ONTARIOFiiWER GENERATION. Brian Duncan Senior Vice President. Darlington Nuclear. May 1, 2014 NK P NK38-CORR P

Transcription

1 ONTAROFiiWER GENERATON Brian Duncan Senior Vice President Darlington Nuclear P.O. Box 4000 Bowmanville, ON LlC 3Z8 Tel: Fax: May 1, 2014 NK P NK38-CORR P Mr. F. Rinfret Director, Darlington Regulatory Program Division Canadian Nuclear Safety Commission P.O. Box Slater Street OTTAWA, Ontario K1P 5S9 Dear Mr. Rinfret: Darlington NGS - Updated Application Requirements for Renewal of the Darlington Nuclear Generating Station Power Reactor Operating Licence Transition Plans for New and Revised Standards and Regulatory Documents The purpose of this letter is to submit to CNSC staff information on transition provisions to new and revised standards and regulatory documents, in support of OPG's application for renewal of the Darlington Nuclear Generating Station (NGS) Power Reactor Operating Licence (PROL), as committed in Reference 1. n response to CNSC staffs letter (Reference 2), an updated table matrix has been provided in Attachment 1. Attachment 2 provides details on transitional information for the new and revised standards and regulatory documents as currently planned. This submission completes Regulatory Management Action Request (REGM) One new REGM will be initiated to provide a detailed plan to transition to N , "General Requirements for Safety Systems of Nuclear power Plants", by September 30,2014. Should you have any questions or concerns, please contact Mr. Doug Coleman, Manager - Regulatory Affairs, at (905) ext Sincerely, C:?;/~~~.f'~ Brian Duncan Senior Vice President Darlington Nuclear Ontario Power Generation nc. Attach. cc: Mr. A. Ling - CNSC (Darlington) Ontario Power Generation nc., This document has been produced and distributed for Ontario Power Generation nc. purposes only. No part of this document may be reproduced, published, converted, or stored in any data retrieval system, or transmitted in any form by any means (electronic, mechanical, photocopying, recording, or otherwise) without the prior written permission of Ontario Power Generation nc. Associated with OPG-STD-0031, Correspondence Standards OPG-TMP-0007-R004 (Microsoft 2007)

2 Mr. M. Leblanc NK38-CORR P References: 1. OPG letter, Brian Duncan to M. Leblanc, "Darlington NGS - Application for Renewal of the Darlington Nuclear Generating Station Power Reactor Operating Licence 13.00/2014", December 13,2013, CD# NK38-CORR CNSC letter, F. Rinfret to Richard MacEacheron, "Updated Application Requirements for renewal of the Darlington Nuclear Generating Station Power Reactor Operating Licence", October 11, 2013, e-doc # , CD# NK38-CORR OPG-TMP-0007 R004 (Microsoft 2007) Page 2 of2

3 ATTACHMENT 1 OPG letter B. Duncan to F. Rinfret, "Darlington NGS - Updated Application Requirements for Renewal of the Darlington Nuclear Generating Station Power Reactor Operating Licence Transition Plans for New and Revised Standards and Regulatory Documents" CD# NK38-CORR Updated Table Matrix Prepared by: Checked by: R. MacEacheron D. Coleman

4 Attachment 1 Updated Table Matrix As requested by CNSC staff per Reference [1] this submission provides transition information for all documents marked in bold italic. # Safety Control Area 1 Generic 2 Management. System 3 Human Performance Management 4 Operating Performance 5 Safety AnalysiS i Current and New Proposed CNSC Regulatory DocumentlCSA Standard EG - Requirements and Guidelines for Written and Oral Certification Examinations for Shift Personnel at Nuclear Power Plants (lch CVC, not in PRQL} EG2 - Requirements and Guidelines for Simulator- Based Certification Examinations for Shift Personnel at Nuclear Power Plants (lch CVC, not in PROl) Requirements for Requalification Testing of Certified Shift Personnel at Nuclear Power Plants (lch CVC, not in PROl) S-99 Reporting Requirements for Operating Nuclear Power Plants REGDOC Reporting Requirements for i Operating Nuclear Power Plants (formerly RD-99.1 will replace S-99 ifissued) (2012) N Requirements for the Safe Operating Envelope for Nuclear Power Plants S-294 Probabilistic Safety Assessment (PSA) for Nuclear Power Plants (2005) RD-310 Safety Analysis for Nuclear Power Plants (2008) N Quality Assurance of Analytical, Scientific, and DeSign Computer Programs for Nuclear Power Plants (reaffirmed in 2007) Compliance Update RD-99.3 Public Disclosure (2012) CNSC Financial Security and ONFA Access Agreement between the Commission, the Province of Ontario and i OPG (as amended and effective January 1, 2013) Provincial Guarantee Agreement between the Commission and the Province of Ontario (effective January 1, 2013) N Management System Requirements for Nuc/ear Facilities provided in Attachment 2 RD-204 Certification of Persons Working at Nuclear Power Plants (2008) i OPG S. n comp rlance provided in Attachment 2 mplementation strategy i as documented in Darlington's LCH-DNGSi R001! Page 1 of 3

