure Boundary Certificate of Authorization in February Regular self-assessments are conducted to ensure Pressure Boundary Program compliance with relevant codes and standards. Page 24 of 54

36 7.0 FITNESS FOR SERVICE 7.1 Program Objectives Fitness for Service programs are implemented to ensure the physical condition of systems, components and structures remains effective over time. This includes programs that ensure all equipment is available to perform its intended design function when called upon to do so Maintenance Program Conduct of Maintenance The Conduct of Maintenance Program establishes processes to ensure the safety of the public and site personnel, the protection of the environment, and availability of plant equipment for safe and reliable operation through effective implementation and control of maintenance activities. This program also provides the requirements for managing identification and execution of preventive maintenance and repetitive task work activities using the predefined process, in support of operations, maintenance, and testing of Nuclear Generating Station equipment and facilities. The objectives of the program are primarily achieved by instituting effective maintenance processes and standards, sufficient resources, monitoring and assessing performance, and holding personnel accountable for their performance. Equipment Reliabilitv The Equipment Reliability Program sets out the requirements for establishing and maintaining optimum levels of reliability for components important to safety and production. The program provides a framework for the following activities: Identification and classification of components according to their criticality to focus activities related to these components according to their assigned criticality. System monitoring and performance monitoring to ensure systems important to safety and production will perform their intended functions under design basis conditions and at optimum levels. Component monitoring for components outside of established component programs. Follow up to critical equipment degradation or failures to minimize recurrence. Oversight and direction by station management on equipment reliability issues and priorities. Management of the technical specifications for preventive maintenance requirements. Page 25 of 54

37 (9) Implementation of predictive maintenance activities to detect early degradation of components. (h) Transfer of Equipment Reliability requirements to on-line, outage, and long range plans to ensure key actions are planned and executed. Component and Equipment Surveillance The Component and Equipment Surveillance Program assures that component and equipment performance support the safe, reliable and economic operation at Nuclear facilities. The program evaluates component and equipment health by means of technical evaluations, inspection, maintenance, certification, and testing. This ensures assumptions in the Safety Report are met, and ensures reliable component performance as credited in licensing documents. In addition, inspection and test programs are in place to ensure mandated inspection and test activities driven by licensing, and codes and standards, are met. Production Work Management The Production Work Management Program ensures maintenance, modification, and testing activities are identified, prioritized, planned, scheduled, and executed to protect plant operational integrity. Where possible, corrective maintenance and modification activities are performed during windows when affected equipment has been removed from service, to perform predefined (repetitive) maintenance. Integrated Aaina Manaqement The Integrated Aging Management Program establishes an integrated set of Nuclear Power Plant programs and activities to ensure performance requirements of critical equipment are met on an ongoing basis. This program confirms the effectiveness of the constituent programs by periodically completing condition assessments of critical components. These assessments supplement the ongoing engineering surveillance activities in place to monitor and optimize system performance. From these assessments, actions are established to ensure equipment performance requirements are met during station life Outage Management The Outage Management processes for preparation and execution of planned and forced nuclear unit outages within Nuclear receive authority from N-PROG-MA-0019, Production Work Managernenf, described above. The Darlington outage plans call for a three-year, tri-cycle, operating interval, therefore the units must operate reliably in between planned outages, Le., the probability of forced outages should be minimized. The intent of a forced outage is to correct the problem causing the unit to shut down, and return the unit to service as soon as is safely possible. Other work which is Page 26 of 54

