CHALK RIVER LABORATORIES (CRL) APPLICATION FOR OPERATING LICENCE RENEWAL (SUPPORTING REFERENCE MATERIAL)

Transcription

1 N' A) ~~~ ~~9aiue of Canada Limited du Canada limitee 2010 November 30 CNSC E.S. (Hank) Drumhiller Vice-President Operations and Chief Nuclear Officer Site Licence Holder - Chalk River Laboratories CCSN Ii CRL-ACN L M. Santini, Director Chalk River Laboratories Compliance and Licensing Division Canadian Nuclear Safety Commission 280 Slater Street P.O. Box 1046, Station B OTTAWA, Ontario KIP 5S9 9~ (c{?l1-\~1 "",. \.- ~, (\\\ ' SA-~n.x~~<~~,c, " Dear Mr. Santini: CHALK RIVER LABORATORIES (CRL) APPLICATION FOR OPERATING LICENCE RENEWAL (SUPPORTING REFERENCE MATERIAL) Further to Atomic Energy of Canada Limited's (AECL) application [1] to renew the Nuclear Research and Test Establishment Operating Licence [2] for Chalk River Laboratories (CRL), this letter will serve to provide additional supporting reference material in accordance with your original request [3]. The letter previously submitted by AECL [1] provided application material consistent with the legal requirements to renew the operating licence [2] for CRL, and further provided a suite ofnewly prepared reference documents [4 to 8] which constitute the management system to support the application. These management system reference documents will be maintained and periodically updated throughout the proposed period of the renewed licence. This letter provides further supplementary infoffilation in support ofthe application [1] and specifically focuses on the ten item list on page 2 of your letter [3]. Accordingly, Appendix A provides a summary of the ten items indicating those for which information was previously provided with the original application letter [1], or provides indication how the relevant information for CRL has been further provided as Appendices B, C and D to this letter. Finally, Appendix E presents some supplementary background material specific to the National Research Universal (NRU) reactor. Chalk River Laboratories Laboratoires de Chalk River Chalk River, Ontario Chalk River (Ontario) Canada KOJ 1JO Canada KOJ 1JO (613) (613) Tel.: (613) Tel. : (613)

2 M. Santini November 30 CRL-ACNO-I L AECL trusts that the enclosed supporting reference application material is satisfactory for your purposes. If you require any further information please contact Mr. Dave Cox, Director - Safety Engineering and Licensing at , extension or mysel Yours sincerely, E.S. (Hank) Drumhiller Vice-President Operations Chief Nuclear Officer Site Licence Holder - Chalk River Laboratories E(H)D/jc References: [1] E.S. Dnlmhiller, Letter to M. Leblanc, Chalk River Laboratories (CRL) Applicationfor Operating Licence Renewal- 2011, CRL-ACNO L, 2010 September 30. [2] Chalk River Laboratories, Nuclear Research and Test Establishment Operating Licence, NRTEOL-01.07/2011. Expiry Date: 2011 October 31. [3] M. Santini, Letter to W.S. Pilkington, Applicationfor the Renewal ofthe Chalk River Laboratories Operating Licence, CRL-NOAC L (E-docs: ),2010 May 10. [4] Research and Technology Operations, Management System, Manual MAN-001, Revision 0, 2010 September. [5] Management System Governing Documentation Index, GDI-001, Revision 0, 2010 September. [6] Sites and Facilities Governing Documentation Index, GDI-002, Revision 0, 2010 September. [7] Management System Contact and Responsibility List, , Revision 0, 2010 September. [8] Organization to Support CRL Operations, CRL RG-001, Revision 0, 2010 September.

3 M. Santini November 30 CRL-ACNO-I L Appendices: A. Summary Information Regarding the Ten Items Listed on Page 2 of Reference [3] B. Information on Approach to Safety at CRL C. Information on Performance, Opportunities for Improvement, and Safety Improvements at CRL D. Information on the Proposed Operating Plan for the Next Licensing Period and Significant Longer Term Activities at CRL E. Supplementary Background Material on the NRU Reactor c. C. Nache (CNSC) N. Riendeau (CNSC) A. Ashworth T. Arthur J. Bond S.J. Bushby J.E. Chilton D.S. Cox C. de Vries J.D. Garrick W.C.H. Kupferschmidt V.J. Langman R.G. Lavoie R.M. Lesco J. McKenna 1.M. Miller J.R. Walker R. Walker A.J. White >CR CNSC Site Office >CR Licensing >SRC

4 M. Santini November 30 CRL-ACNO-10-00S4-L Appendix A: Summary Information Regarding the Ten Items Listed on Page 2 of Reference [3] Item Information Requested AECL Response 1 Summary ofprograms with reference as appropriate to supporting documentation. Information on the nuclear programs supporting operations at CRL was previously provided within the enclosures sent with the application letter [1]. Specifica11y, information on the management system which enables the estab1ishment and maintenance ofappropriate nuclear programs is contained within the manual [4], previously submitted with [1]. In particular, Appendices B.8, B.9 and B.1 0 of [4] define the business processes for the various nuclear programs in place at CRL, and the applicability to the legal requirements ofthe Canadian Nuclear Safety Commission (CNSC) regulations which pertain to the CRL site operating licence. The management system encompassed by this manual, and other supporting documentation, has been prepared in accordance with the requirements of CSA N Further particular material on sub-tier and other supporting documentation for the various nuclear programs has been submitted in the form ofthe governing documentation index [5], previously provided with [1]. The process numbering system (5xxxxx) established in the top level manual [4], is employed throughout the lower level documentation index [5], to effect seamless crossreferencing ofthe various sub-level program documents.

5 M. Santini November 30 CRL-ACNO L Appendix A: Summary Information Regarding the Ten Items Listed on Page 2 of Reference [3] Item Information Requested AECL Response 2 Description ofthe approach to safety, including reference to corporate standards to which the CRL must adhere. 3 Information on CRL performance, including each of the program/safety areas (as defined in Attachment B ofcnsc letter [3]). Relevant supplementary material on the approach to safety at CRL, and corporate standards, is presented as Appendix B to this letter. Relevant information on CRL performance for the various program/safety areas is presented within Appendix C to this letter. 4 Assessment ofexisting safety challenges. Relevant information with respect to existing safety cha11enges at CRL (indicated as opportunities for improvement) is presented within Appendix C to this letter. 5 Safety improvement plans during the next licence period. Relevant information regarding safety improvement at CRL during the next licence period is presented within Appendix C to this letter. 6 Proposed detailed operating plan for the next licensing period. 7 Information on significant activities envisaged beyond the end of the next licensing period. 8 Reference to any federal, provincial, municipal or other regulations, by other authorities besides CNSC that AECL must abide by. Relevant information on the proposed detailed operating plan for the next licensing period at CRL is presented within Appendix D to this letter. Relevant information on significant activities at CRL envisaged beyond the end of the next licensing period is presented within Appendix D to this letter. Specific information on other regulations may be found in section (Codes, Regulations and Standards) ofthe governing documentation index [5], previously provided with [1].

6 M. Santini November 30 CRL-ACNO-I L Appendix A: Summary Information Regarding the Ten Items Listed on Page 2 of Reference [3] Item Information Requested AECL Response 9 Reference to any permits, certificates, or licences that have been issued to CRL by other authorities besides CNSC. 10 A description of duties that CRL has for other municipal, provincial or federal authorities, and public and/or private organizations. Specific information on permits, certificates, and licences from other authorities may be found in section (Other Permits, Licences and Certificates) of the governing documentation index [5], previously provided with [1]. Specific information on duties relating to organizations other than the CNSC may be found in section 5.6 of the management system manual [4], previously submitted with the renewal application [1]. Relevant information is provided regarding: Research and Development Emergency Preparedness World Association ofnuc1ear Operators (WANO) and Institute ofnuclear Power Operations Other customers, partners and stakeholders

7 M. Santini November 30 CRL-ACNO-I0-00S4-L Appendix B: Information on Approach to Safety at CRL The approach to achieving safety in carrying out work in Research & Technology Operations (RTO) is underpinned by a commitment to building a strong safety culture, adoption of W ANO safety principles (W ANO GL , Principlesfor a Strong Nuclear Safety Culture) that guide day-to-day activities, and the responsibilities on employees, management and the executive defined in the AECL Corporate policy on Employee Health and Safety (00-009), which states: "At Atomic Energy of Canada Limited (AECL), our top priority is to provide a safe and healthy working environment." "Prevention of dangerous or hazardous situations and appropriate proactive strategies to positively impact and continuously improve all aspects of Health and Safety, are considered fundamental in everything we do." "We comply with applicable health and safety laws, requirements, and recognized standards and guidelines appropriate to our activities to protect our employees, contractors, visitors, physical assets and the public." "We achieve nuclear safety by providing proper operating conditions, preventing accidents and providing for mitigation of accident consequences, and in doing so we adhere to the principle of ALARA (As Low As Reasonably Achievable...) to minimize radiological impacts on workers, the public and the environment." "AECL is committed to making every reasonable effort to elinlinate or control hazards that may cause workplace incidents by integrating appropriate Health and Safety requirements into all phases of our business activities including product development, project planning, project implementation, operations and decommissioning." "All employees have the personal responsibility to protect their own health and safety, that of their fellow employees and that ofthe public. All employees must learn and comply with the safety rules applicable to the proper discharge of their employment responsibilities." "Working safely is a condition of employment, and employee participation is considered fundamental to our success." Appendix A ofthe RTO Management System Manual [4] provides an explanation of how the eight principles for a strong nuclear safety culture are to be applied by management and staff while performing work in RTO. In applying the W ANO principles, the definition of safety must be understood, the plant must be operated in a manner that ensures it remains within this safe operating envelope and finally it must be possible to demonstrate that safety continues to be achieved (i.e., safety assurance is established). B.I Definition of Safety Research & Technology Operations is a complex organization that undertakes a wide variety of work. In carrying out this work, safety is put as the highest priority. In establishing this priority, it is recognized that "safety" in the organization covers a broad range of areas where the health

