Ontario Power Generation Inc. Darlington Nuclear Generating Station. Ontario Power Generation Inc. Centrale nucléaire de Darlington

Transcription

1 UNPROTECTED/NON PROTÉGÉ ORIGINAL/ORIGINAL CMD: 15-H8 Date signed/signé le : 8 JULY 2015 A Licence Renewal Un renouvellement de permis Ontario Power Generation Inc. Darlington Nuclear Generating Station Commission Public Hearing Part 1 Ontario Power Generation Inc. Centrale nucléaire de Darlington Audience publique de la Commission Partie 1 Scheduled for: 19 August 2015 Prévue pour : 19 Août 2015 Submitted by: CNSC Staff Soumise par : Le personnel de la CCSN e-doc (WORD) e-doc (PDF)

2 15-H8 Unprotected Summary This CMD presents information about the following matters of regulatory interest with respect to Ontario Power Generation Inc.: Renewal of the Power Reactor Operating Licence (PROL) for the Darlington Nuclear Generating Station (NGS) Refurbishment and life extension of the Darlington NGS Compliance with the safety and control areas for the safe operation of the facility Canadian Nuclear Safety Commission staff recommend that the Commission take the following action: Renew the PROL to authorize OPG to refurbish and continue to operate the Darlington NGS from January 1, 2016 to December 31, Accept the delegation of authority as set out in this CMD. The following items are attached: The proposed PROL 13.00/2025 The draft Licence Conditions Handbook The current PROL 13.01/2015 Résumé Ce CMD soumet des renseignements sur les questions d intérêt réglementaire suivantes à l égard de Ontario Power Generation Inc.: Renouvellement du permis d exploitation du réacteur de puissance (PERP) de la centrale nucléaire de Darlington Réfection et prolongement de la durée de vie de la centrale nucléaire de Darlington Conformité avec les domaines de sûreté et de réglementation pour une exploitation sûre de la centrale Le personnel de la Commission canadienne de sûreté nucléaire recommande à la Commission de prendre la mesure suivante : Renouveler le permis d exploitation du réacteur de puissance de la centrale nucléaire de Darlington pour la période du 1 janvier 2016 au 31 décembre Accepter la délégation des pouvoirs telle qu établie du présent CMD. Les pièces suivantes sont jointes : Le permis d exploitation du réacteur de puissance proposé PERP 13.00/2025 Le manuel des conditions de permis proposé Le permis d exploitation du réacteur de puissance actuel PERP 13.01/2015 e-doc (Word) - ii - July 2015 e-doc (PDF)

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5 15-H8 Unprotected TABLE OF CONTENTS EXECUTIVE SUMMARY... 1 PART ONE OVERVIEW Background Highlights Overall Conclusions Overall Recommendations MATTERS FOR CONSIDERATION Environmental Assessment Refurbishment and Life Extension Safety and Control Areas (SCAs) Other Matters of Regulatory Interest Regulatory and Technical Bases REFURBISHMENT AND LIFE EXTENSION Integrated Safety Review Global Assessment and Integrated Implementation Plan Refurbishment Project Execution Return to Service Conclusions and Recommendations GENERAL ASSESSMENT OF SCAS Management System Human Performance Management Operating Performance Safety Analysis Physical Design Fitness for Service Radiation Protection Conventional Health and Safety Environmental Protection Emergency Management and Fire Protection Waste Management Security Safeguards and Non-Proliferation Packaging and Transport OTHER MATTERS OF REGULATORY INTEREST Aboriginal Consultation Other Consultation Cost Recovery Financial Guarantees e-doc (Word) - v - July 2015 e-doc (PDF)

6 15-H8 Unprotected 5.5 Improvement Plan and Significant Future Activities (including Fukushima Actions) Licensee Public Information Program Nuclear Liability Insurance Fisheries Act Authorization Tritium Removal Facility Previous Commitments Raised by the Commission Proposed Licence Period Delegation of Authority Licence Conditions Handbook OVERALL CONCLUSIONS AND RECOMMENDATIONS REFERENCES GLOSSARY A. RISK RANKING B. RATING LEVELS C. SAFETY AND CONTROL AREA FRAMEWORK C.1 Safety and Control Areas Defined C.2 Specific Areas for Nuclear Power Plants D. SUPPORTING DETAILS D.1 Radiation Protection E. ENVIRONMENTAL ASSESSMENT INFORMATION REPORT F. INTEGRATED IMPLEMENTATION PLAN (IIP) PART TWO Proposed changes to the licence and the licence conditions handbook 2. The proposed licence 3. The proposed licence conditions handbook 4. The current licence e-doc (Word) - vi - July 2015 e-doc (PDF)

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8 15-H8 Unprotected EXECUTIVE SUMMARY The Darlington Nuclear Generating Station (NGS) is located in Ontario on the north shore of Lake Ontario, in the Municipality of Clarington and Regional Municipality of Durham. It has four 881 megawatt CANDU reactors and a tritium removal facility, all of which are owned and operated by Ontario Power Generation (OPG). OPG is proceeding with detailed planning for the mid-life refurbishment of the four Darlington NGS reactors to extend the station s life for an additional 30 years. In March 2013, the Commission reached a decision on the environmental assessment (EA) of the proposed refurbishment and continued operation of the Darlington NGS under the Canadian Environmental Assessment Act 1, 1992 (CEAA, 1992). The Commission concluded that the proposed project is not likely to cause significant adverse environmental effects, taking into account mitigation measures identified in the EA Screening Report. The Commission also renewed the Darlington NGS power reactor operating licence (PROL) for 22 months to allow OPG sufficient time to complete the necessary studies for the proposed refurbishment outages. At the request of OPG, to allow additional time to provide more comprehensive documentation, reflect new CNSC expectations relative to probabilistic safety assessments and facilitate public engagement for this relicensing process, the PROL was subsequently renewed by the Commission until December 31, OPG has applied to renew the Darlington NGS PROL, for a period of 13 years, to cover life extension activities including refurbishment of the four Darlington reactors. In support of the licence application, OPG has completed an Integrated Safety Review, Global Assessment Report, and Integrated Implementation Plan in accordance with Canadian Nuclear Safety Commission (CNSC) Regulatory Document RD-360, Life Extension of Nuclear Power Plants. CNSC staff are recommending a 10-year licence period to align with the recommended frequency of periodic safety reviews in the recently published REGDOC 2.3.3, Periodic Safety Reviews. In this Commission Member Document (CMD), CNSC staff present their assessments of the licence application and its supporting documents, as well as OPG s past performance. This CMD also presents information that was specifically requested by the Commission as part of the CEAA EA and 22 month PROL renewal records of decision. The public, Aboriginal groups and other stakeholders were invited to participate in the relicensing process. To enable their participation, up to $75,000 was made available through the CNSC s Participant Funding Program. This CMD provides comprehensive information on CNSC staff s assessments performed during the current licence period, the issues on which CNSC staff have been focusing, the current status of these issues, and CNSC staff s future expectations of OPG. It presents the rationale for staff s conclusions and recommendations to the Commission on section 24 of the Nuclear Safety and Control Act 2 (NSCA). 1 S.C. 1992, c S.C. 1997, c. 9. e-doc (Word) July 2015 e-doc (PDF)

9 15-H8 Unprotected The CNSC staff review provides information in all CNSC safety and control areas (SCAs) with focused highlights on: refurbishment and life extension; probabilistic safety assessment; aging management (including pressure tubes); nuclear emergency management; an update on Fukushima action items (FAIs); and environmental assessment under the NSCA. The following table lists CNSC staff s rating of OPG s performance in each SCA from 2008 to It shows that OPG has operated Darlington safely and that OPG continues to meet or exceed regulatory requirements in all SCAs. In fact, the Darlington NGS has received a fully satisfactory (FS) integrated plant rating, the highest rating possible, each year for the past seven years from 2008 to CNSC staff are confident that OPG will continue to operate the Darlington NGS safely and that OPG will continue to maintain and implement adequate programs, fulfill regulatory commitments, and complete the planned improvements during the proposed licence period. Darlington Nuclear Generating Station Performance Ratings for SAFETY AND CONTROL AREAS RATINGS Management System SA SA SA SA SA SA SA 2. Human Performance SA SA SA SA SA SA SA Management 3. Operating Performance FS FS FS FS FS FS FS 4. Safety Analysis SA SA SA SA SA SA SA 5. Physical Design SA SA SA SA SA SA SA 6. Fitness for Service SA SA FS FS FS SA SA 7. Radiation Protection FS SA FS FS FS FS FS 8. Conventional Health and FS FS FS FS FS FS SA Safety 9. Environmental Protection SA SA SA SA SA SA SA 10. Emergency Management FS FS SA SA SA SA SA and Fire Protection 11. Waste Management SA SA SA SA FS 12. Security SA SA SA SA SA FS FS 13. Safeguards and Non- FS SA SA SA SA SA SA Proliferation 14. Packaging and Transport SA SA SA SA SA Integrated Plant Rating FS FS FS FS FS FS FS FS: fully satisfactory SA: satisfactory e-doc (Word) July 2015 e-doc (PDF)

10 15-H8 Unprotected There were no serious process system failures, the availability of special safety systems was acceptable, and doses to workers and the public were well below regulatory limits. Risk to the public and workers have been kept low and, in CNSC staff s opinion, should remain low over the proposed licence period. With the introduction of periodic safety reviews (PSRs) to the CNSC regulatory framework, CNSC staff are recommending a transition to 10-year operating licences for nuclear power plants with a PSR done every 10 years to coincide with licence renewals. The Integrated Safety Review performed by OPG in accordance with RD-360 is considered to be equivalent to the first PSR. As such, CNSC staff are recommending a 10-year licence period for the Darlington NGS PROL and have included a condition in the proposed licence requiring OPG to perform a PSR in accordance with REGDOC , Periodic Safety Reviews, in support of OPG s next licence application. Overall, CNSC staff conclude that OPG has made, and will continue to make, adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed. CNSC staff recommend that the Commission renew, pursuant to section 24 of the NSCA, the Darlington operating licence to authorize OPG to refurbish and continue to operate the Darlington NGS from January 1, 2016 to December, 31, The proposed PROL and a draft Licence Conditions Handbook are presented in Part Two of this CMD. e-doc (Word) July 2015 e-doc (PDF)

11 15-H8 Unprotected PART ONE This Commission Member Document (CMD) is presented in two parts. Part One includes: 1. An overview of the matter being presented; 2. Overall conclusions and overall recommendations; 3. Discussions pertaining to refurbishment and life extension; 4. General discussion pertaining to all safety and control areas (SCAs); 5. Discussion about other matters of regulatory interest; and 6. Addenda material that complements items 1 through 5 Part Two provides information pertaining to the current and proposed licence, including: 7. Proposed changes to the licence and the licence conditions handbook; 8. The proposed licence; 9. The proposed licence conditions handbook; and 10. The current licence. e-doc (Word) July 2015 e-doc (PDF)

12 15-H8 Unprotected 1. OVERVIEW 1.1 Background The Darlington Nuclear Generating Station (NGS) is located in the Province of Ontario on the north shore of Lake Ontario, in the Municipality of Clarington and Regional Municipality of Durham. The facility is owned and operated by the licensee, Ontario Power Generation (OPG), a Canadian corporation, whose head office is located in Toronto, Ontario. Figure 1: Darlington Nuclear Generating Station The Darlington NGS consists of four 881 megawatt CANDU reactors which came into service between 1990 and The Darlington site is also home to a Tritium Removal Facility which is designed to reduce levels of radioactive tritium from the heavy water used in the moderator and primary cooling circuit. The site is also home to the Darlington Waste Management Facility (DWMF) which became operational in The DWMF processes and stores used nuclear fuel from the Darlington NGS that has cooled in the irradiated fuel bays for at least ten years. The DWMF is subject to a separate Class 1B Waste Facility Operating Licence (WFOL) which was renewed by the Commission in 2013 for a period of 10 years [1]. CNSC staff presented a report on the regulatory performance of the DWMF in CMD 15-M22 on June 17, 2015 [2] which concluded that the DMWF meets regulatory requirements. e-doc (Word) July 2015 e-doc (PDF)