38 required to meet regulatory or safety commitments and work required for safe and reliable operation of the unit until the next planned outage is also performed. Additional work may be completed provided the schedule and available resources can accommodate it Major Components The Major Components Program establishes a formal and systematic process in Nuclear for managing information related to four major component areas: Feeders, Steam Generators, Fuel Channels, and Reactor Components and Structures. This program provides a framework for integrating and reporting of the component performance, condition, and compliance with design basis documents. The objective is to ensure the four major components perform safely and reliably over the life of the stations, maintaining the design and licensing bases. To ensure the integrity of the pressure boundary and fitness for service of nuclear plant systems and components, has implemented Periodic Inspection Program (PIP) Plans for fuel channels, feeders, steam generators, containment components and concrete containment components. Elements of PIP are required to satisfy CSA Standards. Fuel Channels Life Cvcle Manaqement Plan The Fuel Channels LCM Plan specifies a combined program of in-service inspection, maintenance, engineering assessments and research and development. The plan is revised yearly to document and respond to inspection findings and industry observations. The Fuel Channels LCM Plan provides the 10 year inspection and maintenance requirements (including for periodic inspection), and the strategy for inspection and maintenance to end of life. Feeders Life Cvcle Management Plan The Feeders Life Cycle Management (LCM) Plan contains requirements for inspections of pipe bends and wall thinning, as well as visual inspection and evaluation of the feeder support components, e.g., feeder piping spacers, tie rods, chafing shields and hangers. This inspection and maintenance plan is forward looking and defines required activities to support feeder operation extending five or more years into the future. The plan is regularly updated to incorporate changes to these requirements that may be warranted from inspection results on the rates and extent of active degradation. The plan also contains strategies to deal with plausible aging mechanisms that are not active but may become active. It considers the probabilities, areas of vulnerability in the piping system, and mitigating actions to ensure that feeders remain within the design basis. Page 27 of 54

39 Steam Generator Life Cvcle Manaqement Plan The primary goal of the Steam Generator (SG) LCM Plan is to operate all four units safely and reliably with the existing steam generators over the life of the station, while maintaining the design and licensing bases, and optimizing station reliability, production and cost effectiveness. Another key goal of the SG LCM Plan is to maintain or restore thermal performance. To achieve the above, the Inspection and Maintenance Program must be effective at preventing or mitigating SG degradation and failures. Inspection of pressure boundary shell welds, nozzles and external vessel supports is prescribed in the Periodic Inspection Program specific to each unit. Reactor Components and Structures Life Cvcle Manaaement Plan The Reactor Components and Structures LCM Plan addresses a number of components such as the calandria assembly, end shield assemblies, reactivity mechanisms, calandria supports, calandria relief ducts and calandria tubes. The Reactor Components and Structures LCM Plan is updated annually to capture new information from inspection, research, and OPEX. Aaing Management Plan for Containment Structures The Aging Management Plan (AMP) for Containment Structures was adapted from the CNSC Regulatory Document RD-334, Aging Management for Nuclear Power Plants; OPEX from CANDU plants and outside the industry; COG; and other industry leaders such as the IAEA. The AMP was updated following an aging management workshop in January 2010, hosted by and including key industry players such as CNSC, NB Power, Bruce Power, Hydro Quebec, Kinectrics, COG and AECL. This AMP evaluates the programs and practices currently in place at that create a systematic and integrated approach to manage aging of containment structures. Documentation of lessons learned is based on inspection and testing programs related to aging of containment. These are created in accordance with the AMP to determine the overall effectiveness and complete the cycle of a systematic and integrated approach to manage aging Environmental Qualification Program The Environmental Qualification (Ea) program defines activities to ensure that essential safety-related equipment, required to mitigate the consequences of a design basis accident, will perform its intended function when exposed to harsh environmental conditions resulting from that accident, and to maintain this capability over the life of the stations. This program also includes programmatic controls necessary to maintain the qualified status of equipment over the life of the plants. Page 28 of 54

40 7.1.5 Key Governing Documents s key documents for the Fitness for Service SCA are listed in the table presented below. Source Document Title Effective Document Number Revision # Date ~ Conduct of Maintenance N-PROG-MA-0004 ROO EauiDment Reliabilitv N-PROG-MA-0026 ROOO ~- Component and Equipment N-PROG-MA-0017 ROO Surveillance Production Work Manaaement N-PROG-MA-0019 ROO Planned Outage Maintenance N-PROC-MA-0013 R Forced Outage Maintenance N-PROC-MA-0049 ROO , Maior Components I N-PROG-MA-0025 Feeders Life Cycle Management N-PLAN ROOO 1 ROIO I Plan Darlington Nuclear Unit 1 Fuel Channel Feeder Pipes Periodic Inspection Program Plan NK38-PIP ROOO Darlington Nuclear Unit 2 Fuel NK38-P1P ROOO Channel Feeder Pipes Periodic Inspection Program Plan Darlington Nuclear Unit 3 Fuel NK38-PIP ROOO Channel Feeder Pipes Periodic Inspection Program Plan Darlington Nuclear Unit 4 Fuel NK38-PIP ROOO Channel Feeder Pipes Periodic Inspection Program Plan Steam Generators Life Cycle N-PLAN ROOO Management Plan Fuel Channels Life Cycle N-PLAN ROO Manaaement Plan Darlington Nuclear 1-4, Unit 1 NK38-PIP ROO Fuel Channel Pressure Tubes Periodic Inspection Program Plan Darlington Nuclear 1-4, Unit 2 NK38-PIP ROO Fuel Channel Pressure Tubes Periodic Inspection Program Plan Darlington Nuclear 1-4, Unit 3 NK38-PIP ROO Fuel Channel Pressure Tubes Periodic Inspection Program Plan Darlington Nuclear 1-4, Unit 4 NK38-PIP ROO Fuel Channel Pressure Tubes Periodic Inspection Program Plan Page 29 of 54