8 M. Santini November 30 CRL-ACNO-I L and well-being of workers or visitors as well as that of the wider general public and/or the environment could be threatened. The general approach taken is to ensure that RTO sites and facilities are "safe" by design and that they are "safe" during all stages ofoperation. It is important to recognize, that any aspect of site operation can have consequences in other areas ofthe site that must be understood and effectively managed; this is especially the case for critical elements of site infrastructure. In the context of the development, production and use of nuclear energy and the production, possession and use ofnuclear substances, prescribed equipment, and prescribed information, "safe" means the prevention of unreasonable risk to the public, environment and to the health and safety ofpersons, associated with that development, production, possession, or use. There are two aspects to the basis of safety; the first is a definition ofwhat safety means, that is to say the definition of"acceptable" risk, while the second is the implementation of the necessary assured operational programs to ensure that safety limits are not exceeded. All aspects of safety (Le., product, personal, public, and environment) are managed through the processes defined in the RTO Management System Manual [4]. However, the degree ofrig our applied should be proportional to the level of risk associated with the specific facility. Risk is defined as a permutation ofthe hazards present, the potential consequence ofthese hazards, and the duration of exposure to the hazard. Across RTO, risk-based safety cases are developed through analysis, to define the specific radiological and conventional safety targets for each of the safety acceptance criteria appropriate to the facility. Safety acceptance criteria address the following states: normal operation, abnormal operation, design basis events, and beyond-design basis events. Safety acceptance criteria are established for: operations personnel, site workers, the public, and the environment. These acceptance criteria form the basis of design requirements, including degree of rigour in the process to be followed for new facilities and for changes to existing facilities, and for assessing the dependencies between operations in nuclear facilities and non-nuclear infrastructure. B.2 Achieving Operational Safety Safe operation is achieved by fohowing a number of key programs and processes, each with a focus on a specific safety area. They include the following processes, which are described in the RTO Management System Manual: Manage Nuclear Materials and Safeguards;

9 M. Santini November 30 CRL-ACNO-I L Manage Transportation of Radioactive Materials; Provide Nuclear Criticality Safety Control; Manage Waste; Provide Physical Security; Provide Fire Protection; Provide Emergency Preparedness; Provide Radiation Protection; Provide Operating Experience; Provide Safety Analysis and Operational Safety Assessment; Manage Environmental Protection; and Ensure Employee Safety and Well-being. Other supporting processes such as maintenance and work planning are carried out within the overall safe operating envelope. B.3 Assurance of Safety Assurance of safety is achieved in a number ofdiverse methods. There are several key comnlittees involving employees at all level ofrto. Site Safety and Health Committees: Safety and health committees at the various sites are dedicated to the promotion and improvement ofthe safety and health ofemployees and is the principal forum for joint employee/management consultation and development of solutions on safety and health concerns in the workplace. Nuclear Performance Assurance Review Board (NP ARB): The NPARB reviews the performance and effectiveness ofnuclear facilities and the implementation of supporting processes/programs required to achieve operational excellence. The board monitors the interfaces between facilities and the processes/programs and resolves any obstacles to effective implementation of identified actions. Safety Review Committee: Is an internal body, independent of line management that is responsible for providing a high level of independent oversight and confirming that all Health, Safety, Security, and Protection ofthe Environment (HSSE) controls are in place, including independent review of facilities and of products and services developed by RTO. As well as these formal committees, the responsible authorities for the nuclear facilities, both design and operational, require confidence that each facility has been designed and is operated within the safe operating envelope identified in the applicable safety case. Self-assessment of adherence to design and safety analysis processes, change control processes, and operating procedures for the facility, contribute to safety assurance. In addition to program-specific measures, monitoring of safety performance in the operational area is achieved through the concept of "events" and the associated record of"event Free Days", as described in the R TO Management System Manual. This is a fundamental measure of our safety performance that is made visible to all employees at CRL and is a key element in ensuring RTO staff remains engaged and committed to safety at all times.

10 M. Santini Noventber 30 CRL-ACNO-I0-00S4-L B.4 Improvement to Safety Management An enhancement to the RTO approach to safety will include an over-arching safety case for the whole CRL site identifying the various operations and facilities at CRL, including the radiological laboratories and non-nuclear supporting infra-structure. This over-arching site safety case will contain: A description ofhow site-wide safety aspects are addressed and integrated into specific "lower order" safety cases (Le., the apportionment of site risk to facilities/operations). Identification ofcommon site-wide information (e.g., Site Characteristics). Establishment of site design bases from site safety documentation (e.g., flood, seismic, meteorology, Class IV power, external fire etc.). This site safety report will be supplemented by the specific safety cases for the Class-l and Class-2 nuclear facilities, which will, in turn, be compliant with CNSC requirements and consistent with International Atomic Energy Agency (IAEA) guidance, as appropriate and applicable. These safety cases shall be updated periodically, and analyses shall be maintained up-to-date to ensure alignment with changes in plant configuration, evolution of operating procedures and plant condition (Le., system and component aging).

11 M. Santini November 30 CRL-ACNO-I L Appendix C: Information on Performance, Opportunities for Improvement and Safety Improvements at CRL The following information is provided in sequence and accordance with the listing of 14 various Safety and Control Areas as defined in Attachment B of CNSC letter reference [3]. C.l Management System C.l.l Infornlation on Performance Since Licence Renewal in 2006 AECL made several improvements to the documents and infrastructure that govern RTO work activities which are consistent with recent industry developments in management systems. Inlprovements have focussed on integrating quality, safety, environmental, and regulatory requirements into user-friendly documents that facilitate process ownership, comprehension, and adherence. This approach is aligned with current international (IAEA) and Canadian (CSA N286) standards for the nuclear industry. As opposed to the more narrowly focussed conventional "Quality Assurance" documents, the new Management System manual [4] consolidates the following: management commitment to the development, implementation and continuous improvement ofthe management system; safety (safety culture and safety management); management principles (those from ISO-9001 and CSA N286-05); overview ofrto/nuclear Laboratories; nuclear operations; responsibilities and organization; business process; governing documentation; and measurement, assessment and improvement. The manual includes the following supporting documents: A Governing Documents Index (GDI) document listing external requirements, company policies and manuals, and governing documents to support business processes issued for general use within the organization. A GDI document listing the main governing documents for sites and facilities managed and operated by RTO. A Contact and Responsibility List listing the names of individuals responsible for the departments, facilities, laboratories and supporting processes and programs. C.1.2 Assessment of Opportunities for Improvement Opportunities for improvement include the following: Implementation of the business process management model is a large, complex task affecting all organizations in R TO. Benchmarking with international and national nuclear facilities is

12 M. Santini Noveulber 30 CRL-ACNO-I L ongoing to develop an effective change management plan. Benchmarking to date has demonstrated that a systematic, gradual approach is most effective for establishing a sustainable management system. Quality Assurance support ofthe Operations organization was strengthened in a recent reorganization, and minor adjustments are ongoing to establish strong process owners within the Operations organization. Some processes will need to be revised to fully comply with the CSA N requirements and other requirements covered in the Management System manual [4]. At present a detailed gap analysis is being conducted to develop an action plan. Subsequent improvement activities will be prioritized accordingly. Improvement activities will be aligned with those being defined under Isotope Supply Reliability Project (ISRP) in the NRU Integrated Implementation Plan (IIP). C.1.3 Safety Improvement Plans During the Next Licence Period Planned activities include: Strengthen process documentation, support and oversight by establishing an effective supporting group to oversee the implementation of the Management System. Terms of Reference for a cross-functional Management System Working Group will define appropriate membership, mandate, requirements, and responsibilities. Upon revising existing governing documentation and preparing new governing documents, ensure alignment with Management System manual [4]. This to include ensuring integration amongst the processes and programs and removing or reducing duplication of information. C.2 Human Performance Management C.2.1 Information on Performance Since Licence Renewal in 2006 The Operational Experience (OPEX) process has undertaken many improvements since licence renewal in Most notable of these was the introduction of the Improvement Action (ImpAct) process to facilitate and encourage increased event reporting. This increased reporting culture has led to a dramatic increase from events (mostly high significance issues) reported in 2006 to more than ImpActs raised during This has enabled increased awareness of lower significant items that when resolved in a timely fashion, contribute to a reduction in the number of higher significance issues and events. In addition, the introduction of the Event Free Day Reset Metric has provided management with a single key metric to highlight those events where deficiencies in human performance have contributed to the occurrence of significant events. The use of Event Free Tools has been introduced across RTO with a view to improving how work is performed both safely and efficiently. An Observation and Coaching program has also been introduced which is designed to get supervisors in the field to directly provide staff coaching (using event free tools) on how best to accomplish the task at hand, to reinforce the expectations and to monitor if those expectations are being met. The OPEX program has piloted improved trending methodologies with these being improved for general use. Development of root cause analysis methods with enhanced training (with external contacts) has been provided to the analysts in order to improve the quality of event reports.