13 15-H8 Unprotected OPG is proceeding with detailed planning for the mid-life refurbishment of the four Darlington NGS reactors to extend the life of the station for an additional 30 years. Refurbishment is a multi-year program to enable the replacement of lifelimiting components such as fuel channels, and to make safety improvements to the plant, programs, and processes. In March 2013, the Commission reached a decision on the environmental assessment (EA) of the proposed refurbishment and continued operation of the Darlington NGS [3] under the Canadian Environmental Assessment Act (CEAA, 1992). The Commission concluded that the proposed project is not likely to cause significant adverse environmental effects, taking into account mitigation measures identified in the EA Screening Report [4]. The Commission also renewed the Darlington NGS power reactor operating licence (PROL) for a period of 22 months to allow OPG sufficient time to complete the necessary studies for the proposed refurbishment outages [5]. With a CEAA EA decision reached and the necessary studies for the proposed refurbishment outages complete, the Commission can now consider OPG s licence application under the Nuclear Safety and Control Act (NSCA). 1.2 Highlights In December 2013, OPG submitted its application [6] for renewal of the Darlington NGS PROL. The PROL was originally set to expire on December 31, At the request of OPG [7], to allow additional time to provide more comprehensive documentation, reflect new CNSC expectations relative to probabilistic safety assessment and facilitate public engagement at the hearing, the PROL was subsequently renewed by the Commission until December 31, 2015 [8]. In January 2015, OPG submitted an addendum to the licence application [9] which focused on station performance data and provided an update on activities since the original licence application was submitted. OPG s licence application requests the Commission renew the operating licence to December 1, 2028 to cover the period to complete the refurbishment outages on all units and activities in the Integrated Implementation Plan (IIP). The purpose of this CMD is to provide CNSC staff s conclusions and recommendations to support the Commission s decision on the licence application. This CMD provides information on Canadian Nuclear Safety Commission (CNSC) staff s review of all safety and control areas (SCAs) with focused highlights on: refurbishment and life extension; probabilistic safety assessment; aging management (including pressure tubes and operating beyond 210,000 equivalent full power hours); nuclear emergency management; e-doc (Word) July 2015 e-doc (PDF)

14 15-H8 Unprotected an update on Fukushima Action Items (FAIs); and an environmental assessment under the NSCA. Previous commitments raised by the Commission in the records of decision for the CEAA EA [3] and 22 month PROL renewal [5] are complete and summarized in section 5.10 of this CMD. 1.3 Overall Conclusions CNSC staff have concluded the following with respect to paragraphs 24(4)(a) and (b) of the Nuclear Safety and Control Act (NSCA), in that OPG: 1. is qualified to carry on the activities authorized by the licence; and 2. in carrying out the licensed activities, has made, and will continue to make adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed. 1.4 Overall Recommendations Therefore, CNSC staff recommend that the Commission: 1. accept CNSC staff s conclusions and exercise its authority under the NSCA to renew the licence to authorize OPG to refurbish and continue to operate the Darlington NGS from January 1, 2016 to December 31, 2025; 2. authorize OPG to operate the Darlington NGS beyond 210,000 equivalent full power hours (EFPH) up to the proposed refurbishment outages to a maximum of 235,000 EFPH; 3. authorize the delegation of authority as set out in section 5.12 of this CMD. e-doc (Word) July 2015 e-doc (PDF)

15 15-H8 Unprotected 2. MATTERS FOR CONSIDERATION 2.1 Environmental Assessment An Environmental Assessment (EA) under the NSCA and its regulations was conducted for this licence application. Further information can be found in the EA Information Report in Addendum E of this CMD. CNSC staff conclude that OPG has made and will continue to make adequate provision for the protection of the environment and the health of persons. 2.2 Refurbishment and Life Extension An Integrated Safety Review (ISR), Global Assessment Report (GAR) and Integrated Implementation Plan (IIP) for refurbishment and life extension were completed for this licence application. Further information can be found in section 3 of this CMD. CNSC staff conclude that OPG has met the regulatory expectations set out in CNSC Regulatory Document RD-360, Life Extension of Nuclear Power Plants [10] for the Darlington refurbishment and life extension project. 2.3 Safety and Control Areas (SCAs) Regulatory oversight is performed in accordance with the 14 SCAs that are applicable to an operating nuclear power plant (NPP). For each SCA, specific areas of regulatory interest were identified by CNSC staff which can vary between facility types. Addendum C Safety and Control Framework provides further information about the SCAs: C.1 - Safety and Control Areas Defined C.2 - Specific Areas for this Facility Type For each SCA, information is presented in the context of both current operations and proposed refurbishment activities Risk Ranking and Rating Levels The CNSC has applied a risk-informed regulatory approach to each SCA to determine relative risk rankings as they relate to NPPs. An overview of the risk ranking, and the management and monitoring approach associated with the various degrees of risk, can be found in Addendum A Risk Ranking. The rating level for each relevant SCA indicates the overall compliance with regulatory requirements for implementation. Information and definitions can be found in Addendum B Rating Levels. The table below summarizes the plant safety performance ratings for those SCAs that applied to the licensed activities from 2008 to CNSC staff s ratings for OPG s performance in the SCAs for the Darlington NGS show that Darlington has been a top performer. In fact, Darlington NGS has received a fully e-doc (Word) July 2015 e-doc (PDF)

16 15-H8 Unprotected satisfactory (FS) integrated plant rating, the highest rating possible, each year for the past seven years from 2008 to Darlington NGS Performance Ratings from 2008 to 2014 SAFETY AND CONTROL AREAS RATINGS Management System SA SA SA SA SA SA SA 2. Human Performance Management SA SA SA SA SA SA SA 3. Operating Performance FS FS FS FS FS FS FS 4. Safety Analysis SA SA SA SA SA SA SA 5. Physical Design SA SA SA SA SA SA SA 6. Fitness for Service SA SA FS FS FS SA SA 7. Radiation Protection FS SA FS FS FS FS FS 8. Conventional Health and Safety FS FS FS FS FS FS SA 9. Environmental Protection SA SA SA SA SA SA SA 10. Emergency Management and Fire Protection FS FS SA SA SA SA SA 11. Waste Management SA SA SA SA FS 12. Security SA SA SA SA SA FS FS 13. Safeguards and Non- Proliferation FS SA SA SA SA SA SA 14. Packaging and Transport SA SA SA SA SA Integrated Plant Rating FS FS FS FS FS FS FS Note: FS - fully satisfactory SA = satisfactory. e-doc (Word) July 2015 e-doc (PDF)

17 15-H8 Unprotected 2.4 Other Matters of Regulatory Interest The following table identifies other matters that are relevant to this CMD. OTHER MATTERS OF REGULATORY INTEREST Area Aboriginal Consultation Other Consultation Cost Recovery Financial Guarantees Improvement Plans and Significant Future Activities (including Fukushima Actions) Licensee s Public Information Program Nuclear Liability Insurance Fisheries Act Authorization Tritium Removal Facility Previous Commitments Raised by the Commission Proposed Licence Period Delegation of Authority Licence Conditions Handbook Relevant to this CMD? The relevant other matters of regulatory interest are discussed in section 5 of this CMD. 2.5 Regulatory and Technical Bases Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes The regulatory and technical bases for the matters discussed in this CMD, including international guidance documents, national standards and CNSC regulatory documents, are provided in the preamble of the draft Licence Conditions Handbook (LCH). e-doc (Word) July 2015 e-doc (PDF)

18 15-H8 Unprotected 3. REFURBISHMENT AND LIFE EXTENSION OPG is proceeding with detailed planning for the mid-life refurbishment of the four Darlington NGS reactors to extend the life of the station for an additional 30 years. Refurbishment is a multi-year program to enable the replacement of lifelimiting components such as fuel channels, and to make safety improvements to the plant, programs, and processes. The CNSC s regulatory expectations for proposed projects to refurbish and extend the life of a NPP are contained in CNSC Regulatory Document RD-360, Life Extension of Nuclear Power Plants. As described in RD-360, once a licensee decides to undertake a life extension project, the licensee systematically identifies and addresses all environmental and safety concerns and integrates them into an IIP. To do this the licensee: 1. Participates in the EA process; 2. Carries out an ISR; and 3. Incorporates the results of these assessments into a Global Assessment Report (GAR) and Integrated Implementation Plan (IIP). An EA conducted under the CEAA, 1992, was completed for the proposed refurbishment project. The Commission concluded that the proposed refurbishment and continued operation of the Darlington NGS is not likely to cause significant adverse environmental effects, taking into account mitigation measures identified in the EA Screening Report [3]. Further information on the ISR, GAR, and IIP as well as OPG s plans for refurbishment project execution and return to service can be found in the subsections below. 3.1 Integrated Safety Review As outlined in RD-360, an ISR is a comprehensive assessment of plant design, condition, and operation. Performed by the licensee, an ISR involves an assessment of the current state of the plant and plant performance to determine the extent to which the plant conforms to modern codes, standards and best practices, and to identify any factors that would limit safe long-term operation. This enables the determination of reasonable and practical modifications that should be made to the plant or operational programs to enhance the safety of the facility to a level approaching that of a modern NPP, and to allow for safe long-term operation. Guidance on the ISR can be found in the International Atomic Energy Agency s (IAEA) Safety Standard Series, Specific Safety Guide No. SSG 25 Periodic Safety Review for Nuclear Power Plants [11]. It is referred to as an ISR in this CMD due to the unique application of the periodic safety review process for refurbishment and life extension projects. OPG s ISR for Darlington refurbishment and life extension was completed over a three-year period and submitted to CNSC staff in October The ISR e-doc (Word) July 2015 e-doc (PDF)

19 15-H8 Unprotected consisted of a final ISR report, supported by individual safety factor reports and code review reports. The ISR was carried out in accordance with OPG s ISR basis document [12] which was submitted to and accepted by CNSC staff as the methodology for performing the ISR. The ISR addressed the 14 safety factors described in IAEA PSR guidance plus an additional 3 safety factors as recommended by RD-360. Each ISR safety factor was broken down into specific review tasks based on IAEA guidance. The safety factors addressed in the ISR and their objectives are presented in the table below: Darlington ISR Safety Factors and their Objectives Safety Factor Objective 1. Plant Design To determine the adequacy of the design and its documentation in an assessment against current international standards and practices. 2. Actual Condition of Structures Systems and Components (SSCs) 3. Equipment Qualification To determine the actual condition of SSCs important to safety and whether it is adequate for them to meet their design requirements. In addition, the review should confirm that the condition of SSCs is properly documented. To determine whether equipment important to safety is qualified to perform its designated safety function throughout its installed service life. 4. Aging To determine whether aging is being effectively managed so that required safety functions are maintained and whether an effective Aging Management Program is in place for future plant operation. 5. Deterministic Safety Analysis 6. Probabilistic Safety Analysis To determine to what extent the existing Deterministic Safety Analysis remains valid when the following aspects have been taken into account: actual plant design; the actual condition of SSCs and their predicted state at the end of the period covered by the ISR; current deterministic methods; and current safety standards and knowledge. In addition, the review should also identify any weaknesses relating to the application of the defence in depth concept. To determine to what extent the existing PSA remains valid as a representative model of the plant when the following aspects have been taken into account: changes in the design and operation of the plant; new technical information, current methods; and new operational data e-doc (Word) July 2015 e-doc (PDF)

20 15-H8 Unprotected 7. Hazard Analysis To determine the adequacy of protection of the Nuclear Power Plant (NPP) against internal and external hazards taking into account the actual plant design, actual site characteristics, the actual condition of SSCs and their predicted state at the end of the period covered by the ISR, and current analytical methods, safety standards and knowledge. 8. Safety Performance To determine the safety performance of the NPP and its trends from records of operating experience. 9. Use of Experience from Other Plants and Research Findings 10. Organization and Administration To determine whether there is adequate feedback of safety experience from other NPPs and of the findings of research. To determine whether the organization and the administration are adequate for the safe operation of the NPP. 11. Procedures To determine whether the procedures are of an adequate standard. 12. Human Factors To determine the status of the various human factors that may affect the safe operation of the NPP. 13. Emergency Management To determine (a) whether the operating organization has adequate plans, staff, facilities and equipment for dealing with emergencies and (b) whether the operating organization s arrangements have been adequately coordinated with local and national systems and are regularly exercised. 14. Quality Management To ensure all aspects of nuclear safety ranging from design to operations are managed at high quality standards. This review is in addition to the Safety Factors identified by the IAEA. 15. Environment To determine whether the operating organization has an adequate program for surveillance of the radiological (and non-radiological) impact of the plant on the environment. 16. Safeguards To confirm that the Darlington NGS operating organization is able to comply with safeguards regulatory requirements prescribed by the CNSC. This review is in addition to the Safety Factors identified by the IAEA. 17. Security To ensure the maintenance of national security and measures required to implement international obligations to which Canada has agreed. This review is in addition to the Safety Factors identified by the IAEA. e-doc (Word) July 2015 e-doc (PDF)

21 15-H8 Unprotected At the request of CNSC staff, OPG performed supplemental assessments to address the additional CNSC SCAs not addressed by the ISR safety factors identified above, including Conventional Health and Safety, Waste Management, and Packaging and Transport. In addition, the ISR addressed 103 modern codes, standards, and best practices considered most likely to apply to a new NPP. The set of modern codes, standards and practices selected for the ISR included CNSC regulatory documents, Canadian Standards Association (CSA) and other Canadian standards and codes and international standards and practices including IAEA safety requirements and guides. The list of modern codes, standards and practices assessed in the ISR is contained in the ISR basis document [12] The ISR demonstrated a high level of compliance with modern codes, standards and practices. In some cases, the ISR identified difference between OPG s current practices and those which would likely apply to a new NPP. These were grouped into ISR issues which were categorized and prioritized according to their safety significance and assessed for recommended resolution. Overall, the ISR concluded that: the process was conducted in accordance with RD-360; all objectives of the ISR were met; no issues were identified that would impede safe long-term operation; and completing the safety improvements proposed in the IIP will continue to enhance the current strong performance at the Darlington NGS. CNSC staff conducted an extensive review of the ISR over a two-year period. CNSC staff s review of the ISR resulted in requests for modifications to OPG s ISR findings [13, 14 and 15]. As a result, OPG produced an addendum to the final ISR report to document new or modifications to existing ISR issues to address CNSC staff s review of the ISR. In February 2014, OPG submitted an ISR emerging issues review which addressed ISR basis codes, standards and practices that were updated since the original ISR assessment as well as any new significant industry operating experience (OPEX). Issues identified as part of the ISR emerging issues review followed the same process as the original ISR. CNSC staff s review of OPG s ISR emerging issues review confirmed OPG s findings and confirmed that the review methodology had been followed correctly. 3.2 Global Assessment and Integrated Implementation Plan RD-360 requires the results of the CEAA EA and ISR be incorporated in a Global Assessment Report (GAR), and IIP. The GAR presents the results of the EA and ISR in an integrated manner and provides an overall risk judgment on the acceptability of continued operation for the proposed extended plant life. The IIP presents the proposed environmental and safety improvements, resulting from the EA and the ISR and includes timeframes for implementation. e-doc (Word) July 2015 e-doc (PDF)