41 I Source I Document Title Reactor Components and Structures Life Cycle Management Plan Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 1 Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 2 Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 3 Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 4 Darlington Nuclear Generating Station - Periodic Inspection Program For Unit 0 and Units 1 To 4 Containment ComDonents Darlington Nuclear - Unit 0 Containment Periodic Inspection Program Aging Management Plan for Containment Structures Darlington Nuclear - Reactor Building Periodic Inspection Proaram Darlington Nuclear - Vacuum Building Periodic Inspection Program Document Number N-PLAN I I NK38-PIP ROO2 I NK38-PIP ROO NK38-PIP N K38-P I P I I Effective Revision# Date 1 ROO6 ROO1 I NK38-PIP NK38-PIP NK38-PIP ROO 1 ROO1 -~ N-PLAN ROO NK38-PIP I I ~ Environmental Qualification I N-PROG-RA-0006 I ROO Performance Darlington was rated Fully Satisfactory for its compliance and safety performance in the Fitness for Service SCA in the 2010 Annual CNSC Staff Report on the Safety Performance of Canadian Nuclear Power Plants. This is an improvement from 2009 where Fitness for Service was rated as Satisfactory Maintenance Performance Darlington s performance in maintenance has remained consistent over the licence period. Systems, structures and components remained available (with one exception in 2009 as discussed in Section 4.2), reliable and effective, consistent with design, analysis and quality control measures. During the licence period the Preventive Maintenance Completion Ratio has met or exceeded the station target, and no significant findings related to pressure boundary degradation have been identified. Page 30 of 54

42 7.2.2 Outage Performance During the licensing period Darlington has successfully completed outages on all units including a Vacuum Building Outage (VBO) in The VBO was the largest and most complex project executed by in 2009 and was completed meeting or bettering all of s safety targets. Most recently Darlington s Unit (DI 11 1) outage was completed ahead of schedule. This was a complex outage due to the high number of reactor inspections. In addition, this outage included a PULSW outage. Significant improvements were made during D1111 in conventional safety and radiological safety performance. D1111 experienced a significant reduction in the number of medically treated and first aid injuries seen in the previous outage. The outage achieved top quartile radiological performance, with whole body dose well below target, and internal dose less than half of the outage target. For D1111, 98% of the outage scope was completed, representing over 2,000 work orders including over 200 discovery work orders Reliability Darlington NGS has made significant progress in improving equipment reliability and as a result the Forced Loss Rate (FLR) trend has been improving. The year-to-date FLR at the end of May was 0.12%. For 2010 with better work week schedule stability and adherence, reduced number of critical component failures, and implementation of the long-term plan initiatives, Darlington s Equipment Reliability Index (ERI) was 77%, one percent above the 2010 annual target of 76%, and an improvement of three percent over the 2009 ERI. To continue improving equipment reliability and FLR, the station is focused on backlog reduction, reducing equipment failure rates, and putting actions and oversight in place to address events that contribute to the FLR. Further processes are ongoing to assist the station to report the ERI for each in service operating unit, taking Unit 0 as an integral part of the operating units Major Components Fuel Channels maintains Fitness for Service (FFS) for fuel channels through life cycle plans which require periodic inspections of pressure tubes to maintain assurance of FFS on an ongoing basis. Sufficient data and inspection results have been collected to date to monitor pressure tube behaviour. The pressure tubes at Darlington are expected to remain in operation for up to 210,000 to 220,000 Effective Full Power Hours (EFPH). These limits will not be approached in the period up to the end of Neutron Overpower (NOP) analysis shows that based on the current rate of aging, the currently installed NOP Trip Setpoints (TSP) support the acceptability of Darlington operation with mitigating measures (e.g., occasional derating) to continue safe operation of the units. Derating is achieved through the use of Channel Power Page 31 of 54