5 # Safety Current and New Proposed CNSC Regulatory Compliance Control Area DocumentlCSA Standard Update 6 Physical N General Requirements for Pressurei Design Retaining Systems and Components in CANDU provided in Reference [2] Nuclear Power Plants N General Requirements for Seismic Design and Qualification of CANDU Nuclear Power Plants provided in Reference [2] N General Requirements for Safety Systems of Nuclear Power Plants provided in Attachment 2 N Requirements for Safety Related Structures for CANDU Nuclear Power Plants (Update No ) (N currently referenced in R&G offitness provided in Reference [2] for Service) N Environmental Qualification of Equipment. for CANDU Nuclear Power Plants (update No.1, 2009) 7 Fitness for RD/GD-210 Maintenance Programs for Nuclear Power Service Plants (2012) N Periodic nspection of CANDU Nuclear Power Plant Components (Update No.1 and Update provided in Attachment 2 No.2) N Periodic nspection of CANDU Nuclear Power Plant Containment Components Transition plan is N n-service Examination and Testing documented in Requirements for Concrete Containment Structures Darlington's LCH-DNGSfor CANDU Nuclear Power Plants (update No ) R001 RD/GD-98 Reliability Programs for Nuclear Power. Plants (2012) REGDOC 2.6.2, "Fitness for Service: Aging Management" (replaces RD 334) provided in Attachment 2 8 Radiation Protection N/A N/A 9 Conventional Health and N/A N/A Safety 10 Environmental S-296 Environmental Protection, Policies, Programs Protection and Procedures at Class Nuclear Facilities and Uranium Mines and Mills (2006) N Guidelines for calculating derived release OPG can comply as per limits for radioactive material in airborne and liquid information in effluents for normal operation of nuclear facilities Attachment 2. (update No.1, 2011) N Environmental Monitoring Program provided in Reference L3 N Effluent monitoring programs at [Class 1 nuclear facilities and uranium mines and mills] provided in Attachment 2 N Environmental Risk Assessment provided in Attachment 2 i 11 Emergency Management RD-353 Testing and mplementation of Emergency Measures (2008) and Fire Protection N Fire Protection for CANDU Nuclear Power Plants provided in Reference [2] i i Page 2 of 3

6 # Safety Control Area Current and New Proposed CNSC Regulatory DocumentlCSA Standard 12 Waste N Decommissioning of Facilities Containing Management Nuclear Substances N Management of Low and ntermediate Level Radioactive Waste 13 Security - S-298 Nuclear Response Force Standard RD-363 Nuclear Security Officer medical, Physical and Ps~chol09ical Fitness (2008) RD-321 Criteria for Physical Protection Systems and - Devices at High-Security Sites (2010) RD-361 Criteria for Explosive Substance Detection, X-ray maging, and Metal Detection Devices at High- - Security Sites (2010) REGDOC Site Access Security Clearance (2013) 14 Safeguard RD-336 Accounting and Reporting for Nuclear Material (2010L i! 15 Packing and N/A Transport 16 Nuclear RD-360 Life Extension of Nuclear Power Plants Facility - (2008) Specific Compliance Update provided in Reference [2] N/A provided in Reference [4] i References: [1]. OPG letter, F. Rinfret to R. MacEacheron, "Updated Application Requirements for Renewal of the Darlington Nuclear Generating Station Power Reactor Operating Licence", October 11,2013, e-doc # CD# NK38-CORR [2]. OPG letter, Brian Duncan to M. leblanc. "Darlington NGS - Application for Renewal of the Darlington Nuclear Generating Station Power Reactor Operating Licence 13.00/2014", December CD# NK38-CORR [3]. OPG letter, G. Jager to M. Santini, "Pickering NGS - Pickering Licence Renewal nformation Request pursuant to Application for Renewal -Environmental Monitoring Program and mplementation of CSA N ". December 7,2012. CD# P-CORR [4]. OPG letter. Brian Duncan to F. Rinfret, "Darlington NGS - Response to CNSC Staff Technical Sufficiency Review of the Application for Renewal of the Power Reactor Operating Licence (PROl) 13.00/2014". February 14, 2014, CD# NK38-CORR Page 3 of 3