22 15-H8 Unprotected OPG submitted the GAR and IIP for Darlington refurbishment and life extension to CNSC staff in December, 2013 [16] and made the documents publicly available on OPG s external website. The GAR summarizes Darlington s overall plant performance, the results of the EA and ISR, the basis for continued operation for the proposed extended life, and an overview of the IIP. The GAR includes a cross-reference table to demonstrate how the applicable expectations of RD-360 are addressed. The GAR confirms the conclusions of the EA and ISR and provides additional detail regarding the positive basis for life extension and continued operations. The GAR concludes that the current plant, with planned safety improvements including refurbishment, will meet to the extent practicable, the regulatory design requirements of a new NPP. The IIP presents the proposed safety improvements resulting from the EA and the ISR and includes the timeframes for implementation. Some of the major IIP activities include: Replacement of pressure tubes, calandria tubes, feeders and end fittings; Installation of auxiliary shutdown cooling (SDC) pumps which are physically separate and of diverse design than the SDC pumps; Installation of a containment filtered venting system; Provision of shield tank overpressure protection; Enhancements to the powerhouse steam venting system; Installation of a 3 rd seismically qualified emergency power generator; Provision of an alternate, independent supply of water as an emergency heat sink; Implementation of safety related recommendations from ISR component condition assessments; and Implementation of CEAA EA mitigation and follow up activities. CNSC staff provided their review and assessment results of the GAR and IIP to OPG in April 2014 [17]. CNSC staff concluded that the GAR and supporting documents prepared by OPG meet RD-360 expectations. CNSC staff found that the timeframes for implementation for certain IIP activities (e.g. anywhere between 2016 and 2028) were too broad and CNSC staff requested that a more detailed schedule be provided. OPG submitted Revision 1 of the IIP in October 2014 [18] to specifically address the feedback received from CNSC staff. CNSC staff accepted IIP Revision 1 in December 2014, on condition of making specific changes as noted in the attachment to the letter [19]. As a result, OPG submitted Revision 2 of the IIP in April 2015 [20] which was formally accepted by CNSC staff [21]. CNSC staff s review concluded that Revision 2 of the IIP meets RD-360 expectations. A copy of Revision 2 of the IIP is presented in Addendum F of this CMD. e-doc (Word) July 2015 e-doc (PDF)

23 15-H8 Unprotected 3.3 Refurbishment Project Execution RD-360 expects that the licensee prepare project plans, programs and processes to carry out the refurbishment project. The licensee is also expected to monitor the project for progress, safety and quality at all phases of the project. OPG s high level plans for refurbishment execution are summarized in the sections that follow Refurbishment Organization OPG has established a separate refurbishment management organization that is distinct from the station s operating organization. The intent of this new organizational structure is to allow both organizations to focus on their areas of responsibility and expertise. As described in the licence application, the refurbishment organization is responsible for the development, implementation, and assurance of the refurbishment project while the station s operating organization is responsible for safe operation of the operating units Refurbishment Project Plans, Programs, and Processes As stated in the licence application, the refurbishment organization is subject to OPG s nuclear management system and all governance under that system. Specifically, the refurbishment project is governed under OPG s project management program, which is implemented through standards on project management, contract management, project oversight, field engineering, and a procedure on the technical contractor management process. OPG has organized the Darlington refurbishment as a program under which individual projects are being carried out. The refurbishment organization has prepared program management plans that describe how refurbishment meets the nuclear management system and provides additional direction specific to refurbishment of the units. Contractor Oversight OPG will use Engineer, Procure, Construct (EPC) contractors to perform the majority of the refurbishment work. As stated in the licence application, EPC contractors are qualified under OPG s supply chain to ensure that the contractor has developed and implemented a management system that meets the requirements of CSA N286. OPG will oversee the activities of the EPC contractors including review and acceptance of all plans and deliverables, surveillance and witnessing of activities, as well as initial and ongoing acceptance of the EPC contractor s management system. OPG has developed project specific oversight plans detailing how oversight of the EPC contractors will be managed. These plans will be updated during the course of the project as experience is gained and lessons are learned to ensure that safety and quality requirements are met at all phases of the project. e-doc (Word) July 2015 e-doc (PDF)

24 15-H8 Unprotected CNSC staff have verified OPG s contractor oversight approach for the refurbishment project. OPG s contractor oversight approach includes an interface strategy for management of deliverables and entails a close working relationship with the contractor, starting with an initial definition of requirements, on-going clarifications and oversight, and a simplified review process that leads to a consistent output of the desired contractor deliverables. CNSC staff have verified that there is a clear OPG understanding and implementation of how the engineering organization hierarchy interacts with projects through a functional matrix organization. OPG s contractor oversight approach provides the interfaces required for meeting CSA N286 requirements. CNSC staff will continue to conduct regulatory oversight to ensure that OPG is providing the necessary measures for contractor oversight for the refurbishment project. Benchmarking from other Refurbishment Projects OPG has informed CNSC staff that, as part of the initial planning for the refurbishment project, OPG benchmarked its program with other refurbishment projects, including the refurbishments at Bruce Power Units 1 and 2, Point Lepreau, and Wolsong, South Korea. OPG also seconded staff to the Bruce Power Units 1 and 2 and the Point Lepreau refurbishment programs to gain experience and capture lessons learned. Some of the key lessons learned include establishing a separate refurbishment organization independent from the station, performing detailed front-end planning, and the construction of a full-scale reactor mock-up for training and tool development. Training and Mock-up Building In preparation for refurbishment, OPG has constructed a full scale replica of a Darlington reactor. The replica is being used to train staff prior to performing work in the field and will also be used to test and commission specialized tooling required for refurbishment work. The construction of a full-scale reactor mock-up will assist in the training of personnel, the testing of tools, and the development of work plans. This will help ensure worker familiarity with tasks and tooling compatibility when refurbishment execution begins. A photo of the mock-up reactor is provided below. e-doc (Word) July 2015 e-doc (PDF)

25 15-H8 Unprotected Figure 2: Darlington Refurbishment - Reactor Mock-Up Refurbishment Timeline OPG is planning on staggering the proposed refurbishment outages at Darlington with Unit 2 being refurbished first, starting in October 2016, followed by Unit 3 in 2019, Unit 1 in 2021, and Unit 4 in A high level schedule, adapted from OPG s licence application addendum [9], is provided below. Figure 3: Darlington Refurbishment Timeline e-doc (Word) July 2015 e-doc (PDF)

26 15-H8 Unprotected The replacement of pressure tubes, calandria tubes, end fittings and feeders is the primary refurbishment work. The remaining IIP actions will be completed either at power or during other planned maintenance outages. OPG commits to perform the safety improvements with the highest safety benefit as early as possible and no later than the next planned maintenance outage following the unit s refurbishment outage. This plan takes the completion of all activities outlined in the IIP for all units out to Return to Service RD-360 requires that the licensee establish a return to service plan for the refurbishment project. Return to service involves returning the reactor back to commercial operation, post-refurbishment, and includes demonstration that the associated work meets specified requirements and management arrangements have been updated appropriately. As outlined in RD-360, return to service is accomplished through four commissioning phases: 1. Phase A: Focuses on ensuring that those systems required to ensure safety with fuel loaded in the reactor have been adequately commissioned. This phase must be successfully completed prior to loading the fuel in the reactor; 2. Phase B: Focuses on ensuring the fuel is loaded in the reactor safely, and confirming that the reactor is in a suitable condition to be started up and that all prerequisites for permitting the reactor to go critical have been met. This phase must be successfully completed prior to removal of the guaranteed shutdown state (GSS); 3. Phase C: Focuses on confirming reactor behavior at the state of initial criticality and subsequent low power tests, and includes activities that cannot be done during GSS; and 4. Phase D: Focuses on demonstrating reactor and systems behavior at higher power levels, including activities that could not be carried out at the power levels in Phase C. Return to service and commissioning is achieved through the accomplishment of a number of milestones, including regulatory hold points, which are typically aligned with the four phases of commissioning described above. For Darlington, CNSC staff have identified four regulatory hold points for the return to service of each unit undergoing refurbishment to align with the four phases of commissioning described above [22]. These hold points are: 1. prior to fuel load; 2. prior to guaranteed shutdown state (GSS) removal; 3. prior to exceeding 1% full power; and 4. prior to exceeding 35% full power. e-doc (Word) July 2015 e-doc (PDF)

27 15-H8 Unprotected These hold points will serve as regulatory verification to ensure operational readiness of the plant safety systems to support full power operation, and satisfy regulatory requirements for staged increases in reactor power. Similar hold points were selected for the Point Lepreau NGS and Bruce Power Units 1 and 2 refurbishment projects. CNSC staff have assessed that OPG has developed a return to service program management plan for the Darlington refurbishment project in accordance with RD-360 requirements. This plan describes the processes, procedures and organization that will be used by OPG to manage the commissioning and restart activities of the refurbished Darlington units. The plan also describes the return to service phases and hold points which will be used to ensure pre-requisite activities are complete and the required approvals are obtained prior to transitioning from one state to another. CNSC staff are recommending that approval to remove regulatory hold points be delegated to the Executive Vice President and Chief Regulatory Operations Officer, Regulatory Operations Branch. For reference, similar delegation of authority was previously granted by the Commission for the Bruce Power Units 1 and 2 and Point Lepreau refurbishment projects [23, 24]. Approval to remove a hold point will be contingent on OPG s submission of completion assurance documentation which provides evidence that all prerequisite commitments have been met. Pre-requisite commitments for each regulatory hold point are included in the draft Licence Conditions Handbook presented in Part 2 of this CMD. Prior to releasing a regulatory hold point, CNSC staff will verify compliance and provide a report to the Executive Vice President and Chief Regulatory Operations Officer, Regulatory Operations Branch. Based on the review of this report, the Executive Vice President and Chief Regulatory Operations Officer, Regulatory Operations Branch will issue a record of decision. The same process was used successfully for the Bruce Power Units 1 and 2 and Point Lepreau refurbishment projects. CNSC staff will update the Commission on the status of the refurbishment project as part of the annual CNSC Staff Regulatory Oversight Report for Canadian Nuclear Power Plants. The public will have an opportunity to participate in the proceedings when this report is presented to the Commission each year. In addition, as documented in the licence application, OPG has committed to appear before the Commission following the completion of each unit s refurbishment outage. CNSC staff will continue to update the Commission on the performance of the Darlington NGS, including refurbishment, as part of the routine status reports on power reactors and through event initial reports as necessary. e-doc (Word) July 2015 e-doc (PDF)

28 15-H8 Unprotected 3.5 Conclusions and Recommendations CNSC staff conclude that the assessments performed by OPG in support of Darlington refurbishment and life extension meet the expectations set out in CNSC regulatory document RD-360, Life Extension of Nuclear Power Plants. CNSC staff recommend the following conditions, specific to refurbishment and life extension, be included in the proposed licence: A condition requiring OPG to implement the IIP resulting from the ISR and the CEAA EA; A condition requiring OPG to implement a return to service plan for refurbishment activities; A condition requiring OPG to obtain the approval of the Commission, or consent of a person authorized by the Commission, prior to the removal of established regulatory hold points during return to service. These proposed conditions are included in the proposed licence and additional details are contained in the draft LCH. e-doc (Word) July 2015 e-doc (PDF)

29 15-H8 Unprotected 4. GENERAL ASSESSMENT OF SCAS CNSC staff s assessments, presented in the following sections, are based on the review of the safety and control measures to be implemented by OPG for the next licence period outlined in OPG s licence application and documentation submitted in support of the application and the review of OPG s past performance. The specific areas that comprise the SCAs for the Darlington NGS are identified in Addendum C.2 and in the following sections. Most specific areas and some other topics (including refurbishment execution) are included in the discussion section. If a specific area is not mentioned in the discussion section, it means that there was no relevant information for a licence renewal decision. Supporting details for the radiation protection SCA are provided in Addendum D of this CMD. The current licence period dates back to February 2013, however, CNSC staff have provided trending data back to 2008 and have included information from the previous licence period in some cases where deemed relevant for this licensing process. CNSC staff provide continuous regulatory oversight at the Darlington NGS. The table below presents the compliance effort from CNSC staff for the Darlington NGS in term person-days from 2008 to This effort includes staff from the CNSC Darlington site office as well as head office staff in Ottawa. CNSC staff compliance activities at the Darlington NGS (person-days) Inspections p-days S-99 Event Reviews p-days Other compliance p-days* Total p-days of effort *Includes verification activities such as the review of documents and reports submitted by OPG e-doc (Word) July 2015 e-doc (PDF)