43 Peaking Factor (CPPF) adjustment factors as a more practical and readily achievable method for effecting a TSP reduction. Monitoring of the aging trends on a periodic basis is used to confirm that compliance is maintained with the analysis assumptions used in the NOP analysis to represent aged Primary Heat Transport System conditions. Fuel Channel Life Management Proiect A Fuel Channel Life Management Research and Development Project has been initiated to provide assurance that the Fuel Channels and in particular the tight fitting spacers that maintain the gap between fuel channels and calandria tubes remain fit for service for the longer term operation of Darlington units prior to refurbishment. The research and development work will further enhance s knowledge and this will be applied to enhance surveillance and inspection methods for pressure tube fitness for service toward end of life. The intent is to identify, by the end of 2012, the information and activities required that will aid in reducing the uncertainty in predictions of fuel channel life and provide reliable future reactor operation. Reactor Feeders All of the feeder wall thickness values measured during inspection activities have been above their current minimum required thickness. Thinning inspections have confirmed that feeders are thinning at a rate that will result in some feeders requiring replacement. Several feeders were replaced during the current licensing period and other replacements are planned to occur prior to refurbishment. Replacement predictions are based on inspection results, and some are brought forward to optimize replacement costs. Steam Generators Steam Generator tube inspections, internals inspections, and waterlancing are completed each planned outage in accordance with the latest revision of the Steam Generator LCM Plan. The latest inspection results continue to show that the Darlington SGs are in good condition. There has been no recent tube plugging due to tube degradation since the plugging of one tube in Unit 1 during the 2008 outage due to U-bend fretting, The most recent assessments for Units 2, 3 and 4 confirmed that the SGs are fit for service until their next planned inspection outages (3.5 year operating intervals have been accepted). The Unit inspection campaign determined that the results were still within the bounds of the previous 2008 Unit I assessment. Reactor Components and Structures Darlington Calandria Tubes (CT) are unlikely to be susceptible to any degradation mechanism before refurbishment. In an ongoing strategy to manage fitness for service under the Reactor Components and Structures LCM Plan, baseline inspection of CT to Liquid Injection Shutdown System (LISS) nozzle clearance is planned for the 2013 Unit 2 outage. Page 32 of 54

44 Containment Structures There are three Darlington civil containment structure PIP documents (Vacuum Building, Reactor Building, and Unit 0). The combination of these PIPS encompasses the entire concrete containment boundary. Final leak rate test results from the 2009 Darlington Building Outage (VBO), confirmed that both the containment and the vacuum structure are exceptionally leak tight. During the VBO, a campaign was conducted to perform an inspection of the vacuum structure's post tensioning systems. Analysis of the inspection results from this campaign determined that no abnormal degradation of the Vacuum Structure Post Tensioning System has occurred and that there is no adverse impact on station operation. The inspection results from Unit containment structure inspection campaigns conducted during planned Unit outages over the current licence period were compared to previous inspection results, and no significant changes were noted. A qualified professional engineer from Darlington's Civil Design department reviewed the results from the inspection campaigns, and confirmed that the concrete containment structures are in a good condition Environmental Qualification Darlington has undertaken extensive Environmental Qualification (EQ) activities to meet a regulatory commitment made in the previous reporting period. For example, various equipment upgrades related to environmental qualification were undertaken, such as replacement with qualified components and improved protection against steam during accident conditions. Darlington has achieved full compliance for the requirements in CSA standard N , Environmental Qualification of Equipment for CANOU Nuclear Power Plants. The most significant highlight during the reporting period was the successful conclusion to Phase 2 of the EQ Closure Project. The project continued through the current licensing period and met the December 31, 2010 commitment to be fully compliant with the PROL licence condition and CSA Standard N Following are some of the significant activities accomplished: 0 Re-definition of the EQ List, through preparation and revision of the EQ document set (Le., Design Guide, Room Conditions Manual, Technical Basis Documents, EQ List Development Packages, and EQ Assessments). 0 Components replacement and upgrades to qualified status. 0 Establishment of Column Line 1 I wall as a steam protection barrier. 0 Completion Assurance walkdowns and reviews. 0 EQ standard drawing updates. 0 Passport Master Equipment List updates. Page 33 of 54