13 M. Santini November 30 CRL-ACNO-I L Apparent Cause Analysis training has also been improved to develop competencies in the line. The OPEX program has introduced improvements on how operating experience is disseminated to the line organizations. This was improved through the raising of OPEX ImpActs but now an improved process is being piloted with the operations staff to get the information to those who need to know in a more timely and efficient process. This is scheduled for wider use by the end ofthe fiscal year. The OPEX program now includes a Change Management section specifically tasked with supporting change initiatives across RTO. Industry best practices training in change management methods has also been provided to line field consultants, such that the expertise is available to those who need it in a timely manner to improve how changes are implemented and communicated. The Performance Improvement and Nuclear Oversight (PINO) organization, that includes all of the above, also is tasked with conducting performance based audits using the W ANO Performance Objectives and Criteria as the benchmarks. These audits, which go beyond compliance, have provided insights to line and senior management on program/facility performance and vulnerabilities. Over a three-year cycle all programs and nuclear facilities listed in the CRL licence have been reviewed. The group also conducts audits to fulfill the compliance requirements ofthe Pressure Boundary, Environmental Management and Dosimetry programs. C.2.2 Assessment of Opportunities for Improvement Opportunities include improving the ImpAct process and reducing barriers to its usage by staff, improving identification ofeffective corrective actions, increasing timeliness of cause analysis and improving management oversight. Improvements to human performance are a major component ofthe organizational improvement program, Voyageur Program Phase II that has been established to address safety culture findings, and events such as the NRU reactor vessel leak. C.2.3 Safety Improvement Plans During the Next Licence Period Work will continue on the introduction of improvements in reporting culture, completion of performance based audits to enhance the strictly compliance reviews, improvements to the cause analysis methodologies, and the introduction of Human Performance methodologies. C.3 Operating Performance C.3.1 Information on Performance Since Licence Renewal in 2006 All CRL nuclear facilities have operated safely over the licence period ending 2011 October 31 and it is expected that they will continue to be operated safely over the next licence period. In particular, continued safe operation ofthe NRU reactor in the next licence period will be supported by the timely execution of the NRU lip (See section CA. 1 ). Chalk River Laboratories recognizes that further work to refurbish the NRU systems, structures and components (SSCs) is required to improve the future reliability ofnru operation. The priority ranking ofthe various items of refurbishment work will be established in the NRU lip, which is technically supported

14 M. Santini November 30 CRL-ACNO-I L by the NRU Global Assessment Report (GAR). Both the lip and the GAR are currently being completed by AECL and will be submitted to the CNSC by 2011 February 28 as part of the NRU Integrated Safety Review (ISR). Detailed information on the operating performance ofthe nuclear facilities at CRL has been presented in the annual safety review documents prepared and submitted to CNSC staff in accordance with the site operating licence condition. C.3.2 Assessment of Opportunities for Improvement The implementation ofthe second phase ofthe NRU reactor ISR, as referred to in section C.4.1, will result in improvements for all facilities at CRL. C.3.3 Safety Improvement Plans During the Next Licence Period During the next licence period, AECL will continue to work on refurbishing SSCs important to the safe and reliable operation ofnru, training additional NRU certified staff and maintenance staff as well as improving NRU management processes. Timely execution of the lip work program will not only support continued safe operation ofnru; it is expected to enhance the reliability ofnru operation. A graded approach to safety improvements will be applied to all nuclear facilities throughout the next licence period. The operating performance of all CRL nuclear facilities will continue to benefit from the high quality performance audits conducted by PINO. Operations and maintenance procedures will continue to be improved and TRAK 1 will continue to be used to provide efficient access to the correct procedures. Furthermore, training ofnru staffwill continue, as required, to maintain very experienced operations and maintenance staff. Execution of the vessel repair and the Extended Activities Program (EAP) during the recent extended shutdown ofnru (2009 May to 2010 August) has provided AECL with valuable experience which will be used in the planning of future annual extended outages. Planning the detailed scope and execution of non-routine work at NRU will continue to benefit from the review and assessment of a dedicated, multidisciplinary team. Based on the priorities established in the NRU lip, AECL will address attaining and sustaining improvements to various degrees in the following areas: 1. safety culture; 2. provision of adequate numbers oftrained certified and support staff, including the development of an integrated succession plan; 3. meeting regulatory commitments in a timely manner; 4. basing procedures on industry best practice and adhering to procedures; 5. timely and efficient execution of work; 6. timeliness of identifying problems, developing corrective action plans and executing corrective action plans; and 7. effective use of internal and external OPEX. TRAK is AECL's Corporate Document ControllInformation Management System.

15 M. Santini November 30 CRL-ACNO-I L C.4 Safety Analysis C.4.1 Information on Performance Since Licence Renewal in 2006 Criticality Safety Program documentation to meet current Licence Condition 14 (ANSI/ ANS-8 series of standards) was established and put into use (Requirements, Overview, Governing Document Index and Procedures). Generic training on the program has been completed, and facility-specific training plans for each nuclear criticality controlled area are under development. Several procedure documents for performing safety analysis were issued or revised. Work has been initiated on a Conduct of Safety Engineering to provide an overall process for integrated safety analysis. Facility Safety Analysis Reports (FSARs) were revised, reviewed and approved for the NRU reactor, the Zero Energy Deuterium (ZED-2) reactor and five other CRL facilities. Revisions are in progress for the remaining six FSARs to be completed in the current licence period. Revision of the first high priority Criticality Safety Document (CSD) to meet the requirements of the ANSI/ ANS-8 series of standards was completed. The processes and procedures involved in the revision have been evaluated and lessons learned will be applied to subsequent CSD revisions. Statements of upper sub-critical limits have been incorporated into several other CSDs and a standard format has been established to ensure consistency in the documents. All nuclear criticality controlled areas are being evaluated and work is being planned to ensure that AECL can demonstrate compliance with licence conditions associated with criticality alarms. An ISR of the NRU facility was launched to provide a detailed and systematic review ofwork that would need to be performed to ensure ongoing safe operation ofnru beyond 2011 October 31. The ISR is contributing to an improved definition ofthe NRU safety basis. The scope of the ISR was established using guidance from the IAEA Guide: Periodic Safety Review ofnuclear Power Plants (NS-G-2.10, 2003) and the CNSC Regulatory Document: Life Extension ofnuclear Power Plants (RD-360, 2008 February). The NRU ISR is being performed in two phases: In the first phase, NRU was assessed against the requirements of modern codes and standards for 17 safety factor areas (see Table C-l). The results ofthis assessment identified the strengths ofnru as well as any gaps against modern codes and standards, as a function of the 1 7 safety factors. The second phase ofthe NRU ISR is referred to as global assessment. The work in this phase yields a GAR and an lip. The GAR assesses the range of issues relevant to the future operation ofnru and establishes the priority of addressing these various issues based on the safety and/or isotope supply reliability impact ofany given issue. The GAR also provides an overall assessment ofthe acceptability ofthe integrated safety and reliability risks of operating the NRU reactor beyond 2011 October 31. The lip describes AECL' s work plan for addressing the range of issues cited in the GAR.

16 M. Santini November 30 CRL-ACNO-I L Subject Area Table C-l: Seventeen Safety Factor Areas (NRU Reactor) Plant 1 Plant Design Safety Factor 2 Actual Condition of SSCs 3 Equipment Qualification 4 Aging Safety Analysis 5 Deterministic Safety Analysis Performance and Feedback of Experience 6 Probabilistic Safety Analysis 7 azard Analysis 8 Safety Performance 9 Use of Experience from Other Plants and Research Findings Management 10 Organization and Administration 11 Procedures 12 Human Factors 13 Emergency Planning 14 Quality Management Environment 15 Impact ofnuclear and Hazardous Substances Security and Safeguards 16 Safeguards 17 Security C.4.2 Assessment of Opportunities for Improvement Current FSARs for CRL's nuclear facilities have been developed over many years. Therefore, these FSARs do not follow a standard format, nor is the content graded based on risk significance. The NRU ISR has identified gaps between the deterministic and probabilistic safety analysis. An over-arching site-wide safety case is being developed as described in Appendix B (Section B.4). C.4.3 Safety Improvement Plans During the Next Licence Period Execution of improvement actions defined in the NRU lip. Some examples ofthese improvements include the following: Establish procedural guidance and analytical reliability targets for systematic definition of Operating Limits and Conditions and alarm set points. Strengthen level ofdetail in deterministic safety analysis event sequences.