30 15-H8 Unprotected 4.1 Management System The management system SCA covers the framework that establishes the processes and programs required to ensure an organization achieves its safety objectives and continuously monitors its performance against these objectives and fostering a healthy safety culture. This CMD covers the following specific areas of the management system: Management System and Organization Change Management Safety Culture Management of Contractors Configuration Management Records Management Trends The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: MANAGEMENT SYSTEM Annual Safety Performance Ratings SA SA SA SA SA SA SA Comment OPG continues to perform satisfactorily in this SCA at the Darlington NGS. SA = satisfactory Discussion Management System and Organization OPG is required to implement and maintain a management system at the Darlington NGS in accordance with CSA N286-05, Management system requirements for nuclear power plants. CNSC staff have assessed that OPG has a management system that meets N requirements. The 2005 version of CSA N286 has been superseded by N286-12, Management system requirements for nuclear facilities. The adoption of the 2012 version of CSA N286 does not represent a fundamental change to OPG s current management system and OPG has committed to implement the 2012 version by December 31, Business Transformation and Centre-led Organization The business transformation initiative (BTI) being implemented at OPG will change the manner in which OPG conduct s future business. The BTI is changing OPG to a centre-led matrix organization where production organizations (i.e. e-doc (Word) July 2015 e-doc (PDF)

31 15-H8 Unprotected Nuclear, Hydro, Thermal) will have common services (i.e. Finance, Human Resources) provided by central service organizations. The resulting centre-led matrix organization will also impact the implementation of the nuclear management system as a number of nuclear management system program owners will no longer be within the OPG nuclear organization. As such, interfaces between the OPG nuclear organization and service organization needed to be established to assure that the management system continues to meet regulatory requirements. CNSC staff reviewed OPG top tier governing documents to assess the impact of the changes being made. Based on the review of this, CNSC staff identified that the nuclear management system documentation required re-alignment to better reflect the BTI changes [25]. OPG has revised its governance where necessary to provide greater clarity in this regard. This area has been assessed as satisfactory as CNSC staff oversight activities have not identified any safety significant or systemic implementation deficiencies as a result of the BTI changes. Change Management The BTI has resulted in changes to the OPG nuclear organization including that of the Darlington NGS. Records were provided by OPG nuclear staff, to indicate that changes to the nuclear organization followed OPG s organizational change control process. Safety Culture OPG conducted a self-assessment of safety culture in The results were submitted to CNSC staff in 2013 which concluded that Darlington has a healthy safety culture, combined with a strong respect for nuclear safety and that is not compromised by production priorities. Areas for improvement were identified in the report and corrective actions are in place. CNSC staff reviewed this report and no additional concerns were identified. In 2015, OPG will conduct a safety culture self-assessment across its nuclear organization. Management of Contractors CNSC staff conducted an inspection in 2013 and identified deficiencies with respect to adhering to contract management procedures. The interface between OPG technical staff and supply chain staff was identified as an area requiring improvement. To address this issue, OPG conducted additional observation and coaching sessions to team members to re-iterate the importance of complying with contract management procedures. OPG has adequately addressed the inspection findings and CNSC staff declare that all actions have been closed [26]. Configuration Management An inspection conducted in 2013 identified some weaknesses with respect to configuration management at Darlington NGS. These weaknesses were determined not to be safety significant or systemic. OPG has adequately e-doc (Word) July 2015 e-doc (PDF)

32 15-H8 Unprotected addressed the inspection findings and CNSC staff declare that all actions have been closed [26]. Records Management CNSC staff conducted an inspection on document control and records management at OPG in 2012 [27]. The inspection identified specific areas for improvement that were addressed by OPG. CNSC staff reviewed OPG s response to the inspection findings and declare that all findings have been resolved and OPG meets CNSC regulatory requirements [28]. Implementation of records management at Darlington NGS is effective and continues to be monitored by CNSC staff on an on-going basis. Management System for Refurbishment As described in section 3 of this CMD, OPG will use Engineer, Procure, Construct (EPC) contractors to perform the majority of the refurbishment work. EPC contractors are approved under OPG s supply chain to ensure that the contractor has developed and implemented a management system that meets the requirements of the CSA N286 standard. OPG will oversee the activities of the EPC contractors including review and acceptance of all plans and deliverables, surveillance and witnessing of activities and initial and ongoing acceptance of the EPC contractor s management system. Although EPC contractors will perform the majority of refurbishment work, OPG retains the ultimate responsibility as licensee under the NSCA and associated Regulations. As such, OPG is accountable to ensure the health, safety and security of persons and the environment are protected, and this accountability cannot be delegated through contractual arrangements. CNSC staff will continue to conduct regulatory oversight to ensure that OPG is providing the necessary measures for contractor oversight for the refurbishment project Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance CNSC staff have verified that OPG has implemented and maintained a management system at the Darlington NGS that has met and continues to meet regulatory requirements and expectations. Regulatory Focus for the Next Licence Period Given that the majority of refurbishment work will be performed by EPC contractors, OPG s management of contractors will be key to the success of the refurbishment project. In addition, the changes resulting from BTI may also introduce additional challenges for OPG with respect to the alignment of the management system documentation and its implementation. CNSC staff s regulatory oversight will focus on these areas during the proposed licence period. e-doc (Word) July 2015 e-doc (PDF)

33 15-H8 Unprotected Proposed Improvements For refurbishment, OPG has developed governance for contractor management and is developing project specific oversight plans detailing how oversight of the EPC contractors will be managed. These plans will be updated during the course of the project as experience is gained and lessons are learned to ensure that safety and quality requirements are met at all phases of the project. OPG has committed to implement CSA N Management system requirements for nuclear facilities by December 31, This timeline is acceptable to CNSC staff Conclusion Based on CNSC staff assessments of OPG s licence application, supporting documents and past performance, CNSC staff conclude that OPG has implemented and maintained a management system at the Darlington NGS in accordance with CNSC regulatory requirements. Licence condition 1.1 in the proposed licence pertains to implementing and maintaining a management system. 4.2 Human Performance Management The human performance management SCA covers activities that enable effective human performance through the development and implementation of processes that ensure a sufficient number of licensee personnel are in all relevant job areas and have the necessary knowledge, skills, procedures and tools in place to safely carry out their duties. This CMD covers the following specific areas of human performance management: Human Performance Programs; Personnel Training; Personnel Certification; Initial Certification Examinations and Requalification Tests; Work Organization and Job Design; and Fitness for Duty. e-doc (Word) July 2015 e-doc (PDF)

34 15-H8 Unprotected Trends The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: HUMAN PERFORMANCE MANAGEMENT Annual Safety Performance Ratings SA SA SA SA SA SA SA Comment OPG continues to perform satisfactorily in this SCA at the Darlington NGS. SA = satisfactory Discussion The Darlington NGS PROL requires OPG to implement and maintain a human performance program, maintain a minimum shift complement at the facility, and implement and maintain a training program for workers and a certification program for certified staff in accordance with RD-204 Certifications of Persons Working at Nuclear Power Plants. CNSC staff have assessed that OPG has implemented and maintained adequate programs in order to ensure a sufficient number of qualified workers are available in all relevant job areas and have the necessary knowledge, skills, procedures and tools in place to safely carry out their duties. OPG programs in the area of human performance, personnel training, initial and requalification certification processes, minimum complement and fitness for duty ensure continued satisfactory performance in this SCA. Human Performance Programs OPG has a human performance program which establishes a framework for the various elements of the management of human performance across OPG. Numerous supporting documents provide the means by which human performance is integrated within the day-to-day operations of the facility. An inspection conducted in 2013 concluded that OPG met regulatory requirements [29]. Personnel Training OPG has a well-documented and robust fleet-wide training system grounded on the Systematic Approach to Training (SAT). The training programs at Darlington NGS are defined, designed, developed, implemented, evaluated and managed in accordance with the many processes and procedures that constitute its SAT-based training system. An inspection conducted in 2014 revealed that the nuclear operator training program at OPG did not fully adhere to its SAT-based training system [30]. For example, task lists were not being periodically reviewed, continuing training was not consistently delivered, and there were some course materials that were found out of date or incomplete. OPG was issued action e-doc (Word) July 2015 e-doc (PDF)

35 15-H8 Unprotected notices in order to provide CNSC staff with corrective action plans to address the discrepancies regarding this training program. The corrective action plans developed are being implemented to the satisfaction of CNSC staff. CNSC staff continue to monitor OPG s progress. This issue is not of safety significance or is it an impediment to licence renewal. The CNSC recently issued regulatory document REGDOC-2.2.2, Personnel Training, which sets out the CNSC's requirements and guidance for the development and implementation of a training system at nuclear facilities. REGDOC does not represent a fundamental change to OPG s current training programs. OPG will perform a gap analysis by March 2017 and will take the appropriate actions to ensure that its training system meets the requirements set out in the regulatory document as per OPG s transition plan which will follow after the gap analysis is complete. This approach is acceptable to CNSC staff and CNSC staff will oversee that any findings will be addressed by OPG. Personnel Certification OPG has sufficient numbers of personnel for all certified positions at Darlington NGS. CNSC staff conclude that the certified staff at Darlington are competent to perform the duties of their position safely and adequately. Initial Certification Requirements and Re-qualification Tests The initial certification examination program and requalification test program met the regulatory requirements for initial certification of workers and renewal of certification of workers. CNSC staff have assessed the processes and procedures and found them to be adequate. OPG continues to meet regulatory requirements for initial certification examinations and requalification tests. Work Organization and Job Design Minimum shift complement is defined as the minimum number of qualified workers who must be present in the nuclear facility at all times for normal operations and in order to respond to design basis accidents and emergencies should they occur. OPG has undertaken an extensive analysis of the minimum shift complement for the Darlington NGS, using the guidance set out in CNSC Regulatory Guide G- 323, Ensuring the Presence of Sufficient Qualified Staff at Class I Nuclear Facilities Minimum Staff Complement [31]. OPG conducted a validation exercise to demonstrate the adequacy of the minimum complement in January CNSC Regulatory Guide G-278, Human Factors Verification and Validation Plans, [32] was used as guidance. OPG has demonstrated industry leadership in the analysis and validation of minimum shift complement at the Darlington NGS. OPG has moved to a Days Based Maintenance organization in order to increase the efficiency of maintenance tasks. In order to make this transition, OPG also analyzed its Emergency Response Organization (ERO) structure and staffing requirements, particularly with respect to its maintenance staff. Validation exercises were conducted in 2012 for the maintenance and ERO staffing e-doc (Word) July 2015 e-doc (PDF)

36 15-H8 Unprotected requirements. The exercises demonstrated that the new ERO structure would provide an adequate response and meet the requirements set out to protect workers, the public and the environment. CNSC staff have verified that OPG has conducted a systematic and comprehensive analysis to determine its minimum shift complement and that OPG has implemented an effective process at the Darlington NGS to ensure that a sufficient number of qualified staff are available at the facility at all times. Fitness for Duty In accordance with CNSC requirements, OPG developed a procedure to monitor and control the hours of work of its employees and conducts its own compliance reviews of hours of work limits. This ensures that any systemic issues are identified and corrective actions are developed in order to limit the potential effects of fatigue on worker performance. CNSC staff carried out an inspection on hours of work in 2013 [33]. The inspection team concluded that OPG is currently maintaining compliance with its internal hours of work governance at the Darlington NGS as approved by the Commission. CNSC staff have verified that OPG has effective procedures in place to manage the risks of fatigue on worker performance and has adequate fitness for duty measures in place. Human Performance Management for Refurbishment Human Performance Programs OPG s provisions for human performance for its employees will remain in effect during refurbishment. Refurbishment contractors will have their own human performance programs. OPG will perform oversight to ensure that contractors implement practices to support excellence in human performance. CNSC staff will be verifying OPG s oversight of contractor organizations during the refurbishment project as part of the compliance program. Personnel Training OPG has developed plans that detail the activities and tasks necessary to fulfill training requirements of the entire refurbishment project, including the key elements and steps necessary for training various staff at various phases of the refurbishment project. It addresses the major areas of contractor on-boarding training, contractor project/job specific training, and OPG personnel training, including training for OPG personnel that will be involved with the refurbishment and those that must be trained to operate and maintain the plant postrefurbishment. On-boarding training includes OPG specific qualifications which will ensure that the workers have the skill sets to complete the work in a safe and reliable manner such as radiation protection training and nuclear general employee training. OPG has constructed a full scale replica of a Darlington reactor to train staff prior to performing work in the field (Figure 1). The construction of a full-scale reactor e-doc (Word) July 2015 e-doc (PDF)