45 In addition, the project completed the following activities to improve the Sustaining EQ Program: Maintenance Procedure revisions. EQ Preventive Maintenance program revisions. Supply Chain EQ information updated. Development of surveillance tools. Page 34 of 54

46 8.0 RADIATION PROTECTION 8.1 Radiation Protection Program Objectives The Radiation Protection (RP) program,,nplements a series of standards and procedures for the conduct of activities within Nuclear sites, and with radioactive materials, intended to achieve and maintain high standards of RP including the following objectives: (a) Controlling occupational and public exposure: (1) Keeping individual doses below regulatory limits. (2) Avoiding unplanned exposures (3) Keeping individual risk from lifetime radiation exposure to an acceptable level. (4) Keeping collective doses As Low As Reasonably Achievable (AURA), social and economic factors taken into account. (b) (c) Preventing the uncontrolled release of contamination or radioactive materials from Nuclear sites through the movement of people and materials. Demonstrating the achievement of (a) and (b) through monitoring Key Governing Documents s program document for the Radiation Protection SCA is listed in the table presented below. The hierarchy of governing documents that implement the RP program is tabulated in the program document. RADIATION PROTECTION PROGRAM I Radiation Protection I N-PROG-RA ROO5 I I WORKER RADIATION PROTECTION ACTION LEVELS Occupational Radiation Protection N-REP ROO0 ~ Action Levels for Power Reactor Operating Licences 8.2 Performance Darlington was rated Fully Satisfactory for the Radiation Protection SCA in the 2010 Annual CNSC Staff Report on the Safety Performance of Canadian Nuclear Power Plants. This is an improvement from 2009 where Radiation Protection was rated as Satisfactory. Page 35 of 54

47 During the licence period there were no radiation exposures at Darlington that exceeded regulatory limits, and no incidents resulting in reportable doses in excess of action levels. Darlington continues to be a leader in collective dose performance. Darlington received the Information System on Occupational Exposure (ISOE) AURA World Class Performance award in January 2008 for exemplary performance in occupational dose reduction. Darlington s external and internal dose performance continues to be among the best in the CANDU community. Although varying from year-to-year, collective dose has remained relatively steady. Variation year to year is primarily due to the number of maintenance outages performed, which impacts the total collective dose for the year. Darlington s continuing good equipment reliability and low FLR have contributed to low dose attributed to normal operations and forced outages. Improvements in dose performance include: Excellent internal dose performance achieved through reducing Gravity Filled State during outages and improving portable dryer performance to reduce tritium in air concentrations. An ALARA tritium mitigation plan has been aggressively implemented, including reduction in tritium content in moderator heavy water and reduction of heavy water leaks. Implementation of an enhanced radiation protection program related to alpha monitoring and control, including the acquisition of improved alpha contamination instrumentation, the increase in routine and non routine monitoring for alpha contamination (both surface and airborne monitoring), and the enhancement and increase in use of personal air samplers and dosimetry for alpha uptakes. A four-fold reduction in reactor face dose rate achieved by installing a combination of innovative shielding canopy and end fitting shielding blocks. Dose savings in excess of 10 rem (100 msv) were realized during the recent Unit planned outage. Innovative use of teledosimetry arrays for reactor face scans to save dose and reduce critical path time. Use of remote real time gamma and tritium monitoring during outages, reducing Radiation Protection Coordinator dose by minimizing the need for routine vault gamma and tritium surveys. Use of mobile work platform to minimize scaffold use and dose associated with setup and removal during planned outages. Fabrication of new feeder jackets with remote application tools to reduce ice-plug dose received by operators. This improvement has reduced ice-plug dose by more than a factor of two in recent outages. Page 36 of 54