17 M. Santini November 30 CRL-ACNO L Implement a comprehensive uncertainty analysis for key events in deterministic safety analyses. Align safety analysis with plant condition and plant configuration. Implementation of Conduct of Safety Engineering, including developing an over-arching site safety case to capture interactions between facilities and CRL support infrastructure. Modernization of FSARs to meet current standards and integration within a site-wide safety case. Update CSDs per a risk-based prioritization. C.5 Physical Design C.5.1 Information on Performance Since Licence Renewal in 2006 Design oversight and change control has been significantly strengthened since 2006, establishing a new organizational infrastructure as well as new and improved processes for Design, Engineering Change Control, Field Change Control, Item Equivalency Evaluations and Technical Operability Evaluations. The Chief Nuclear Engineer position was created, and was appointed as the Design Authority for the nuclear laboratories. This role is responsible for authorizing all design changes, and ensuring that all design, safety and licensing requirements are satisfied prior to construction. Process improvements were made based on benchmarking of Canadian nuclear utilities as well as the W ANO Performance Objectives and Criteria. Change control has been expanded to the whole CRL site, and a more rigorous risk assessment process has been established to screen design changes. The Engineering Change Control Office was established to monitor all changes from initiation through to closeout to ensure that engineering and operational documents and drawings were updated prior to closeout. This oversight and the establishment ofthe Configuration Management Oversight Committee have significantly improved configuration management at the CRL site. Management and implementation of the Pressure Boundary program has been significantly strengthened since The Chief Nuclear Engineer was appointed as the Program Authority, tasked with ensuring effective implementation of the program requirements within RTO. The cross-functional Pressure Boundary Working Group provides managerial oversight and ongoing assessment of all aspects of the program, meeting monthly to evaluate performance indicators, self assessments, ImpActs and other areas for improvement. The Pressure Boundary program office was established, with pressure boundary specialists dedicated to supporting the program. An Authorized Inspection Agency agreement was established with the TSSA in 2009, as required, to provide continuing jurisdictional oversight of Pressure Boundary program and activities. With specific regard to the NRU reactor, the NRU ISR has recognized that the plant has a number of design strengths. Examples ofthose relevant to safety include: 1. NRU has a much larger than necessary shutdown margin. As a result, shutdown following an accident is guaranteed even if some ofthe rods fail to drop into the core. 2. NRU has a large number of shutdown system trip parameters resulting in substantial diversity and redundancy in the trip initiation function.

18 M. Santini November JO CRL-ACNO-I0-00S4-L 3. The heat removal capacity of the secondary side for NRU is 400 MW which is well in excess of the normal operating thermal power of 135 MW. As a result, not all of the eight 50 MW heat removal circuits are required to function ay any given time. 4. The reactor operates at very low pressure and temperatures compared to power reactors. As such, the driving initiators for potential failures in the process systems are far less challenging to the integrity of those systems. C.S.2 Assessment of Opportunities for Intprovement Consistent with a graded approach to the other nuclear facilities at CRL, improvements from the NRU ISR and the improved design processes described above in C.5.I will be implemented across the site accordingly. Audits have demonstrated that individual roles (e.g., welders, quality control inspectors, specialized engineers) satisfy the clearly defined qualification and certification requirements. However, the general awareness of staff and management with the ability to affect pressure boundaries is an area for improvement. A training plan for staff and management with roles in the Pressure Boundary program was established, and training modules are being developed to establish a broad understanding of the overall program requirements. To date, the first general awareness module has been completed and piloted, and modules for nuclear and non-nuclear program requirements are being developed in fiscal year 2010/2011. C.S.3 Safety Improvement Plans During the Next Licence Period Based on the priorities established in the NRU IIP, AECL will address attaining and sustaining improvements to various degrees in the following areas: 1. Adequacy of design documentation to assess the design against current codes and standards. 2. Configuration management and the safety assessment and human factors aspects of Engineering Change Control. 3. Configuration management and validation of software used in analysis. 4. Seismic qualification requirements to current standards. 5. Fire protection requirements with respect to current standards. 6. Human Factors requirements against current standards. 7. Modern design standards as applied to existing systems. 8. Nuclear criticality safety alarm system assessment. Although the previous discussion relates mostly to the NRU reactor, there are expected to be spill-over benefits to the other nuclear facilities. C.6 Fitness for Service C.6.1 Information on Performance Since Licence Renewal in 2006 As cited in the AECL Commission Member Document (NRU Vessel Leak Repair for CNSC Hearing, 2010 June), and concurred in the CNSC Commission Member Document (AECL NRU Reactor Return to Service, 2010 June) submitted in relation to returning the NRU reactor to

19 M. Santini November 30 CRL-ACNO-I L service, from a safety perspective the NRU reactor is fit for service. However, it is also recognized that aging degradation of a number of the NRU safety-related SSCs, could result in issues that could affect the reliable operation ofnru. The concern is that aging degradation problems with NRU SSCs could result in an unplanned reactor shutdown which would necessitate a potentially extended outage to effect repairs. During the EAP associated with the extended shutdown for vessel repair, work was performed to refurbish a number of the NRU SSCs with the most significant aging-related degradation effects. The priority for future continued refurbishment ofnru will be based on the results of the NRU ISR work related to Safety Factor 2, "Actual Condition of SSCs". Contributing to this is an ongoing exercise, directed by senior NRU technical staff and supported by AECL Sheridan Park engineering staff, to clearly document the technical basis for AECL's understanding of the current condition of, and leading contributors to, aging-related degradation of the NRU SSCs. This work will also be used to further enhance the effectiveness of the NRU aging management plan, the documentation for which was recently updated (NRU Aging Management Plan, NRU PLA-002, Revision 0, 2010 September). C.6.2 Assessment of Opportunities for Improvement Please refer to information in section C.6.1. C.6.3 Safety Improvement Plans During the Next Licence Period Based on the priorities established in the NRU IIP, AECL will address attaining and sustaining improvements to various degrees in the following areas: 1. Lack of implementation of many recommendations from earlier Condition Assessments and Life Assessments ofthe NRU SSCs. 2. Lack of an Equipment Qualification List and gaps with respect to current equipment qualification standards, notwithstanding the fact that NRU operating conditions are relatively benign compared to power reactors. 3. Aging management and system health monitoring programs have not been fully developed and have not been effectively implemented. 4. Maintenance program gaps relative to current standards and gaps relative to assurance of equipment qualification and aging management. Although the previous discussion relates mostly to the NRU reactor, there are expected to be spill-over benefits and graded application to the other nuclear facilities. C.7 Radiation Protection C.7.1 Information on Performance Since Licence Renewal in 2006 Overall, during the current licence period of2006 August to date, AECL's Radiation Protection (RP) Program met the intent ofthe objectives and expectations of the CNSC Radiation Protection Regulations and AECL's Health and Safety policy (00-009). Radiation dose performance remained stable.

20 M. Santini November 3'0 CRL-ACNO-I L AECL's RP Program is a fully implemented, mature program that is continuously monitored and undergoes any identified improvements as appropriate. AECL's RP Program is designed and implemented to ensure AECL's activities comply with, or exceed, the level of radiation safety that is required by the Nuclear Safety and Control Act and the associated Radiation Protection Regulations. The program is governed by AECL's Radiation Protection Requirements document and the companion Radiation Protection Manual. Over the review period, the reporting environment and culture for radiation protection related events has significantly improved. Through the use ofthe ImpAct reporting process, areas for improvement have been identified and actions have been implemented as required. Two PINO audits carried out in 2006 and 2009 resulted in a number of improvement initiatives being identified and implemented. These initiatives concentrated primarily on compliance requirements and contamination control. During the period 2006 August to date, the largest individual dose has been maintained below 20 msv. Achieving a maximum dose below 20 msv/a (an AECL Action Level) ensures compliance with the five-year dose limit (l00 msv in five years). During the review period, no worker at CRL received a dose (delivered plus committed, at any site) in excess of any of the respective radiation dose limits for radiation workers, as defined in the Radiation Protection Regulations. All workers and visitors at CRL who received annual doses approaching or exceeding 1 msv during the review period had previously been designated as Nuclear Energy Workers. C.7.2 Assessment of Opportunities for Improvement AECL's RP Program is continuously identifying areas for improvement and evolving. Current areas identified as opportunities for improvement are: further improvement in contamination control, and management of doses within and by each facility. Currently underway and to be continued into the period ofthe renewed licence, are initiatives to improve the overall safety culture, specifically in radiation protection, and updating/modernizing key radiation protection equipment to meet or exceed industry best practices. C.7.3 See Section C.7.2. Safety Improvement Plans During the Next Licence Period C.S Conventional Health and Safety C.S.l Information on Performance Since Licence Renewal in 2006 Since licence renewal in 2006 there has been no observable adverse trend in the recordable lost-time accident frequency for activities at the CRL site. Similarly, no observable adverse trend is noted for the severity of lost-time accidents. Medical and first aid events have remained steady throughout.