37 15-H8 Unprotected mock-up will assist in the training of personnel, development of work plans and testing and commissioning of specialized tools. This will help ensure worker familiarity with tasks and tooling compatibility when the execution phase begins. OPG has committed to using its SAT-based training system to define, design, develop, implement and evaluate all refurbishment-related training that is the sole responsibility of OPG. Contractors training qualifications are defined, designed, developed, implemented and evaluated in accordance with the contractor s management system that meets the requirements of CSA N286. OPG will provide oversight of the contractors training and will ensure that a rigorous training system is applied in all cases. During refurbishment, OPG will implement a Training Change Control (TCC) Centre to ensure that all engineering, design and procedural changes are analyzed to identify and document their impacts on the various training programs and to coordinate the design, the development and the delivery of the modification training packages. Once the modification training packages have been delivered, the TCC Centre will also be accountable for the redesign and redevelopment of the existing initial and continuing training programs, in accordance with OPG s SAT based training system, which will be necessary as a result of the refurbishment changes. CNSC staff are satisfied that OPG has adequately detailed the activities and tasks necessary to fulfill the training requirements for the refurbishment project. Personnel Certification OPG s initial certification and requalification training, examination and testing programs will ensure that all certified personnel are competent to safely operate a refurbished unit prior to the re-start of the first refurbished unit. OPG will provide additional knowledge and performance training, formal evaluations and examinations for all certified shift personnel prior to the initial approach to criticality of a reactor unit following loading of the reactor core with new fuel. During refurbishment, Darlington's two full scope simulators will be maintained in fidelity with the refurbished units and the yet to be refurbished units accordingly: one simulator will be maintained in fidelity with the reference refurbished unit to accommodate updated initial and requalification certification training, examinations and testing on operations with new fuel, modified systems and components, while the other simulator will be maintained in fidelity with the units yet to be refurbished, to continue to facilitate initial certification and requalification training, examinations and testing programs on those units. Work Organization and Job Design During refurbishment activities, the minimum shift complement requirements will continue to be in place, monitored and enforced. There are no changes expected to minimum shift complement due to the refurbishment project. e-doc (Word) July 2015 e-doc (PDF)

38 15-H8 Unprotected Fitness for Duty OPG s provisions for fitness for duty for its employees will remain in effect during refurbishment. Refurbishment contractors will have their own fitness for duty programs which will include provisions for managing fatigue. OPG will perform oversight to ensure that contractors implement fitness for duty measures and provisions for managing fatigue. CNSC staff will be verifying OPG s oversight of contractor organizations during the refurbishment project as part of the compliance program Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance CNSC staff have assessed that OPG s programs under the Human Performance Management SCA at the Darlington NGS have met and continue to meet regulatory requirements and expectations. Regulatory Focus for the Next Licence Period CNSC staff s regulatory focus during the proposed licence period will be to ensure that all workers, including refurbishment contractors, are qualified to perform their assigned duties and that human performance expectations are demonstrated. CNSC staff will verify that training programs are amended to reflect the new configuration of the plant, incorporating all refurbishment-related engineering, design and procedural changes. Fitness for duty and fatigue management during refurbishment will also be areas of focus for CNSC staff. Proposed Improvements OPG will perform a gap analysis against REGDOC-2.2.2, Personnel Training by March 2017 and will take the appropriate actions to ensure that its training system meets the requirements set out in the regulatory document as per OPG s transition plan which will follow after the gap analysis is complete. This approach and timeline are acceptable to CNSC staff as REGDOC does not represent a fundamental change to OPG s current training programs. CNSC staff will report to the Commission (through the annual CNSC Staff Regulatory Oversight Report for Canadian Nuclear Power Plants) on the implementation progress of REGDOC e-doc (Word) July 2015 e-doc (PDF)

39 15-H8 Unprotected Conclusion Based on CNSC staff assessments of OPG s licence application, supporting documents and past performance, CNSC staff conclude that OPG continues to implement and maintain effective human performance management programs at the Darlington NGS in accordance with regulatory requirements. Licence conditions 2.1, 2.2 and 2.3 in the proposed licence pertain to the human performance management SCA. 4.3 Operating Performance The operating performance SCA includes an overall review of the conduct of the licensed activities and the activities that enable effective performance. This SCA also includes an accident management program for design and beyond design basis accidents. This CMD covers the following specific areas of operating performance: Conduct of Licensed Activity; Procedures; Reporting and Trending; Outage Management Performance; Safe Operating Envelope; Accident Management and Recovery; and Severe Accident Management and Recovery Trends OPG continues to maintain a set of programs covering the operating performance SCA which meet regulatory requirements. The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: OPERATING PERFORMANCE Annual Safety Performance Ratings FS FS FS FS FS FS FS Comment OPG s operating performance at the Darlington NGS continues to be fully satisfactory. FS = fully satisfactory Discussion OPG has a highly effective operations program at Darlington NGS that ensures the safety of workers, plant equipment, the public and the environment under normal and accident conditions. e-doc (Word) July 2015 e-doc (PDF)

40 15-H8 Unprotected CNSC site inspector s activities at the Darlington NGS include surveillance, monitoring, and inspections. Details of these activities and CNSC staff s assessment are presented in the following sections. Conduct of Licensed Activity Operational activities at the Darlington NGS are established by the Operating Policies and Principles (OP&Ps), as referenced in the current licence. The OP&Ps clearly outline the operating boundaries within which the stations may be operated safely. They specify how OPG will operate, maintain and modify station systems to maximize nuclear safety and minimize risk to the public. CNSC staff conduct routine inspections against the OP&Ps and have concluded that there is satisfactory implementation at the Darlington NGS. OPG maintains an effective Operational Experience (OPEX) program which gathers and disseminates operational experience at other nuclear stations to help prevent accidents. OPG stations have databases of information regarding identified problems for ongoing reporting and trending that OPG staff at all levels can access. Unplanned transients CNSC staff monitor unplanned transients which occur in the reactors. Unexpected power reductions may indicate problems within the plant and place unnecessary strain on the plant process systems to respond to the transients. Unplanned transients include stepbacks, setbacks and reactor trips where the trip resulted in a reactor shutdown. These unplanned transients are monitored and verified to ensure adherence to OP&Ps and this is used as an indicator by CNSC staff on how OPG manages its culture of response to events. A list of the number of unplanned transients from 2008 to 2014 is provided below. Unplanned Reactor Trips Number of unplanned transients from 2008 to Stepbacks Setbacks Total CNSC staff followed up on all transients that occurred and concluded that OPG followed approved procedures, investigated or evaluated the root causes of the events and took appropriate corrective actions. Although unplanned transients place unnecessary burden on the plant and its operating staff, none of these resulted in a risk to nuclear safety. e-doc (Word) July 2015 e-doc (PDF)

41 15-H8 Unprotected Procedures OPG has well defined processes in place to ensure that procedures are developed in a consistent manner to support the safe operation and maintenance of the Darlington NGS. OPG has a standard which specifies the requirements for the structure, minimum content and format of technical procedures which ensures that usability issues receive consideration in order to reduce error-likely situations. Additionally, OPG has clearly documented expectations for procedural use and adherence and implements a structured process for the development, review and approval of technical procedures. Reporting and Trending OPG continued to submit reports for the Darlington NGS in accordance with CNSC regulatory document S-99 Reporting Requirements for Operating Nuclear Power Plants until December 31, CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants came into effect on January 1, REGDOC supersedes S-99, Reporting Requirements for Operating Nuclear Power Plants. For all reportable events, OPG followed up with corrective actions and root cause analyses, when appropriate. Any significant events that are reported were raised to the Commission s attention either via event initial reports (EIRs) or the status update on power reactors. Outage Management Performance In order to ensure that the NPP remains fit for service, planned outages occur routinely to conduct maintenance, testing or inspections that cannot be performed when the reactor is at power. The table below provides the number of planned maintenance outages which occurred from 2008 to Number of Planned Maintenance Outages from 2008 to 2014 Unit For each of the planned maintenance outages, CNSC staff verified that adequate provision had been established for reactor safety, heat sinks, radiation protection, and that all regulatory committed work had been completed. OPG also undertook forced unplanned outages to fix or replace equipment. These were communicated to the Commission via EIRs, status reports on power reactors e-doc (Word) July 2015 e-doc (PDF)

42 15-H8 Unprotected or the annual CNSC Staff Regulatory Oversight Report for Canadian Nuclear Power Plants. OPG conducted appropriate follow-up actions for these outages. In the fall of 2015, OPG will be conducting a vacuum building outage to perform inspections and maintenance on the vacuum building and other unit specific work. All units will be shut down during this planned outage. Rod Based GSS A new guaranteed shutdown state called Rod-based Guaranteed Shutdown State (RBGSS) was proposed by OPG. It is a configuration achieved by guaranteeing that all Shut Off Rods (SORs), Control Absorbers (CAs) are in the core and Adjuster Absorbers (AAs) remain in the nominal configuration. Appropriate physical barriers and procedural controls are applied to prevent their inadvertent removal from the core. Following a review of OPG s safety case and a demonstration of rod-based GSS in one unit, CNSC staff approved the use of RBGSS in 2013 as an alternative Guaranteed Shutdown State for general use in all Darlington NGS units [34]. Safe Operating Envelope A licensed NPP must be controlled in accordance with a set of operational safety requirements, derived from the safety analysis, within the boundaries of the Safe Operating Envelope (SOE). The SOE is the set of limits and conditions within which a NPP must be operated and which is monitored and controlled by the operator. The objective of the SOE is to ensure compliance with the detailed safety analyses that are submitted by the licensee to demonstrate safe operation. CSA N290.15, Requirements for the Safe Operating Envelope of Nuclear Power Plants was developed to provide requirements for definitions, implementation and maintenance of the SOE. CNSC staff verified that this standard has been successfully implemented by OPG at the Darlington NGS. Along with the OP&Ps discussed previously, OPG s implementation of the SOE maintained the reactors operating in their analyzed state thereby ensuring adequate safety at all times. Accident Management and Recovery Licensees must have procedures capable of dealing with abnormal incidents and design basis accidents. OPG has a series of abnormal incident manuals (AIMs) and emergency operating procedures (EOPs) at the Darlington NGS to mitigate situations to return the plant to a safe and controlled state and to prevent the further escalation of the abnormal incident into a more serious accident. CNSC staff routinely perform verifications to ensure that up-to-date AIMs and EOPs are available to the operators, should they be required and that operators are trained in their use. CNSC staff are satisfied that this specific area at the Darlington NGS meets CNSC regulatory requirements. Severe Accident Management and Recovery A Severe Accident Management program provides an additional layer of defence against the consequences of beyond design basis accidents (BDBAs) including severe accidents. Severe Accident Management Guidelines (SAMGs) ensure that e-doc (Word) July 2015 e-doc (PDF)

43 15-H8 Unprotected personnel involved in managing a BDBA have the information, procedures and resources necessary to carry out effective onsite actions. In a staged approach agreed to by CNSC staff, OPG has implemented SAMGs for single unit events [35]. The outstanding work of the SAMG project at Darlington will address the final enhancements to the SAMG documentation, as well as required training and drills to demonstrate effectiveness. These enhancements are scheduled for completion in 2015 and will include multi-unit SAMG and SAMG for irradiated fuel bays. The existing SAMG could be used to manage response to a severe accident on more than one unit, but the work that will be done will enhance the response to a multi-unit accident, and will incorporate additional lessons learned from the Fukushima event. CNSC staff have witnessed the execution of a simulated severe accident involving the use of SAMG procedures during emergency drills and exercises, including Exercise Unified Response. CNSC staff conclude that the SAMG program development has added another layer of defence-in-depth against extremely rare low-probability events. OPG has committed to implement REGDOC-2.3.2, Accident Management: Severe Accident Management Programs for Nuclear Reactors by December 31, This timeline is acceptable to CNSC staff. Operating Performance for Refurbishment As stated in the licence application, OPG will put in place physical barriers and boundary points to capture the partition between the operating units and the unit undergoing refurbishment. In addition, OPG has committed to ensure that the refurbishment unit configurations and activities will not violate the SOE of the operating units. The primary change to SOE arising during refurbishment will involve revisions to the OP&Ps to reflect the unit and station configuration. Any changes to the OP&Ps will be supported by assessment and analysis and subject to CNSC notification or approval as required Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance OPG continues to be a top performer in the area of operating performance at Darlington NGS. The conduct of operations is accompanied by a strong OPEX program, reporting and the development of clear procedures and guidelines. CNSC staff have assessed Darlington s operating performance as fully satisfactory for the past seven years. e-doc (Word) July 2015 e-doc (PDF)