48 9.0 CONVENTIONAL HEALTH AND SAFETY 9.1 Conventional Safety Program Objectives The goal of N s Conventional Safety Program is to ensure workers work safely in a healthy and injury-free workplace by managing risks associated with activities, products and services of s Nuclear operations. Risk reduction is primarily achieved through compliance to operational controls, developed through risk assessment and safe work planning. N s Conventional Safety Program is intended to align with a number of internal and external specifications or standards. The Conventional Safety Program is aligned with policy on Management Systems, and British Standards Institution s Occupational Health and Safety Assessment Series (OHSAS) 18001, Management System Specification. Both the Policy on Management Systems and OHSAS are based on a Plan--+Do+Check+Review cycle of management. The Conventional Safety Program is designed to be an integrated system with Nuclear business managed processes, where appropriate, and considers the current organizational culture and structure. N s Conventional Safety Program results in: (a) (b) (c) Compliance with applicable legislative, corporate and Nuclear business requirements. Identification of continuous improvement opportunities and annual business objectives to ensure conventional safety risks are appropriately managed to achieve the annual safety performance targets. Application of sound business management processes to the management of conventional safety risks Health and Safety Policy It is a legal requirement in Ontario to prepare and review, at least annually, a written occupational health and safety policy. The Health and Safety Policy has been approved by the Board of Directors and reflects s commitment to continuous improvement in health and safety performance. Minor changes were made to the last paragraph of the policy, to add further clarity on how continuous improvement is accomplished by regularly measuring health and safety performance and monitoring the effectiveness of s safety management systems. The Health and Safety Policy commits that: (a), and its contractors, will carry out its business activities in a responsible manner that minimizes risks to employees and the public. Page 37 of 54

49 (b) (c) (d) will integrate public safety considerations into business practices and decisions and its contractors will meet all applicable health and safety legislative requirements, and other associated standards to which we subscribe, with the objective of moving beyond compliance will require that contractors and their sub-contractors maintain a level of safety equivalent to that of employees while at workplaces. The Health and Safety Policy further states that is committed to the prevention of workplace injuries and ill health, improving health and safety performance and the management of health and safety. This will be accomplished through the application of continuous improvement principles and systems to promote and maintain the physical, mental and social well being of employees in an injury-free and healthy workplace. The Policy is communicated and promoted annually with the intent that employees at all levels are aware of s commitment to health and safety and individual health and safety obligations Key Governing Documents s key documents for the Conventional Health and Safety SCA are listed in the table presented below. CONVENTIONAL HEALTH AND SAFETY PROGRAM I Health and Safetv Policv 1 -POL-0001 I NIA I I 1 Conventional Safety I N-PROG-HR-0004 I ROO2 I Performance Darlington s compliance and safety performance in this SCA was rated Fully Satisfactory in the 2010 Annual CNSC Staff Report on the Safety Performance of Canadian Nuclear Power Plants. In 2010, achieved its lowest All Injury Rate (number of injuries) since N uses the Canadian Electricity Association (CEA) safety measures to report safety performance and to compare against similar industries using the same indicators. The CEA indicators used to measure the conventional safety performance of N employees and Contractors at Darlington are: AIR - All Injury Rate (number of Lost Time Accidents + Medically Treated lnjuries/200,000 hours worked). 0 ASR - Accident Severity Rate (number of days lost due to Lost Time Accidents/200,000 hours worked). Page 38 of 54

50 With the exception of ASR in 2006, Darlington s safety performance as measured by these two indicators has been well within the CEA top quartile for comparable industries over the past five years. The AIR and ASR results in Figures 5 and 6 include exposure hours and injuries of employees who reside at the station, as well as contractors working on site. Figure 5 - All Injury Rate good OActua +Targel Year Figure 6 - Accident Severity Rate GZEl Actual +Target Year In May 201 1, Darlington employees (reporting to the Site VP s organization) achieved over 1,100 days of operation (10,000,000 hours) without a Lost Time Accident. Page 39 of 54

51 On June 14, 2010, became the first employer in Ontario to be awarded the Infrastructure Health and Safety Association (IHSA) ZeroQuestB Platinum (Sustainability) award. The ZeroQuestB program recognizes member firms for their Health and Safety Management System design, implementation and sustainability. The awards program includes an evaluation of a firm s safety performance, safety management systems and safety culture. It is based on the elements of the OHSAS Health and Safety Management System Standard as a guide. There are four levels of achievement - Bronze, Silver, Gold and Platinum. The Platinum level can only be reached after five years of sustainability at the Gold Award level. s progress through the ZeroQuestB program is a tripartite initiative with endorsement from both the Power Workers Union and The Society of Energy Professionals who actively participate in the preparations for the reviews. s level of achievement in the ZeroQuestca, program acknowledges that is a safe, responsible employer - a leader in promoting safety in the workplace, and sharing best practices throughout the industry. Although Darlington s health and safety performance is very good, the station s target is to achieve zero injuries. Conventional safety related events are evaluated through the corrective action process to identify potential trends and areas for improvement. Specific areas targeted for improvement in include falling objects prevention, more consistent application of work protection to control hazardous energies in work activities, continued focus on material handling fundamentals, and the prevention of musculoskeletal injuries. Page 40 of 54