21 M. Santini November 30 CRL-ACNO-I L C.8.2 Assessment of Opportunities for Improvement Current areas identified as opportunities for improvement are: The Incident Management system requires upgrading to improve timeliness of incident investigations. The procedure and supporting documentation need to be revised and followed with training for supervisors/managenlent. The Contractor Management process needs to be improved. Occupational Safety & Health (OSH) processes need to be included in the management system. Initial OSH training needs to be upgraded and refresher training needs to be developed for selected OSH elements. C.8.3 Safety Improvement Plans During the Next Licence Period Current plans include: Implementation of an Incident Management system integrated with existing AECL processes. Work in progress with Devonway to integrate ImpAct process with incident/injury reporting. This will require an updating ofassociated procedures and the development ofrelated training. Contractor Management program developed to include systematic oversight. Implementation of ISO/OHSAS or comparable system such as CSA Z1000. Training matrix developed and implemented to include refresher and recertification requirements. Refresher training will need to be developed. C.9 Environmental Protection C.9.1 Information on Performance Since Licence Renewal in 2006 Environmental Performance at CRL is summarized through the CRL Site Environmental Monitoring Program which is comprised ofthree components; Radiological, Non-Radiological and Groundwater Monitoring. Together, these three components comprise contaminant pathway monitoring at CRL, enabling the tracking of contaminants throughout the different compartments ofthe geosphere and biosphere. All components ofthe monitoring program are designed to confirm that releases remain as low as reasonably achievable, social and economic factors being taken into account (ALARA). Monitoring results for the 2006 to 2010 period verified that the levels of radiation and radioactive contaminants in the environment outside the CRL site due to operations at the site, and resulting radiation doses to members ofthe public, were below the regulatory limit of 1 msv/a. The 2009 and 2010 results were lower than the period 2006 to This is consistent with expectations from the NRU reactor vessel leak, where a small portion of water from the vessel leak was evaporated into the environment, and the fact that NRU was in safe shutdown from 2009 May until 2010 August.

22 M. Santini November 3D CRL-ACNO-I L Non-radiological monitoring results for 2010 were consistent with the previous four years and verified that levels of non-radiological contaminant releases from operations at the CRL site did not negatively affect the quality ofwater on-site. Groundwater monitoring results for 2010 from around the perimeters ofthe Waste Management Areas (WMAs) and other nuclear facilities and locations within the CRL site confirm that, for the most part, the conditions did not change significantly from previous years. At the monitoring sites where impacts are observed, trending of key parameters show that in most cases the groundwater concentrations remained at similar levels or have decreased (indicating stable or improved environmental performance), and the changes that occurred were consistent with long-term trends. Ofthe 26 sites subject to groundwater monitoring, the only trend of significance that, in tum, is causing contaminant concentration and flux increases in surface waters is with tritium at the southern and south western region of WMA B. Tritium in this area is attributed to the historical emplacement oftritium-containing solid wastes in concrete bunkers and the limited ability of waste packaging and concrete containment to contain tritium vapours. Given the nature of the waste containment, the results are expected and the performance is considered normal. A project to remove the tritiated water from the NRU rod bays is well advanced. An environmental assessment has been completed, and the project is currently examining detailed design options with respect to storage tank design and transfer equipment. Once implemented, this project will result in a significant lowering ofnru rod bay tritium concentrations. C.9.2 Assessment of Opportunities for Improvement Challenges to the Environmental Protection Program are well understood due to the significant oversight mechanisms applied to the program. C AuditlInspection The Environmental Management System at CRL is an ISO registered system. Over the five year licence period, the program was subject to five annual compliance audits by an external auditor, five internal audits, one CNSC Type II Inspection and one CNSC Type I Inspection. The outcomes from these audits fall into the following categories: program documentation (revision updates), Legal Registry, evaluation of legal compliance, emissions (Tritium and Argon), and monitoring (calibration and maintenance). All findings from the CNSC Type I inspection (action notices and recommendations, no directives - consistent with the areas listed above) will be conlpleted by 2011 July.

23 M. Santini November 30 CRL-ACNO-IO-0054-L C.9.3 Safety Improvement Plans During the Next Licence Period Over the next five years improvements in the CRL Environmental Protection Program will be gained through the implementation of: CSA N , Environmental Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills; and, CSA N , Effluent Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills. Additionally, Phase Two of the Ecological Effects Review will be conducted with a focus on site specific studies of environmental stressors. C.IO Emergency Management and Fire Protection C.IO.1 Information on Performance Since Licence Renewal in 2006 Since the effective date of the current CRL licence the Emergency Operations Centre (EOC) was activated on six occasions and there were no incidents of significant radiological or chemical releases June 20: Particulate monitor filter missing from the reactor stack effluent monitor after maintenance. Event was reported and equivalent monitoring identified so no stay-in required August 03: Class IV Power Outage February 09: Transportation accident at Stayner, Ontario. Packages remained intact with zero releases August 19: Building 320 fire incident. Precautionary stay-in was called May 14: Class IV Power Outage October 02: Building 330 power bar fire incident. The Senior Emergency Officer has been involved in the support of minor incidents where the EOC was not initiated. For example, in 2010 May, following a motor vehicle accident on Plant Road, the Site Emergency Officer authorized the successful use ofthe alternate evacuation Mattawa Road route. The Emergency Preparedness Program Manual was revised in 2007 and various processes and procedures have been updated. There have been no major changes as a result of regulatory changes. Highlights for the Emergency Preparedness Program include: All required annual drills and exercises completed. Submitted the CRL-specific component ofthe Provincial Nuclear Emergency Response Plan with Emergency Management Ontario (2010). Significant Improvements in Emergency Preparedness include: 1. CRL EOC upgraded. 2. Site siren system upgraded.

24 M. Santini November 30 CRL-ACNO-I L 3. ImpAct process used to track and monitor alliesson-leamed actions as a result of drills, exercises or incidents. 4. Cross-functional Exercise Design Teams develop exercises. 5. Emergency Operations Centre status board and EOC Assistant function added to EOC team. 6. Emergency status "hotline" to support communications during emergency situations. The Fire Protection Program has achieved the following since licence renewal in 2006: Monthly fire prevention inspections resulted in over resolved non-conformances. Sprinkler upgrades completed in 23 buildings. 26 fire alarm upgrades completed. 104 Fire Hazard Assessments (FHAs) completed, 26 FHAs under review, and 34 FHAs in progress. Significant improvements in Fire Protection since licence renewal in 2006 include: Fire Protection Program staff increased by nine personnel. Fire response shift complement increased from seven to nine. Addition of Training Officers and Deputy Chief to Fire Operations. Fire Protection Screening Process implemented to review all modifications with the potential to impact protection from fire. Monthly fire inspections consistently completed for all rooms of all buildings. Daily fire inspections completed in NRU. Fire Hazard Assessment implementation to plan. Wild Land Fire Prevention Program implemented. Monthly inspection of fire and exit doors. New Fire Hall constructed. Additional fire response equipment procured (Mobile Radio System, Command Vehicle, Mobile Compressor, Hydrocarbon response boat). Hot work management process improvements. Fire water supply assessment completed. Smoking policy implemented. C.I0.2 Assessment of Opportunities for Improvement The Emergency Preparedness Improvement Plan will continue to be implemented, revised, and prioritized as new needs arise. Current major activities over the next five years will address the following: Criticality alarms are becoming obsolete and system/processes will be upgraded by Criticality Program and Operations staff. The plan is to develop and implement more robust criticality emergency response.