44 15-H8 Unprotected Regulatory Focus for the Next Licence Period CNSC staff will continue to verify OPG s compliance with the SOE and OP&Ps during the proposed licence period. In particular, CNSC staff will focus on the OP&P changes necessary to reflect the unit and station configuration during refurbishment. Proposed Improvements OPG will be conducting a vacuum building outage at the Darlington NGS in the fall of 2015 to perform inspections and maintenance on the vacuum building and other unit specific work. All units will be shut down during this planned maintenance outage. In addition, OPG has committed to implement REGDOC-2.3.2, Accident Management: Severe Accident Management Programs for Nuclear Reactors by December 31, Conclusion Based on CNSC staff assessments of OPG s licence application, supporting documents and past performance, CNSC staff conclude that OPG continues to implement and maintain an effective operations program at the Darlington NGS in accordance with regulatory requirements. Licence conditions 3.1 to 3.4 in the proposed licence pertain to the operating performance SCA. 4.4 Safety Analysis The safety analysis SCA covers the maintenance of the safety analysis that supports the overall safety case for the facility. Safety analysis is a systematic evaluation of the potential hazards associated with the conduct of a proposed activity or facility and considers the effectiveness of preventative measures and strategies in reducing the effects of such hazards. This CMD covers the following specific areas of safety analysis: Deterministic Safety Analysis; Probabilistic Safety Analysis; Hazard Analysis; and Management of Safety Issues (including R&D programs) Trends CNSC staff have reviewed a number of submissions related to the different aspects of safety analysis during the current licence period and no issues of major concern have been identified. Some safety analysis issues remain open and, where necessary, compensatory measures are in place to reduce risk to a very low level. Overall, progress by OPG has been acceptable and a high level of safety has been demonstrated. e-doc (Word) July 2015 e-doc (PDF)

45 15-H8 Unprotected OPG continues to perform satisfactorily in the safety analysis SCA at the Darlington NGS. The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: SAFETY ANALYSIS Annual Safety Performance Ratings SA SA SA SA SA SA SA Comment OPG s performance in the safety analysis SCA continues to be satisfactory. SA = satisfactory Discussion The CNSC requires OPG to conduct safety analysis for the Darlington NGS to demonstrate that the design continues to provide adequate prevention and mitigation to protect against postulated accidents and that the plant meets safety requirements. A number of submissions related to the different aspects of safety analysis have been reviewed during the current licence period and the most significant of these are highlighted below. Deterministic Safety Analysis OPG s reactor safety program and implementing procedures and standards govern management of issues related to nuclear safety analysis and their impact on safe operation. Further details on deterministic safety analysis at the Darlington NGS are described below. Implementation of REGDOC-2.4.1, Deterministic Safety Analysis As with all NPPs in Canada, OPG is required to maintain a very comprehensive, systematic and conservative deterministic safety analysis for the Darlington NGS. While the current deterministic safety analysis for the Darlington NGS has proven satisfactory in demonstrating the safety of the plant, OPG has undertaken a safety analysis improvement initiative to adopt modern safety analysis requirements by implementing CNSC regulatory document RD-310 Safety Analysis for Nuclear Power Plants. In 2013, CNSC staff reviewed OPG s RD-310 implementation plan for the Darlington NGS. CNSC staff concluded that the plan was based on a welldocumented process; the required prerequisite activities and influencing factors were identified and considered. The planned sequence of upgrading Safety Report appendices was found acceptable [36]. In May 2014, RD-310 was superseded by REGDOC-2.4.1, Deterministic Safety Analysis. The changes between RD-310 and REGDOC arise in part to reflect lessons learned from the Fukushima event and to address findings from the CNSC s Fukushima Task Force Report [37]. For existing facilities, REGDOC is being gradually implemented. e-doc (Word) July 2015 e-doc (PDF)

46 15-H8 Unprotected OPG provided CNSC staff with its REGDOC implementation plan in May OPG s approach will be to conduct all new analyses in accordance with REGDOC and to update existing analyses which will provide the most value in terms of demonstrable safety benefit. CNSC staff will continue to review OPG s implementation of REGDOC as part of the CNSC normal compliance program. As part of REGDOC implementation, OPG has recently updated the Darlington loss-of-moderator heat sink analysis. The CNSC staff review of the pilot analysis concluded that the approach adopted in the analysis is consistent with REGDOC and that the analysis can be considered to be a cornerstone of safety analysis improvement. Review findings were provided to OPG for improving the pilot analysis to ensure that it will be fully in line with REGDOC These comments were fully addressed to the satisfaction of CNSC staff [38]. OPG is now in the process of updating the analysis for incorporation into the Darlington Safety Report. This is not considered to be an impediment to licence renewal. Impact of Aging on Safety Analysis Margins OPG has an aging management program in place at the Darlington NGS which includes systematic monitoring of aging related parameters important to safety analysis and assessment of the impact of the aging parameters on the existing safety margins. CNSC staff have reviewed the OPG program to monitor and assess the impact of heat transport system aging on safety analysis and found it satisfactory as it meets CNSC requirements. In December 2013, OPG submitted the latest Darlington NGS deterministic safety analysis for impact of aging on safety margins for loss of flow and small break loss of coolant accidents. CNSC staff have completed the review of the OPG submissions and conclude that the analysis clearly demonstrates adequate margin for Darlington reactors and that the analysis was conducted using acceptable methods. Based on the results of the risk informed decision making (RIDM) process, CNSC staff have concurred with OPG s approach and with the values for Neutron Overpower Protection (NOP) trip setpoints until There is no safety concern as the physical trip setpoints provide adequate protection of the fuel and fuel channels. NOP and aging management related issues will be addressed by the refurbishment of the Darlington NGS reactors. Non-aging related Safety Analysis Safety Code Validation Work An action item was raised by CNSC staff to track OPG s progress in addressing the validation work for a thermalhydraulics computer code called Two Unequal Fluids (TUF). In response to the raised action, OPG has submitted a plan for establishing the TUF validation basis for ongoing and future safety analyses. e-doc (Word) July 2015 e-doc (PDF)

47 15-H8 Unprotected CNSC staff found the proposed plan acceptable [39] and consequently the action item was closed. Coolant Void Reactivity In 2012, OPG reported [40] that a recent re-evaluation of uncertainties in predictions of coolant void reactivity by the Industry Standard Toolset of physics codes concluded that the value of the coolant void reactivity coefficient used in large break LOCA analysis had been underestimated. CNSC staff have completed their evaluation of OPG s 2014 submission regarding the impact of the 2012 findings on Darlington NGS large break LOCA analysis, and found the assessments acceptable with the analyses results supporting the continued safe operation. The analysis results confirmed that all key safety parameters are within the current CNSC large break LOCA limits [41] based on existing analysis. As the regulatory oversight continues and if new information demonstrates the need for changes in CNSC in large break LOCA limits, CNSC staff will take the necessary action towards the licensee. CNSC staff will continue to conduct regulatory oversight in this area and will report to the Commission on an annual basis through the CNSC Staff Regulatory Oversight Report for Canadian Nuclear Power Plants. Probabilistic Safety Analysis Probabilistic safety analysis (PSA) provides a comprehensive, structured approach to identifying accident scenarios and deriving numerical estimates of risks. The main benefit of PSA is to provide insights into plant design and operation, including the identification of dominant risk contributors and safety improvement opportunities, and the comparison of options for reducing risk. PSA is used in a complementary manner to the traditional deterministic safety analysis and defence-in-depth considerations. OPG s risk and reliability program at the Darlington NGS establishes a framework for the development and use of PSA as a means to manage radiological risk and contribute to safe operation of the facility. Further details on PSA at the Darlington NGS are described below. Darlington PSA Submission In 2011, OPG submitted a detailed and comprehensive PSA for the Darlington NGS as required by the PROL. The PSA was based on the requirements of CNSC regulatory standard S-294 Probabilistic Safety Assessment for Nuclear Power Plants and on OPG methodologies and computer codes which were previously accepted by CNSC staff [42]. The PSA marked the first such work completed per the requirements of S-294, which included results for both internal and external events. CNSC staff completed an in-depth, systematic review of the PSA and confirmed that the submitted PSA followed the accepted methodologies and that Darlington NGS is compliant with the requirements of S-294. e-doc (Word) July 2015 e-doc (PDF)

48 15-H8 Unprotected In addition to the requirements of S-294, OPG also submitted the analysis of seismic events leading to consequential fires and floods, committed as part of OPG's response to the Fukushima Daiichi event. The methodology was the first of its kind and was prepared in partnership with the Electrical Power Research Institute (EPRI), including reviews by EPRI staff and U.S. and European utilities. The submission was also reviewed by CNSC staff as part of the PSA review and CNSC staff concluded that the submission meets CNSC expectations [43]. Darlington PSA Submission OPG recently submitted an update to the Darlington PSA in The 2015 PSA update includes recent design modifications and station operating experience as well as the consideration of feedback from CNSC staff s review of the 2011 PSA. In consideration of the latest changes in IAEA and EPRI hazard screening methodologies, a High Wind PSA has been included in the 2015 PSA update. The 2015 PSA update submission includes Emergency Mitigating Equipment (EME) credit in the baseline studies. In addition, the 2015 PSA update includes a separate case that credits the Safety Improvement Opportunities (SIOs), identified prior to the Fukushima event, as part of the refurbishment project and committed as part of the CEAA EA. Further details on the SIOs are contained in section 5.5 of this CMD. At the time that this CMD was being written, OPG was preparing a public summary report of the results and assumptions of the 2015 PSA update. OPG is planning to post this report on their external website in August Darlington 2015 PSA Update Results OPG s PSA results for the Darlington NGS are presented in the tables below. Consistent with other NPP licensees, OPG uses two internationally accepted metrics to assess the probabilistic risk of potential accidents at its NPPs. These safety goals are called Severe Core Damage Frequency and Large Release Frequency. Severe Core Damage Frequency (SCDF) is a measure of the likelihood of releasing radioactive material from the fuel into containment. Large Release Frequency (LRF) is a measure of the potential for release of radioactive material from containment to the environment. These metrics are quantified in the PSA with the results expressed as a frequency of occurrence per reactor year. OPG s safety goal limit for SCDF is 1x10-4 per reactor-year and its safety goal limit for LRF is 1x10-5 per reactor-year. In addition, OPG sets safety goal targets which are one order of magnitude lower than the safety goal limits. OPG s safety goals target for SCDF is 1x10-5 per reactor-year and its safety goal target for LRF is 1x10-6 per reactor-year. The tables below present the SCDF and LRF for each individual hazard group as well as the single unit aggregated SCDF and LRF for all hazards based on the conservative method of simple addition. The results show that the SCDF for individual and aggregated hazards are below OPG s safety goal targets and limits. e-doc (Word) July 2015 e-doc (PDF)

49 15-H8 Unprotected The results also show that the LRF for individual and aggregated hazards are below OPG s safety goal limits, with most of the results being below the OPG safety goal target. The one exception is the seismic hazard which is above the OPG safety goal target. As a result, OPG is developing an action plan for risk improvement opportunities to further reduce LRF where practicable. The action plan will consider analytical improvements to the PSA as well physical modifications to the station. This issue is not an impediment to licence renewal and CNSC staff will update the Commission on this matter as part of the annual CNSC staff Regulatory Oversight Report for Canadian Nuclear Power Plants. Darlington Level 1 PSA Results Severe Core Damage Frequency (x 10-5 per reactor-year) Hazard Group 2015 PSA (with EME) 2015 PSA (with EME and SIOs) At Power Internal Events Outage Internal Events Internal Flood 0.02 < 0.02 Fire 0.09 < 0.09 Seismic High wind Aggregation by simple 0.93* 0.47* addition Safety Goal Target 1 1 Safety Goal Limit *The aggregated SCDF does not include the internal events during outage because the internal events at power are bounding and conservatively assume that unit is at full power at all times. Darlington Level 2 PSA Results Large Release Frequency (x 10-5 per reactor-year) Hazard Group 2015 PSA (with EME) 2015 PSA (with EME and SIOs) At Power Internal Events Outage Internal Events < 0.10 <0.05 Internal Flood 0.02 < 0.02 Fire 0.08 < 0.08 Seismic 0.28 < 0.14 High wind Aggregation by 0.58* 0.33* simple summation Safety Goal Target Safety Goal Limit 1 1 *The aggregated LRF does not include the outage internal events because the internal events at power are bounding and conservatively assume that unit is at full power at all times. e-doc (Word) July 2015 e-doc (PDF)

50 15-H8 Unprotected Whole-site PSA OPG has committed to develop a pilot whole-site PSA for the Pickering NGS which is expected to be completed by the end of This work involves the development of appropriate whole-site safety goals and a consensus methodology for risk aggregation. A concept-level, whole-site PSA methodology has been issued as a CANDU Owners Group (COG) document which is publicly available on OPG s external website. The Canadian nuclear industry is leading the world in the development of such a methodology. The lessons learned from the Pickering whole-site PSA will be taken into consideration for the Darlington NGS. Implementation of REGDOC-2.4.2, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants CNSC Regulatory Standard, S-294 was superseded by REGDOC-2.4.2, Probabilistic Safety Assessment (PSA) for Nuclear Power Plants in May The changes in requirements between S-294 and REGDOC arise in part to reflect lessons learned from the Fukushima event and to address findings from the CNSC s Fukushima Task Force Report [37]. REGDOC is being gradually implemented for existing facilities and OPG has committed to implement REGDOC for the next PSA update in PSA Conclusion CNSC staff are satisfied with the Darlington 2015 PSA update, which incorporates the contribution of both the SIOs and EMEs, and confirm that the PSA modelling followed the methodologies accepted by CNSC staff. The 2015 PSA update results show that the EMEs and SIOs improve safety in terms of providing mitigating capabilities as an additional layer of defence in depth for very rare events. The SCDF limit and LRF limit are met for the Darlington NGS. CNSC staff conclude that the updated PSA for the Darlington NGS meets CNSC regulatory requirements. Hazard Analysis Fire protection During the current licence period, OPG updated its Fire Hazard Assessment (FHA) and Fire Safe Shutdown Analysis (FSSA) for the Darlington NGS in accordance with CSA N Fire Protection for Nuclear Power Plants and industry best practices. CNSC staff reviewed and assessed OPG s FHA and FSSA and concluded that they meet regulatory requirements as set out in the standard [44]. The FHA and FSSA identified areas for improvement to enhance fire protection provisions at the Darlington NGS. The majority of the identified areas for improvement have been addressed. The remaining enhancements, primarily related to additional fire detection system coverage, will be addressed during the upcoming refurbishment outages. e-doc (Word) July 2015 e-doc (PDF)