7 ATTACHMENT 2 OPG letter 8. Duncan to F. Rinfret, "Darlington NGS - Updated Application Requirements for Renewal of the Darlington Nuclear Generating Station Power Reactor Operating Licence Transition Plans for New and Revised Standards and Regulatory Documents" CD# NK38-CORR OPG's mplementation Strategies and Transition Provisions for New and Revised Standards and Regulatory Documents Prepared by: Checked by: R. MacEacheron D. Coleman

8 Attachment 2 OPG's mplementation Strategies and Transition Provisions for New and Revised Standards and Regulatory Documents As requested by CNSC staff in Reference [1]. OPG's implementation strategies and transition information is provided for each Safety and Control Area (SCA) with new and revised standards and regulatory documents. as mapped in Attachment 1 of this submission. SCA 2 - Management System Plan for Transition from CSA Standard N to N286-12, "Management System Requirements for Nuclear Power Plants" OPG has completed a gap assessment for transitioning from CSA N to N and concludes that there are no substantive differences in the requirements between these versions of the standard. OPG will be compliant with N by December 31,2014. There are a large number of OPG documents that will need to be revised to reflect the numbering change from N to N The document revisions are administrative in nature and will be completed over the next few years. SCA 4 - Operating Performance Plan for Transition from S-99 to REGDOC-3.1.1, "Reporting Requirements for Operating Nuclear Power Plants" Provided there are no substantive changes between the version of REGDOC provided to the industry in March 2014 and the final published version, OPG has prepared the following transition plan. 1. For scheduled reporting. such as quarterly. bi-annual and annual reports, OPG will initiate data collection within six months after the regulatory document becomes valid and will submit the scheduled report within the subsequent calendar year. 2. For unscheduled reporting events, such as immediate or next business day reportable events, OPG targets to comply with the requirements of REG DOC within one year after the new regulatory document will become valid. On this basis, OPG concludes that it would be acceptable for the renewed PROL to reflect compliance with REG DOC and the Licence Conditions Handbook (LCH) to provide the compliance timing for scheduled and unscheduled reporting as provided above. Page 1 of 4

9 SCA 6 - Physical Design Plan for Transition from CSA Standard N , "General Requirements for Safety Systems of Nuclear Power Plants" Although Darlington's design complies with the intent of CSA N , an Engineering review of the clauses in the standard identified a number of gaps for compliance. A more detailed assessment is being performed to determine the work required and schedule to implement this standard. When this assessment is complete, Darlington will be able to provide CNSC staff with a detailed transition plan for implementing CSA N A Regulatory Management Action Request (REGM) will be entered to provide CNSC staff with this transition plan by September 30,2014. SCA 7 - Fitness for Service Plan for Transition from CSA Standard N to N , "Periodic nspection of Nuclear Power Plant Components (Update No.1 and Update No.2)" OPG understands that the 2014 version of CSA N285.4 will be issued in On this basis, OPG will provide a transition plan for N instead of a plan for N as was committed in Reference [2]. The transition plan for N will be provided to the CNSC staff within one year after the 2014 version of the CSA Standard is published. Plan for Transition to REGDOC 2.6.3, "Fitness for Service: Aging Management" Given REGDOC 2.6.3, was issued in March 2014 superseding RD-334 "Aging Management for Nuclear Power Plants (2011)" OPG is providing the transition information for REGDOC OPG has an integrated aging management program in place as documented in N-PROG-MP 0008, "ntegrated Aging Managemenf'. The integrated aging management program framework consists of two basic elements: 1. A set of programs that establish activities and conditions required to optimize equipment condition, e.g., maintenance and chemistry programs. 2. A condition assessment process used to evaluate the heath of critical components and establish actions necessary to maintain health. The OPG program is consistent with REGDOC which requires that a licensee shall apply a systematic and integrated approach to establish, implement, and improve programs for managing aging and obsolescence of Systems, Structures and Components (SSCs). Darlington's aging management program will need to include the program requirements for extended shutdowns, prior to The following is the transition information: 1. OPG will complete by December 15, 2014, a preliminary assessment of the work effort required and business impact of implementing REGDOC that would be used as input for producing the transition plan. Page 2 of 4