25 M. Santini November 30 CRL-ACNO L Ability to justify the prioritization of formal emergency planning. The plan is to support risk based continuous improvement for emergency readiness (planning, training, documentation, exercises, personnel and equipment resources). Based on the priorities established in the IIP, there is a need to meet regulatory requirements for Severe Accident Management planning for NRU. The plan is to support the work started and integrate into the Emergency Preparedness Program. The Fire Protection Program will continue to be revised as required and prioritized accordingly. Current major activities over the next five years will address the following: Legacy Building Construction: The plan is to prioritize implementation offha recommendations and construct new facilities where applicable. Combustible Loading: The plan is to raise ImpActs of all new fire prevention inspection findings to enable oversight and increase fire protection awareness with fire prevention participation in safety meetings. Fire Emergency Response Capabilities: The plan is to complete response capabilities study, implement recommendations, and improve fire response training with Mutual Aid partners and facility staff. Fire Water Run-Off Retention: The plan is to implement a storm water management upgrade which includes retention ponds. C.lO.3 Safety Improvement Plans During the Next Licence Period See Section C.I 0.2. C.ll Waste Management C.l1.l Information on Performance Since Licence Renewal in 2006 Substantial progress has been made on waste management facilities and processes (including facilities decommissioning and environmental restoration activities). Risks have been reduced, shutdown buildings have been decommissioned, and much has been done to lay the groundwork for the future. Examples ofthe more significant accomplishments to date are: Collecting approximately litres of radioactive and hazardous legacy liquid waste that had been stored in aging containers, and sending it offsite for incineration. Retrieving fuel rods buried in sand since 1952 and storing them in monitored tile holes to improve the storage method. Retrieving radioactive legacy wastes from several experimental emplacements and shipping them offsite for disposition or storing them in tile holes and bunkers in WMA B. Enhancing the groundwater monitoring program to meet new regulatory requirements and to assist in understanding the stability and/or movement of the environmental contamination. Upgrading two of the three existing treatment facilities for contaminated groundwater to allow them to remain operational. Conducting field investigations to support retrieval of older irradiated research reactor fuel stored in approximately 100 tile holes of early design, where infiltrating water has degraded

26 M. Santini November 3'0 CRL-ACNO L the fuel and containers. These investigations include removing water from the tile holes, puncturing fuel cans to relieve internal pressure, test lifting fuel cans, and installing weather covers. Characterizing contaminated sediments in the Ottawa River and developing a preliminary conceptual site model to support decisions about the optimal approach to dealing with the sediments. Beginning construction of a new Fuel Packaging and Storage Facility to be used to dry and repackage the degraded research reactor fuel. Accelerating plans for managing approximately 300 cubic metres of radioactive liquid waste that has been stored in 21 underground tanks by developing an innovative combination of technologies for solidification during removal. Transfer of stored liquid waste from seven loop decontamination waste tanks and commencement of processing ofthis waste in the Waste Treatment Centre (WTC). Decontaminating and demolishing the large (2 800 square metres) radioisotope laboratory (Building 107) and the former plant hospital (Building 464). Draining a leaking portion of the Building 204 former spent fuel handling bays, thereby preventing further releases of bay water to the environment. Removing a 30 metre section ofthe wooden structure that connected the bays to the shutdown Nuclear Research Experimental (NRX) reactor building to create a fire break between the two facilities. Removal of the old site entrance (Building 401), with a footprint of approximately square metres. Construction and operation a Waste Analysis Facility that confirms that likely clean demolition waste that is below release-level limits can be released for unrestricted reuse, recycling, or disposition in a landfill. A process that minimizes radioactive waste volumes and the associated costs for short-term and long-term management. Construction and operation oftwo Shielded Modular Above Ground Storage buildings which are used for storage of low-level radioactive waste as part of AECL's long-term waste management strategy. Introduction of new waste characterization equipment and establishment of a waste characterization service function to support characterization of wastes generated and to facilitate appropriate interim storage or offsite disposition. Bulk Material Landfill is expected to be in service for the storage of all dewatered sewage sludge produced at the Sewage Treatment Plant ensuring proper disposal in an environmentally responsible manner. Improved cemented molybdenum waste (CMW) processes and procedures and continued investment in CMW improvement initiatives. Various studies to support future program activities have been completed or are still underway, such as feasibility studies regarding implementation ofenabling facilities such as very low level waste.

27 M. Santini November 30 CRL-ACNO-I0-00S4-L Geologic investigations to establish whether the site would be a suitable location for a Geologic Waste Management Facility; a repository for the long-term management of low-level and intermediate-level radioactive waste. Development of an integrated waste plan to support improved understanding of needs and timing ofwaste storage and disposition facilities. Maintaining facilities in a safe and stable shutdown condition until they can be decommissioned. Successful waste reduction initiatives based on reduce, re-use and recycle philosophy. Refurbishment ofthe thin film evaporator in WTC. Issue of mercury mass balance document for WTC. Building 240 Tank 1 isolated and dry. Commissioning and placing in service portions ofthe new active drain system. Development of plans for implementation ofthe remaining portions of the new active drain system, and taking out-of-service sections of the original active drain system. Development ofthe waste management program and processes to ensure compliance in waste handling. Lysimeter bale disposition. Clean up of surface of WMA C and disposition ofwaste. Clean up ofwma D. Developnlent ofplans for WMA A diversion of surface water, cover and reduction of contribution to plumes through use ofpermeable reactive barrier. Continued recovery ofhistorical waste data and verification of data. High quality response and lessons learned in response to the Building 240 Tank 2 leak. The following organizational improvements have already been achieved or are expected to have been achieved by 2011 March: Hiring and installing dedicated leadership and Facility Authorities in WTC and WMA. Hiring replacement facility managers in anticipation ofretirements and fully training and putting in place these individuals. Increasing staffing in WMA and WTC by 30 percent. Creation of a new branch (Waste Planning and Processing) with dedicated leadership on clearable waste, mixed and hazardous waste, waste advisors, waste characterization and waste data improvements. C.l1.2 Assessment of Opportunities for Improvement The following events or situations offer opportunities for the waste management program to effect improved practices and processes at CRL. Delays in retrieval ofproblematic fuel and implementation of fuel package and storage facility.

28 M. Santini November 30 CRL-ACNO-IO-OOS4-L Delays in implementing Bulk Material Landfill. Building 240 Tank 2 leak. Delays in commissioning new Active Drain System due to design problems with secondary pipe on the chemical active drain (stainless steel primary and fibreglass secondary). Delays in the design of the retrieval equipment/facilities for processing radioactive liquid waste stored in aging tanks. C.11.3 Safety Improvement Plans During the Next Licence Period Refer to Appendix D for waste management improvement plans under ISRP, Project New Lease (PNL) and Nuclear Legacy Liabilities Program (NLLP). C.12 Security C.12.l Information on Performance Since Licence Renewal in 2006 The Physical Security program has been rated as satisfactory in CNSC Type I and Type II inspections. Furthermore, internal assessments have been positive from AECL's PINO audit, NPARB, Security Program self-assessment and Nuclear Security Services Corporation third party audit. Areas for improvement were identified but in general comments were complimentary on the program's progress. The following significant safety improvements have been completed since 2006 licence renewal: NRU hardening Vehicle Search Portal WMA B security upgrade - in progress armoured vehicle upgrade MILES procurement Systematic Approach to Training force-on-force exercises and training security detection and assessment upgrades C.12.2 Assessment of Opportunities for Improvement Demonstrating consistent and timely interdiction to a Design Basis Threat style attack is becoming increasingly difficult. The FSARs do not consider sabotage events, and the consequence of the sabotage element of the Design Basis Threat is not well understood on a facility-by-facility basis.

29 M. Santini November 30 CRL-ACNO L C.12.3 Safety Improvement Plans During the Next Licence Period Execution of the Security Tactical Response Improvement Plan: Currently scheduled to complete this plan before the end of fiscal year 2010/2011 and it will become the focal point of improvement initiatives over the next five years. Waste Management Area B Security Upgrades: Protected area upgrades are planned for completion in 2011 to support the Fuel Packaging and Storage Facility. Continued Participation in Force-on-Force Exercise (CNSC evaluated and in-house): Will continue to be a measure of effectiveness and a toll to identify areas for improvement. Continued System Upgrades: Security lighting and security operating system upgrades are in progress. C.13 Safeguards C.13.1 Information on Performance Since Licence Renewal in 2006 The safeguards area has seen two significant improvements since licence renewal in The first is the development ofthe Integrated Nuclear Materials Accounting System (INMAS). This is a real time accounting system, which provides a record of active and historical fissionable material transactions, updates facility ledgers and inventories automatically after the appropriate authorizations have been completed on-line. The development of the INMAS has given facilities readily available real time fissionable materials inventory information. This allows for more informed decisions before accepting fissionable material shipments into the facility and determining the location to store this material. The system has also enabled standardized reporting of fissionable material inventories to increase efficiency during safeguards inspections. The INMAS accounting system has enabled the CNSC and IAEA to fully implement integrated safeguards at CRL in 2009 November. Increased reporting to the IAEA and CNSC through secure electronic means has reduced the IAEA inspector presence on-site while still maintaining continuity of knowledge. This has also allowed for increased efficiency and minimizing delays in meeting operational requirements. Internal assessments from PINO audits, NPARB, and self-assessments have been positive. C.13.2 Assessment of Opportunities for Improvement No major opportunities are identified. The program is currently meeting IAEA expectations and requirements. C.13.3 Safety Improvement Plans During the Next Licence Period Changes will be effected in accordance with the regular interactions with IAEA staff. C.14 Packaging and Transport C.14.1 Information on Performance Since Licence Renewal in 2006 All program documentation has been completed.