51 15-H8 Unprotected With the current fire protection provisions in place, the outstanding areas for improvement do not represent an increased risk to nuclear safety and the proposed upgrades will enhance the fire safety at the facility and strengthen the fire defence in depth. CNSC staff will monitor the implementation of these enhancements as part of the normal compliance program. Seismic Hazard Analysis OPG has performed a Probabilistic Seismic Hazard Analysis (PSHA) for the Darlington NGS as an input to the seismic PSA. CNSC staff retained the services of Natural Resources Canada (NRCan) to review OPG s PSHA. Based on NRCan s review, CNSC staff concluded that the Darlington NGS PSHA is of good overall quality in estimating the seismic hazard at the Darlington site. Some follow-up actions were identified which OPG is addressing to the satisfaction of CNSC staff. OPG has assessed the impact of implementing these follow up actions on the seismic PSA and determined that their impact on the PSA results are negligible and do not challenge OPG s PSA safety goal limit. CNSC staff have reviewed and concur with OPG s assessment and will continue to monitor this area as part of the normal compliance program. Management of Safety Issues (including R&D programs) The existing CANDU reactors are designed to safely shutdown in response to even the most remote accident. In addition, completion of the recent Fukushima enhancements have added portable emergency mitigating equipment, cooling water access points to critical systems, which have upgraded the capability of operating crews even further to handle these remote emergencies. However, in the lifetime of a NPP, safety issues may arise as a result of such things as plant aging, research and development (R&D) discoveries, or lessons learned from accidents. As part of continuous improvement, OPG manages these issues as part of the overall safety analysis effort. In other words, the CNSC requires its licensees to continuously work to improve safety. Below are some issues that are known to have adequate safety measures in place, but form part of the continuous safety improvement work required by the CNSC. 1. Fukushima Action Items Follow up actions as a result of the Fukushima event are managed as Fukushima Action Items. Progress on these items is reported to the Commission as part of the annual CNSC staff Regulatory Oversight Report for Canadian Nuclear Power Plants. A summary of OPG s response to the lessons learned from Fukushima are provided in section 5.5 of this CMD. 2. CANDU Safety Issue AA3: Computer Codes and Plant Model Validation CANDU Safety Issue (CSI) AA3 on computer codes and plant model validation was raised in 2007 to ensure the adequacy of computational toolsets and plant models used in safety analysis. OPG, in cooperation with other members of the nuclear industry, has developed two guidelines, one addressing code validation and the other addressing assessment of code accuracy. CNSC staff assessed these e-doc (Word) July 2015 e-doc (PDF)

52 15-H8 Unprotected guidelines and concluded that OPG has made significant progress towards reclassification of CSI AA3. OPG has provided a plan to respond to CNSC comments on both guidelines. CNSC staff reviewed the plan and concluded that OPG has addressed all concerns therefore CNSC staff reclassified the CSI to the very low risk Category 2, since OPG has appropriate control measures in place to address the issue and to maintain safety margins [45]. 3. Channel Voiding during a Large Break Loss of Coolant Accident (LBLOCA) Follow-up to GAI 00G01 In a highly unlikely postulated large loss of coolant accident in a CANDU reactor, coolant in the fuel channels turns to steam as the primary heat transport system pressure falls. This voiding of the fuel channels causes an increase in the reactivity of the reactor (the positive void reactivity effect). This causes power to rise until one of the two fast-acting shutdown systems terminates the nuclear chain reaction in less than two seconds. The severity of the power pulse depends on the coolant voiding rate in the fuel channels. Generic Action Item (GAI) 00G01 was raised to confirm the ability of safety analysis computer codes to accurately predict core voiding. This GAI was closed in 2012 [46] with follow-up work requested of OPG, which was submitted to CNSC staff in CNSC staff have reviewed follow up work and concluded that there are no safety concerns as OPG has demonstrated satisfactorily that the computer codes and models used are acceptable for their application [47]. CANDU Safety Issues AA9 Analysis of Void Reactivity Coefficient, PF9 Fuel behaviour in high temperature transients and PF10 Fuel behaviour in power pulse transients In 2014, CNSC staff completed assessment of the industry s proposed Composite Analytical Approach (CAA) which was submitted for CNSC staff review in late The CAA is a new large loss of coolant accident (LOCA) analysis framework being proposed by industry to resolve the CANDU Safety Issues AA 9, PF 9 and PF 10. This assessment includes an evaluation of the adequacy of knowledge base to support each technical element of CAA, as well as an evaluation of the work done towards two fundamental activities related to reevaluation of the reactor physics parameters and the applicable acceptance criteria. CNSC staff acknowledge the significant effort spent by the industry to complete the CAA and to consolidate current state of knowledge in certain key areas. However, with respect to the regulatory use of the proposed CAA, CNSC staff concluded that the approach needs further validation. The results of CNSC staff review have been communicated to OPG [48] and OPG responded to staff findings in April CNSC staff are reviewing OPG s response and plan to update the Commission on the progress towards addressing CANDU Safety Issues AA9, PF9 and PF10 in late 2015 or early e-doc (Word) July 2015 e-doc (PDF)

53 15-H8 Unprotected Safety Analysis for Refurbishment OPG s reactor safety program and risk and reliability program will continue to provide the framework for safety analysis during refurbishment. All refurbishment modifications are being carried out in accordance with OPG engineering change control governance which requires an assessment against reactor safety criteria and consideration of impact on safety analysis. Modifications which may impact or be credited in the safety analysis will be handled in accordance with established OPG processes. The SIOs (further described in section 5.5) were selected based on risk insights gained from PSA. Once all units have been refurbished, the PSA will be updated to reflect the detailed design and as-installed configuration Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance OPG s past performance has been satisfactory. Progress has been made in all areas in the safety analysis SCA. Units were operated within licensing limits and safely during the current licence period. Regulatory Focus for the Next Licence Period The regulatory focus for the safety analysis SCA will be on the gradual implementation of CNSC regulatory documents REGDOC-2.4.1, Deterministic Safety Analysis and REGDOC-2.4.2, Probabilistic Safety Analysis (PSA) for Nuclear Power Plants, which will result in a more modern deterministic and probabilistic safety analysis such as accounting for aging impacts on the safety margins. Proposed Improvements OPG is working with industry partners to develop a whole site PSA for Pickering and will apply the lessons learned to Darlington. In addition, OPG will conduct all new deterministic safety analyses in accordance with REGDOC and will fully implement REGDOC by As safety analysis is continuously updated over time, this is not a major change but an incremental improvement Conclusion The overall safety case for the Darlington NGS continues to be satisfactory. Based on CNSC staff assessments of the proposed safety and control measures outlined in OPG s licence application, supporting documents and past performance, specific concerns related to this SCA are being addressed through conservative compensatory measures. OPG continues to implement and maintain an effective safety analysis program at Darlington NGS in accordance with regulatory requirements. e-doc (Word) July 2015 e-doc (PDF)

54 15-H8 Unprotected Licence condition 4.1 in the proposed licence pertains to implementing and maintaining a safety analysis program. 4.5 Physical Design The physical design SCA relates to activities that impact on the ability of systems, components and structures to meet and maintain their design basis given new information arising over time and taking changes in the external environment into account. This CMD covers the following specific areas of physical design: Design Governance; System Design; and Component Design Trends The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: PHYSICAL DESIGN Annual Safety Performance Ratings SA SA SA SA SA SA SA Comment OPG s performance in the physical design SCA continues to be satisfactory. SA = satisfactory Discussion The Darlington NGS PROL requires OPG to implement and maintain design programs in accordance with applicable CSA standards as set out in the LCH. CNSC staff have verified that OPG s programs with respect to the physical design SCA continue to meet regulatory requirements and expectations. Further details are provided in the sections that follow. Design Governance Environmental Qualification Program OPG s environmental qualification (EQ) program at the Darlington NGS ensures that all required Structures, Systems and Components (SSCs) are capable of performing designated safety functions during and following postulated harsh environment conditions resulting from design basis accidents. The EQ program must be implemented and maintained in accordance with CSA N , Environmental qualification of equipment for CANDU nuclear power plants. CNSC staff are satisfied that OPG has implemented and is maintaining an e-doc (Word) July 2015 e-doc (PDF)

55 15-H8 Unprotected effective EQ program at the Darlington NGS that complies with the CSA N standard. A CNSC staff inspection conducted in 2014 [49] concluded that OPG s EQ program at the Darlington NGS meets regulatory requirements. A few minor findings were identified related to electrical cable identification and verification of EQ maintenance records. These findings are of low safety significance and OPG is addressing them to the satisfaction of CNSC staff. Human Factors in Design Human factors engineering is the application of knowledge about human capabilities and limitations to plant, system, and equipment design. OPG has an engineering change control process that addresses human factors. OPG has developed a number of procedural tools to improve its process for incorporating human factors when modifications are made to the station. These procedural tools have strengthened OPG s process for addressing the needs of end users when modifications are carried out. CNSC staff are satisfied with OPG s engineering change control process that addresses human factors. Pressure Boundary Program The pressure boundary program comprises the processes used by OPG to ensure pressure boundary activities at Darlington are performed in accordance with the requirements of CSA N285.0 General requirements for pressure-retaining systems and components in CANDU nuclear power plants. As well, OPG has a formal service agreement with the Technical Standards and Safety Authority (TSSA) as the Authorized Inspection Agency (AIA). In 2013, OPG implemented a transition plan from N Update No. 1 to N Update No. 2 at the Darlington NGS. OPG will be adopting the latest CSA N Update No. 1 Annex N Pressure Boundary Program Document in 2015 to improve the documentation of the pressure boundary program. CNSC staff conducted an inspection in 2013 to verify compliance with the current PROL on the implementation of the pressure boundary program processes for system code classification, reconciliation and registration, as well as the AIA service agreement [50]. CNSC staff found that the implementation, for both the code classification and design registration reconciliation process, met regulatory requirements. Overall, CNSC staff conclude that OPG s pressure boundary program meets regulatory requirements. System Design Electrical Systems CNSC staff determined that OPG s performance with regards to the electrical power system at Darlington NGS has remained satisfactory over the current licence period. The last CNSC inspection was completed in September 2014 with the main focus on the class I, II and III electrical power systems [51]. The inspection confirmed that the class I, II and III power systems are being maintained and tested to ensure that they are able to perform their design e-doc (Word) July 2015 e-doc (PDF)

56 15-H8 Unprotected functions. Areas for improvement have been identified which OPG is addressing to the satisfaction of CNSC staff. CNSC staff continue to monitor OPG s performance in this area as part of the compliance program. Overall, CNSC staff are satisfied with OPG s performance with regards to the electrical power system at the Darlington NGS. Instrumentation and Control (I&C) including Software OPG has improved the performance of its instrumentation and control (I&C) systems as well as the associated software through the replacement of Digital Control Computers with Programmed Data Processor PDP11/70 emulators and engineering changes to the reactor regulating control programs (i.e. adding alarms). In addition, OPG has committed to carrying out modifications on the control rod logic modules power supplies. CNSC staff are continuing to review these I&C system modifications as proposed by OPG and are satisfied that the modifications should improve system reliability and maintainability in the future. Fire Protection - Design During the current licence period, OPG carried out a code compliance review (CCR) of the Darlington NGS for compliance with CSA N Fire Protection for Nuclear Power Plants as well as key standards referenced therein such as the National Building Code of Canada, National Fire Code of Canada, and associated National Fire Protection Association standards. CNSC staff s assessment concluded that the CCR for the Darlington NGS is in compliance with the requirements of CSA N293. OPG continues to submit third party reviews (TPRs) of proposed modifications with the potential to impact protection from fire. The submission of the TPRs provides evidence to CNSC staff that the compliance criteria for modifications are being met. CNSC staff have performed desktop reviews of the TPR s and found that they meet regulatory requirements as set out in CSA N Seismic Qualification Seismic qualification at the Darlington NGS ensures that all required structures, systems, and components (SSCs) are capable of performing designated safety functions during and following postulated design basis earthquakes. The Darlington NGS was designed in accordance with the CSA N289 series of standards for seismic design of CANDU reactors in place at the time. In addition, OPG has performed a seismic re-evaluation of the Darlington NGS in the form of a seismic PSA in accordance with regulatory requirements. CNSC staff performed a seismic qualification inspection at the Darlington NGS in 2015 [52]. The inspection concluded that OPG has effective processes in place to ensure the preservation of system seismic qualification that meets regulatory expectations. CNSC staff have introduced two CSA standards in the draft LCH as compliance verification criteria for the physical design SCA. These are CSA N General Requirements for Seismic Design and Qualification of CANDU Nuclear e-doc (Word) July 2015 e-doc (PDF)