52 10.0 ENVIRONMENTAL PROTECTION 10.1 Environmental Protection Program Objectives has established an Environmental Management Program to assess environmental risks associated with its nuclear activities, and to ensure that these activities are conducted such that adverse environmental effects are prevented or mitigated. All aspects of the program are conducted to ensure Nuclear complies with environmental regulatory and other requirements including the International Organization for Standardization (60) : 2004 Environmental Management System Environmental Policy -POL-002 1, Environmental Policy, establishes guiding principles for environmental management and environmental performance for Nuclear employees and those working on Nuclear s behalf. The policy states that will strive to continually improve its environmental performance by committing to the following seven requirements: Meet all legal requirements and s voluntary commitments, with the objective of exceeding those standards where appropriate and feasible. Contribute to environmental protection, pollution prevention and energy and resource use efficiency. Maintain registrations to the IS : 2004 Environmental Management System. Integrate environmental factors and stakeholder considerations into our planning, decision-making and business practices. Engage and educate employees to conduct their activities in a manner that respects and protects the environment. Contribute to and enhance the environmental well-being of the communities in which we operate and the broader public who grant us our licence to operate. Measure and publicly communicate our environmental performance with employees, governments, local communities, contractors and other stakeholders. This Environmental Policy is an important part of s commitment to Sustainable Development. It is made available on the website opg.com and on the intranet. The policy is communicated as part of Nuclear General Employee Training. Page 41 of 54

53 Key Governing Documents s key documents for the Environmental Protection SCA are listed in the table presented below. The hierarchy of governing documents that implement the EP program is tabulated in the program document. Source Document Title Document Number Revision # Effective Date ENVIRONMENTAL PROTECTION PROGRAM 1 Environmental Policv 1 -POL-0021 I NIA I I Environmental Management I N-PROG-OP-0006 I R014 I CONTROL AND MONITORING OF RELEASES 10.2 Performance Derived Release Limits for NK38-REP ROO0 Darlington Nuclear Generating Station Note 2 Environmental Action Levels for Ontario Power Generation Nuclear Generating Stations N-REP ROO During the licence period, gaseous and aqueous releases of nuclear substances were always below Environmental Action Levels and Derived Release Limits. These limits are based on dose to the public and are well below environmental background levels. As discussed in Section 4.2, actual dose to the public from the site is well below the public dose limit of 1,000 psv/year (1 msv/year) and in 2010 was only 0.6 psv. maintains a community relations program that proactively provides information to stakeholders including the general public, elected officials, media, labour unions, and employees. The program informs stakeholders of station operations, participation and involvement in the community, and the general nature and characteristics of the anticipated effects on the environment and the health and safety of persons that may result from station operations. Demineralized water was inadvertently released to the environment in 2009, some of which drained into Lake Ontario. The water contained very low concentrations of tritium and hydrazine. The event was the subject of an Early Notification Report and presented by CNSC staff to the CNSC Commission at a public meeting under CMD 10-M4. CNSC staff confirmed the release was not significant to either the environment or to public health. Non-radiological releases are maintained at low levels. Darlington has seen a significant reduction in SO2 releases due to a general reduction in the sulphur content of diesel fuel used in the Standby Generators and Emergency Power Generators. Starting 201 1, the Standby Generators are no longer made available for the Bulk Note 2 - The DRLs have been updated to implement the current version (2008) of CSA standard N288.1, Guidelines for calculating derived release limits for radioactive material in airborne and liquid effluents for normal operation of nuclear facilities : Darlington NGS A - Request for Licence Amendment for Revision to the Derived Release Limits and Environmental Action Levels, NK38-CORR , June 21,2010. has responded to CNSC comments and a licence amendment is pending. Page 42 of 54