30 M. Santini November 30 CRL-ACNO-I L Locations with AECL trained Radioactive Material Shippers have expanded to include the New Brunswick, Saint John Office. To date, AECL sites that have trained Radioactive Material Shippers are: Chalk River Laboratories, La Prade, Port Hope, Sheridan Park, Saint John Office and Whiteshell Laboratories. In 2008, the Radioactive Materials and Transportation Program implemented transportation of dangerous goods training for CRL staffwho handle, offer for transport or transport dangerous goods. Currently, approximately 200 employees have received this training, with refresher courses required every three years. One of the significant challenges over the current licence period has been non-conformances in shipments from other organizations to AECL. AECL continues to work with those organizations to reduce non-conformances. C.14.2 Assessment of Opportunities for Improvement There are no current significant opportunities. C.14.3 Safety Improvement Plans During the Next Licence Period The new regulatory document RD-336, Accounting and Reporting ofnuclear Material, is expected to be fully implemented.

31 M. Santini November 30 CRL-ACNO-lO-OOS4-L Appendix D: Information on the Proposed Operating Plan for the Next Licensing Period and Significant Longer Term Activities at CRL D.l Overview of the Nuclear Laboratories This appendix provides a high-level summary ofthe plan for operating the Nuclear Laboratories for the period 2011 to 2016, with a focus on the CRL site. The Nuclear Laboratories has three core missions as follows: Research and Development and Innovation, Isotope Production, and Environmental Management. In addition, the Operations organization provides the foundation that enables achievement of the missions. D.l.l Management of the Nuclear Laboratories The model ofthe Nuclear Laboratories is shown in Figure D-l. The primary focus is on the three core missions. Management Accoyntabilities Responsible for delivery ofthe lab's missions to its customers: Operating sharedfacilities that are critical to missions: Providing basic business support Nuclear Laboratories \... RESEARCH, DEVELOPMENT AND INNOVATION Strategy Map ~--- Programs and Finance and Business Services Strategy Map ISOTOPE PRODUCTION 1,' l l~lli l ~--- OPERATIONS Streteg Human Ma ENVIRONMENTAL MANAGEMENT Strategy Map I I I " l ), 1 I ii r ~--- " C )!! J J.J i ~-.-- r"; 1, Engineering and Projects Other Support Functions 1 Strategy Map Figure D-l: Nuclear Laboratories Model

32 M. Santini November 30 CRL-ACNO-I0-00S4-L The core missions are not organizational groups within the Nuclear Laboratories. While the leadership of the core missions is provided by the Research & Development, Isotope Business, and Decommissioning & Waste Management organizational groups, the core missions rely on the successful integration of all groups within the Nuclear Laboratories for their success. The following sections provide a summary ofthe strategic actions that are planned over the next five years to achieve the core missions, and to ensure safe effective laboratory operations. D.2 Research & Development and Innovation D.2.1 Overall Scope and Objectives The overall scope and objectives for Research & Development and Innovation (RD&I) are summarized as follows: Support Canada's nuclear-related policy objectives and initiatives. Collaborate with Canadian nuclear community to develop new technologies and qualified people. Improve competitiveness and enhance services for commercial RD&I customers. D.2.2 Strategic Actions The strategic actions and initiatives to achieve these RD&I objectives over the next five years are as follows: Improve the safe and reliable performance of the CANDU fleet. Develop and implement nuclear-related health science and technologies. Support/discharge Canada's nuclear-related policy objectives (nuclear safety, non-proliferation and safeguards, and environment). Develop highly qualified people and contribute to a knowledge based economy. Develop technologies for future nuclear applications. D.3 Isotope Production D.3.1 Overall Scope and Objectives The overall scope and objectives for Isotope Production are summarized as follows: Manage contractual commitments to isotope customers. Ensure reliable production and supply ofmedical isotopes. Ensure sustainable production to support the next licensing period.

33 M. Santini November 30 CRL-ACNO L D.3.2 Strategic Actions The strategic actions and initiatives to achieve these Isotope Production objectives over the next five years are as follows: Minimize the impact ofour operations on the environment. Support the Government's relevant social policy objectives. Maximize profitability by minimizing costs and driving revenues. Implement practices to ensure optimal performance execution. Manage mission assets to make sure they are available to support reliable and sustainable production. Manage human capital to ensure reliable and sustainable production. D.3.3 Isotope Supply and Reliability Program Initiatives The objective ofthe ISRP is to address reliability risks in the current isotope stream facilities, as follows: 1. Management of Tritium Issues in NRU: This program ofwork addresses the leakage of tritium from the rod bays into the environment; and, the exposure staff receive when working in the rod bays. During the extended outage, the moderator was replaced, which substantially reduced the source oftritium to the rod bays. To maintain a low concentration of tritium in the moderator, plans are underway to use the Darlington detritiation facility on an ongoing basis; construction of a truck transfer station will be required. The tritium concentration in the rod bays will be reduced once the entire volume of light water in the bays is replaced with fresh light water. Tanks are being designed that will hold the removed water on a temporary basis until a light water detritiation facility can be constructed. 2. Initiatives that Bridge Potential Gaps in Storing Isotope Wastes: New tile holes are being constructed in WMA B to enable storage of cemented liquid isotope beyond ~ Projects focussed on improving the cementation process are ongoing. 3. Licence Renewal for NRU in 2011: As defined in the Protocol/or National Research Universal Licensing Activities, completion of an ISR is required. The ISR consists oftwo parts: i) a comprehensive, technical and programmatic review ofnru compared to modem codes and standards (complete); and ii) an implementation plan (currently under development) for closing any gaps in the coming years. In addition to the ISR, the protocol also set dates for the completion of environmental assessments for major projects associated with isotope production. 4. Operational Improvements to the Isotope Stream Facilities: Programs ofwork are underway that address three types of risks, broadly defined as people, process and plant. People: For some key positions (e.g., Senior Reactor Shift Engineers in NRU), loss of staff would lead to a disruption in full-time facility operation.

34 M. Santini November 30 CRL-ACNO L Process: Implementation of modem programs and processes are required to improve equipment reliability, and to ensure industry-best practices of nuclear safety are being met. Plant: The facilities are aging, and there are numerous equipment risks associated with obsolescence, lack of redundancy and general Plant Life Management. D.4 Environmental Management D.4.1 Overall Scope and Objectives The overall scope and objectives for Environmental Management are summarised as follows: Execute funded NLLP on time and budget, to safely and cost-effectively reduce the nuclear legacy liabilities and associated risks based on sound waste management and environmental principles in the best interest of Canadians. Provide waste management and decommissioning services. Minimize environmental impact of ongoing operations. D.4.2 Strategic Actions The strategic actions and initiatives to achieve these Environmental Management objectives over the next five years are as follows: Demonstrate effective risk management through the timely decommissioning of obsolete infrastructure. Remediate the environmental impact of legacy nuclear activities through a risk-based, cost-effective approach. Develop and deliver plans and programs that support waste reduction, reuse, and recycling. Safely manage through international best-practices radioactive, hazardous, and conventional wastes. Plan, develop, and implement an integrated mission-capable suite of facilities and services. Develop technologies and expertise to support environmental management activities. D.4.3 Environmental Management Initiatives Environmental Management initiatives are planned and executed under the NLLP. These initiatives can be broken into three main types of activities: waste management, infrastructure decommissioning, and environmental restoration.

35 M. Santini November 30 CRL-ACNO L D D Waste Management Objectives Develop and implement an integrated waste management strategy that promotes efficiency and provides for the final disposal of all waste streams. Provide enabling facilities necessary to support the Infrastructure Decommissioning and Environmental Restoration Programs. Provide waste management facilities for disposition of very-low-level, low-level and intermediate-level radioactive waste as soon as practicable. Provide waste operations support for the Infrastructure Decommissioning and Environmental Restoration Programs. D Milestones Iteration of Integrated Waste Plan suitable for public consultation completed. Operation of the Fuel Packaging and Storage Facility. Retrieval of spent fuel from tile array IMD-l and IFE-l to IFE-4 for transfer to Fuel Packaging and Storage Facility. Very low level waste facility detailed design. Construction of mobile cementation skid for addressing stored liquid waste. Defined waste form for CMW acceptable for long-term management. Location for Geologic Waste Management Facility determined for safety assessment and licensing purposes. D D Infrastructure Decommissioning Objectives Reduce and eliminate hazards in a safe manner as fast as practicable. Remove structures in an order based on structure availability, hazards, and operational requirements that supports the overall strategy for the site. D Milestones Abandoned above-ground section of the NRX stack duct (Building 157) removed. Fire Hall (Building 407), Fire Equipment Storage (Building 407 A) and Carport (Building 552) removed and site returned for re-use. Office portion of former Thorium Fuel Reprocessing Laboratory (Building 200B) removed. Plutonium Tower (Building 233) annexes renloved.