10 2. OPG will provide CNSC staff, by June 15, 2015 the transition plan for REG DOC as well as, a detailed timeline for all the required steps, such as the preparation and submission to CNSC staff of the detailed gap analysis and dates for completing affected OPG governance document revisions. OPG concludes that it would be acceptable to include REGDOC compliance in the Darlington's renewed PROL with the above transition information in the LCH. sea 10- Environmental Protection Plans for Transition for N , "Guidelines for calculating derived release limits (DRL) for radioactive material in airborne and liquid effluents for normal operation ofnuclear facilities (update No.1, 2011)" This standard provides guidelines and a methodology for calculating Derived Release Limits (DRLs) for routine releases of radionuclides to air and water. OPG's assessment of the 2011 version of the N2BB.1 has concluded that these changes will not affect OPG's calculation of the DRLs; hence a revision to the current DRLs will not be necessary. On this basis, it would be acceptable to include CSA N (2011 update) in Darlington's LCH. N , "Effluent monitoring programs at Class / Nuclear Facilities and Uranium Mines and Mills" An assessment has concluded that the existing effluent monitoring program meets the overall intent of N A large number of gaps are administrative in nature as many of the requirements of this standard are already performed, but are not adequately documented in the effluent monitoring program documents. The implementation strategy includes performing a review of the existing effluent monitoring program against the requirements (i.e. "shall" clauses) as outlined in N A plan has been developed for the mandatory requirements of N288.5 and implementation is currently in progress. These activities include update of the effluent monitoring program governing document and site documentation to incorporate consideration of hazardous substances, data interpretation requirements such as uncertainties, and reporting requirements. OPG will be compliant with N288.5 by December N , "Environmental Risk Assessment at Class Nuc/ear Facilities and Uranium Mines and Mills" N288.6 addresses the design, implementation and management of the environmental risk assessment, including Human Health Risk Assessment (HHRA) and Ecological Risk Assessment (EcoRA) for both radiological and non-radiological contaminants and physical stressors. This standard is intended to be used in conjunction with the N288.4 standard on environmental monitoring and N288.5 standard on effluent monitoring to establish a risk based monitoring program. To support the Darlington NGS Refurbishment and Continued Operations Environmental Assessment, the Environmental mpact Statement (OPG 2011) and a series of technical support Page 3 of 4

11 documents were submitted to CNSC staff in December These documents included an EcoRA and HHRA (SENES 2011 a, SENES 2011 b). The EcoRA and HHRA demonstrated that there will likely be negligible risks to non-human biota and humans as a result of refurbishment and continued operation. mplementation Strategy The implementation strategy will involve a gap assessment to compare the requirements of N288.6 against the relevant documents from the approved Darlington NGS Refurbishment and Continued Operation Environmental Assessment (CNSC 2013). Based on the outcome of the assessment; the Environmental Risk Assessment (ERA) will be updated as required to meet the requirements of N The ERA update will be completed by December 2016, in order to incorporate the results of the Environmental Assessment follow-up monitoring program element #1 to perform a detailed characterization of the non-radiological contaminants present in the Darlington NGS effluent (OPG 2013). References: [1]. OPG letter, F. Rinfret to R. MacEacheron, "Updated Application Requirements for Renewal of the Darlington Nuclear Generating Station Power Reactor Operating Licence", October 11,2013, e-doc# , CD# NK38-CORR [2]. OPG letter, Brian Duncan to M. Leblanc, udarlington NGS - Application for Renewal of the Darlington Nuclear Generating Station Power Reactor Operating Licence 13.00/2014", December 13,2013, CD# NK38-CORR Page 4 of 4