36 M. Santini November 30 CRL-ACNO-I0-00S4-L Waste Water Evaporator (Building 228) prepare for removal completed. Former Plutonium Recovery Laboratory (Building 220) ventilation design conlplete to support decommissioning activities. D D Environmental Restoration Objectives Clearly define end states and cleanup criteria for environmental media. Determine nature and extent of contamination by thorough characterization. Develop site conceptual models with potential transport pathways. Remediate environmental media to meet cleanup and end state criteria, with higher priority on greater hazards. D Milestones WMA B Concrete Lined Crib (CLC3) restoration option implemented as appropriate. Active Liquid Waste Tanks (AL WTI and AL WT2) remediation options implemented as appropriate. WMA C engineered cover installed. WMA A and WMA B sand trenches and asphalt trenches historical assessments and non-intrusive characterization completed. Bulk Storage Compound site restoration complete. Ottawa River bed sediment remediation option recommended to stakeholders. Technical option implemented to mitigate plume currently affecting South Swamp. Technical options implemented to mitigate plumes currently intercepted by Spring Band Chemical Pit treatment systems. D.S D.S.l Laboratory Operations Overall Scope and Objectives The overall scope and objectives for Laboratory Operations are summarised as follows: Ensure safety and compliance and effective relationship with the CNSC. Cost-effectively maintain asset reliability and sustainability Execute funded programs (PNL, ISRP) on time and budget.

37 M. Santini November 30 CRL-ACNO-I0-00S4-L D.S.2 Strategic Actions The strategic actions and initiatives to achieve these laboratory operations objectives over the next five years are as follows: a) Effectively operate facilities and ensure reliability, sustainability, and safety of all site infrastructure by: 1) ensuring safety and compliance, 2) providing complete site services, 3) providing efficient maintenance resources with cost-effective asset reliability, and 4) promoting a learning organization with continuous improvement. b) Enable and contribute to the success of isotope production by: 1) producing isotopes and ensuring their availability, 2) ensuring the sustainability of isotope operations by executing the ISRP, and 3) maintaining the nuclear facilities in the isotope stream. c) Enable and contribute to the success ofrd&i by: 1) ensuring that facilities are available to carry out RD&I mission including VI and V2 loops within the NRV reactor, 2) operating facilities including NRV and hot cells, and 3) maintaining the nuclear facilities used by RD&I. d) Enable and contribute to the success of environmental management by: 1) ensuring facilities are available to carry out environmental management activities, 2) providing adequate resources to support environmental management activities, and 3) maintaining the nuclear facilities used by environmental management. e) Enhance facilities configuration management process, tools, and maintenance capabilities. D.6 Organizational Improvement Program D.6.1 Objective Implement organizational improvements (including safety culture) to achieve world class performance. D.6.2 Strategic Actions a) Phase I WANO Peer Review and implementation of recommendations. b) Implement R TO Improvement Plan -Voyageur Program Phase II to 1) improve equipment reliability, 2) drive desired behaviours, 3) improve problem identification and solving, 4) improve use of OPEX and reduce isolationism,

38 M. Santini November 30 CRL-ACNO-10-00S4-L 5) improve standards for operation, and 6) improve management oversight. D.6.3 Project New Lease Initiatives AECL established PNL, a plan for infrastructure renewal and operating improvement initiatives to: J Ensure that site operations and aging infrastructure are compliant with current regulations. Protect the health and safety of employees, the public and the environment. Improve operating practices to attain industry standards for operating a licensed nuclear site. D.6.4 Operations and Maintenance This area includes requirements to ensure the safe and compliant operations of the CRL site and to nuclear industry standards and regulatory expectation. The intent is to address operational performance, regulatory requirements (Le., site licence conditions etc.), HSSE items, demographic issues of an aging work force and improvement of nuclear programs to comply with licence conditions and a move towards the nuclear industry practices (i.e., security, fire protection, radiation protection, etc.) and ensure a safe and reliable operation. Major initiatives include: work management improvement, operational radiation protection improvement, conventional safety improvement, criticality safety, design engineering improvements and introduction of the Design Authority role, addressing the demographics of an aging work force, increased operating staff to ensure safe operations, and site maintenance improvement to industry practices. D.6.S Capital Investments - Revitalisation of Chalk River Laboratories AECL has a requirement to invest in new and existing building infrastructure to address health, safety, security and environmental issues and maintain full compliance with its CNSC site licence conditions and other regulatory requirements. Throughout the five year operating cycle PNL will continue to seek approval ofthe many operating improvement initiatives that are underway and the continued capital investments such as: Refurbishment ofthe Hot Cells. A new Control Area 2 laboratory.

39 M. Santini November 30 CRL-ACNO-I L Relocation of the Tritium Laboratory from Building 250 to Building 215. Relocation of Hydrogen Program from Building 250 to Building 137. Upgrades to the Sewage Treatment Plant. Upgrades to the Class IV power and switchyard. Fume hood upgrade program. Domestic water. New WMA and storage facilities. D.7 CRL Operations Beyond 2016 The lip, the 10 year Integrated Improvement Initiative for NRU will continue with corrective actions to address primarily the programmatic gaps identified during the ISR process as well as ensuring the effectiveness ofcorrective actions during the first five years. It is expected that AECL will continue to seek capital approval for infrastructure operating initiatives under PNL. It is also expected that the government will continue to invest in reducing legacy liabilities under the NLLP. Major items for waste management include: Finalization ofthe site Integrated Waste Plan. Solidification of liquid wastes from historical tanks. Design and construction of system to retrieve Mo-99 waste from tile holes. Construction and operation of a very low level waste facility. Detailed design and public consultation for a Geologic Waste Management Facility. Major items for infrastructure decommissioning include: Finalization ofthe site Deconlmissioning Plan. Removal ofthe remaining water in the NRX reactor Fuel Storage Bays. Removal ofthe NRX reactor Fuel Storage Bays wooden superstructure. Demolition ofnuclear facilities (e.g., Building 228). Demolition of radiochemical laboratories (e.g., Buildings 242 and 243). Demolition of significant number of likely clean facilities. Major items for environmental restoration include: Finalization ofthe site Environmental Restoration Plan. Submission of the proposed path forward for disposition of the legacy wastes in the WMAs. Implementation of the approved remedial option for the Ottawa River bed. Ongoing operation of groundwater treatment systems to control plume migration, preventing additional contaminants from entering surface waters on site.

40 M. Santini November 30 CRL-ACNO-I0-00S4-L E.l Appendix E: Supplementary Background Material on the NRU Reactor NRU Reactor Integrated Safety Review With the decision made in the spring of 2008 to terminate the pursuit of licensing the Dedicated Isotope Facilities for full power operation and isotope production, it became apparent that the NRU reactor would need to continue to function as the supply source for Canada's isotope production. Consequently the CNSC and AECL prepared and signed a Protocolfor National Research Universal Licensing Activities, in July of The protocol was updated in January of , and is currently undergoing another revision to incorporate activities from the terminatedaecl-cnsc Protocolfor the Restart ofthe NRU Reactor (Revision 1, 2010 January 11), that remain to be completed. The objective ofthe NRU licensing activities protocol is to provide a framework within which AECL and CNSC staff will work to prepare the necessary information for the Commission to assess the continued operation ofthe NRU reactor beyond the current licensing period. In the protocol, both organizations agreed to utilize an ISR of the facility as the detailed and systematic process for determining the nature and scope of any additional NRU-related work that would need to be performed to ensure ongoing safe operation ofnru beyond 2011 October 31. The protocol dictated that the scope ofthe ISR process would be established using guidance from the IAEA Guide: Periodic Safety Review ofnuc1ear Power Plants (NS-G-2.1 0, 2003) and the CNSC Regulatory Document: Life Extension ofnuc1ear Power Plants (RD-360, 2008 February). The protocol also recognizes that NRU is a research and medical isotope production facility approaching licence renewal and not a power reactor undergoing life extension. The ISR applications in Canada to date have been directed at power reactors undergoing refurbishment in order to extend their design life. This power reactor life extension process involves a long shutdown/outage (Le., on the order of a couple of years) in order to perform the necessary refurbishment work. The NRU reactor will experience an annual extended outage of approximately four weeks, along with five-day outages that occur as part of the normal 28 day isotope production schedule. NRU refurbishment work will occur during those outages. It is not necessary from a maintenance ofreactor safety perspective, nor is there any intention, to shut NRU down for a "power reactor life-extension" type refurbishment outage. E.2 NRU Reactor Vessel Repair and Extended Outage In 2008 May the vessel holding the NRU heavy water coolant/moderator started to leak. Consequently the NRU reactor was shutdown from 2009 May to 2010 August to repair the vessel. During this long shutdown other refurbishment work was performed on NRU under the EAP. The EAP refurbishment activities were selected such that the time line for repairing the vessel and returning NRU to service was not adversely affected. Details ofthe vessel repair were provided to the Commission during the return-to-service hearing in 2010 June. It is important to note that as part of the EAP, some refurbishment work has been performed on NRU that otherwise would not necessarily have been completed prior to finishing the NRU ISR. As a result, some ofthe recommendations that would have resulted from the ISR global assessment process have already been addressed. Examples of important NRU refurbishment work that occurred during the extended outage include vessel refurbishment beyond repairing the