57 15-H8 Unprotected Power Plants and CSA N Requirements for Safety Related Structures for CANDU Nuclear Power Plants. OPG has confirmed that the Darlington NGS meets the requirements contained in these CSA standards. CNSC staff will continue to monitor this area as part of the CNSC normal compliance program. Robustness Design Robustness design covers the physical design of nuclear facilities for sufficient robustness against anticipated threats, such as protection against a malevolent aircraft crash. OPG has submitted analyses, including the submission of detailed aircraft impact assessments. OPG has demonstrated, through analysis using conservative initial assumptions and significant safety margins, that vital areas and critical SSCs are protected to the extent that no offsite consequences are expected for general aviation aircraft impact. Additional information with respect to malevolent acts are contained in a separate, protected CMD 14-M81 which was presented to the Commission on December 17, Component Design 37-Element Modified Fuel Bundle OPG has implemented a modification to the currently used 37-element fuel design at Darlington NGS, in order to optimize and improve its thermalhydraulic performance. The modified fuel (37M) is essentially a small variation of the current 37-element fuel, with the diameter of the centre element being slightly reduced while the overall bundle dimensions are retained. This allows more coolant to pass through the fuel bundle thus improving heat removal. The use of the 37M fuel will improve safety margins over the current 37-element fuel design and, consequently, offset partially the safety margin erosion due to plant aging. To date, 37M fuel in core performance has matched expectations and is consistent with the high performance expected of CANDU fuel. Fuel Inspection Program OPG has a well-developed reactor fuel inspection program. Fuel performance at Darlington was acceptable during the current licence period although there has been an increase in the number of fuel defects found in operating units. OPG continues to investigate the causes, and develop and implement corrective actions. CNSC staff consider OPG s fuel program to be robust and conclude OPG is able to adequately manage this issue and maintain safe operations. Electrical Power Cables Electrical power cables have key importance to the safe and reliable operation of NPPs due to their widespread use as the connection medium with many systems important to safety. OPG has implemented an in-situ testing and condition monitoring program of its installed low voltage cables at the Darlington NGS. In addition, OPG has implemented a cable surveillance program, supplemented with a cable aging program to focus on safety-related and operationally-important cables at Darlington. CNSC staff are satisfied with OPG s progress and will continue to monitor this area as part of the CNSC normal compliance program. e-doc (Word) July 2015 e-doc (PDF)

58 15-H8 Unprotected Physical Design for Refurbishment OPG is carrying out refurbishment modifications under its design management and engineering change control governance. For engineering done by contractors, OPG is specifying the requirements for the modifications while design agency contractors prepare the design, including design reports, drawings, calculations and any other documents required by engineering governance. All design agency contractors are qualified under OPG supply chain to ensure that the contractor has developed and implemented a management system that meets the requirements of the CSA N286 standard. OPG continues to oversee the activities of the refurbishment design agencies including review and acceptance of plans and deliverables, established mandatory hold points during the design process and initial and ongoing acceptance of the EPC contractor s management system. CNSC staff will be monitoring OPG s oversight and implementation of the EPC contractor s design processes during refurbishment as part of the compliance program. As per the agreement reached in CNSC letter dated June 22, 2012 [53] a number of design-related codes and standards, associated effective dates and conditions were established to ensure consistent and stable design requirements are applied throughout the refurbishment project Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance During the current licence period, OPG has demonstrated that the design basis of equipment essential to support safe and reliable plant operation has been maintained. OPG continues to maintain the plant configuration in accordance with the design and licensing bases and operation within its safe operating envelope. Overall, CNSC staff have assessed that OPG s programs with respect to the physical design SCA continue to meet regulatory requirements and expectations. Regulatory Focus for the Next Licence Period During the proposed licence period, CNSC staff will continue to focus on OPG s engineering oversight of design agency contractors to verify that refurbishment modifications are compliant with OPG s design management and engineering change control governance. Proposed Improvements CNSC staff have introduced two CSA standards in the draft LCH as compliance verification criteria for the physical design SCA. These are CSA N General Requirements for Seismic Design and Qualification of CANDU Nuclear Power Plants and CSA N Requirements for Safety Related Structures for CANDU Nuclear Power Plants. OPG has confirmed that the Darlington NGS meets the requirements contained in these CSA standards. CNSC staff will verify e-doc (Word) July 2015 e-doc (PDF)

59 15-H8 Unprotected OPG s implementation of these standards at the Darlington NGS as part of the compliance program Conclusion Based on CNSC staff assessments of OPG s licence application, supporting documents and past performance, CNSC staff conclude that OPG continues to implement and maintain an effective design program at the Darlington NGS in accordance with regulatory requirements. Licence conditions 5.1, 5.2 and 5.3 in the proposed license pertain to the physical design SCA. 4.6 Fitness for Service The fitness for service SCA covers activities that impact on the physical condition of Structures, Systems and Components (SSCs) to ensure that they remain effective over time. This includes programs that ensure all equipment and components are available to perform their intended design functions when called upon to do so. This CMD covers the following specific areas of fitness for service: Maintenance; Reliability; Aging Management; Periodic Inspection and Testing; and Chemistry Control Trends OPG continues to maintain adequate programs to ensure the fitness for service for the major SSCs important to safety, and other safety-related SSCs. The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: FITNESS FOR SERVICE Annual Safety Performance Ratings SA SA FS FS FS SA SA Comment OPG s performance in the fitness for service SCA continues to be satisfactory FS = fully satisfactory, SA = satisfactory e-doc (Word) July 2015 e-doc (PDF)

60 15-H8 Unprotected Discussion The Darlington NGS PROL requires OPG to implement and maintain fitness for service programs in accordance with CNSC regulatory documents and CSA standards as set out in the LCH. CNSC have assessed that OPG has well established fitness for service programs that meet regulatory requirements and expectations. The following sections provide a detailed discussion for the specific areas of fitness for service identified above. Maintenance OPG has a maintenance program at the Darlington NGS that meets CNSC requirements and expectations as set out in RD/GD-210 Maintenance Program for Nuclear Power Plants. RD/GD-210 superseded S-210 in December OPG s preventive maintenance completion ratio at the Darlington NGS is consistently above industry average. This indicates that Darlington s preventive maintenance program is effective in controlling the number of corrective maintenance activities and to maintain SSC performance. The small corrective maintenance backlog at the Darlington NGS is in the top quartile of the industry. CNSC staff completed a number of maintenance-related inspections [54, 55] and confirmed satisfactory performance. OPG continues to meet regulatory requirements for maintenance at the Darlington NGS and CNSC staff will continue to monitor this area as part of the compliance program. Reliability OPG has developed and implemented a reliability program which confirms that systems important to safety meet their defined design and performance specifications at an acceptable level of reliability. OPG s reliability program at the Darlington NGS continues to meet the requirements of RD/GD-98 Reliability Programs for Nuclear Power Plants. OPG is required to report annually to the CNSC the results of their reliability program in accordance with REGDOC (formerly S-99). This includes the reliability of the multiple special safety systems that provide protection against rare but possible process system failures and thus ensure safety. No reactor is allowed to operate without the availability of the special safety systems. These special safety systems include two shutdown systems which are independent of each other. The first system uses shutoff rods, which drop into the reactor core by gravity, with an initial spring assist. The second system uses the injection of a neutron absorbing solution into the moderator. At no time are the shutdown systems allowed to be ineffective; in some rare circumstances, their capability might be reduced but coverage is always assured by the other redundant system and immediate actions are always taken by the operating crew to restore the capability. At least one shutdown system will operate, if required, following any process system failure. In addition to the special safety systems, the CANDU design provides other safety-related systems and features to solely perform safety functions. No reactor is allowed to operate without the availability of the special e-doc (Word) July 2015 e-doc (PDF)

61 15-H8 Unprotected safety systems. If unavailability is detected, immediate actions are taken to ensure safety is maintained at all times. Special safety system performance for NPPs are reported to the Commission through the annual CNSC staff Regulatory Oversight Report for Canadian Nuclear Power Plants. OPG s reliability program continues to meet regulatory requirements and CNSC staff will continue to oversee this area as part of the compliance program. Aging Management OPG continues to implement and maintain an integrated aging management program at the Darlington NGS to ensure that the condition of SSCs important to safety is understood and that required activities are in place to assure fitness for service of these SSCs as the plant continues to age. CNSC staff have concluded that OPG has a well-established integrated aging management program that is aligned with CNSC Regulatory Document RD-334, Aging Management for Nuclear Power Plants [56]. In March 2014, the CNSC published REGDOC-2.6.3, Aging Management [57] which replaces RD-334. OPG has committed to implement REGDOC by July Further details of OPG s aging management programs are described below. OPG has established component specific aging management programs for the long term management of major pressure boundary components (fuel channels, feeders and steam generators), reactor components and structures. The programs for fuel channels, feeders and steam generators are commonly referred to as life cycle management plans (LCMPs). OPG also has in place aging management plans for the concrete containment structures and balance of plant safety-related civil structures. The programs are updated on a regular basis to incorporate new operating experience and operational and safety goals. CNSC staff have reviewed these plans and confirmed they meet regulatory requirements established in RD The following is a brief discussion of the LCMPs and aging management programs that OPG has in place for the major components and the containment structures. Pressure Tubes The fitness for service of pressure tubes is evaluated through conservative engineering assessments based on an understanding of degradation mechanisms and adequate inspection and maintenance programs to periodically validate the engineering assessments. Two of the age related degradation mechanisms regarding pressure tubes are fracture toughness and annulus spacers as further described below. Fracture Toughness Based on in-service inspection data and tests conducted on removed tubes from operating reactors, it is known that pressure tubes experience changes in dimensions and material properties through irradiation and micro-structural changes. In particular, a reduction in fracture toughness caused by an increase in e-doc (Word) July 2015 e-doc (PDF)

62 15-H8 Unprotected hydrogen concentration has been identified as one of the most significant degradation mechanisms. As a result, the capability of demonstrating leak-beforebreak (LBB) and fracture protection of the pressure tubes is updated in light of this degradation mechanism. LBB ensures that, if a crack develops in a pressure tube, the consequential leak can be detected in time to shut down the reactor and cool and depressurize the primary heat transport system before the crack becomes unstable and the pressure tube ruptures. Fracture protection evaluations establish the pressure and temperature limits for preventing the fracture of tubes, while the primary heat transport system pressure is being increased to or decreased from the normal operating pressure and temperature during reactor start-up and shutdown. To address the issues related to fracture toughness beyond 210,000 equivalent full power hours (EFPH), OPG, jointly with Bruce Power, conducted a Fuel Channel Life Management Project (FCLMP) to improve the understanding of material behaviour of the pressure tubes and to develop more refined engineering methodologies. CNSC staff conducted extensive reviews and has accepted the newly developed fracture toughness models and probabilistic LBB methodologies. The licensees will be conducting additional research and development activities to further validate the fracture toughness models and refine the engineering methods. CNSC staff are satisfied with OPG s progress and are tracking this on-going work through the CNSC normal compliance program [58]. Annulus Spacers Each fuel channel at the Darlington NGS is equipped with four tight fitting Inconel X-750 annulus spacers to transfer loads and maintain an insulating gap between the pressure tubes (PTs) and calandria tubes (CTs). The long term integrity of X-750 annulus spacers could be affected by neutron irradiation, imposed loads, and rolling wear during reactor startup and shutdown. Spacer integrity is a potential concern because it can lead to PT-CT contact. In the presence of sufficiently high deuterium concentrations in the PT, PT-CT contact could lead to hydride blister formation. To address this issue, OPG has established a long term life management plan for Inconel X-750 annulus spacers to monitor and manage the integrity and mobility of the spacers. The objective of the long term spacer program is to improve the understanding of material and structural behavior of spacers in future operating conditions by conducting tests on spacers removed from reactors. CNSC staff will continue to monitor OPG s activities on spacer integrity to ensure that spacer degradation will not challenge the fitness for service of PTs at the Darlington NGS. Operation Beyond 210,000 EFPH The Darlington NGS LCH specifies that, for operation beyond 210,000 EFPH, OPG shall provide evidence to demonstrate that the predicted condition of PTs continues to be sufficient to support safe operation. Operation of any unit beyond 210,000 EFPH is not permitted unless approved by the Commission. e-doc (Word) July 2015 e-doc (PDF)

63 15-H8 Unprotected Of all the aging and degradation mechanisms affecting the pressure tubes, hydrogen uptake and its reduction of fracture toughness is considered the dominant contributor to risk of pressure tube failure. Fracture toughness issues are only of concern during a very limited period of reactor operation; specifically, the transitions between shut down state to full power state and vice versa (heat up and cool down phases). When the reactors are at power (normal operation) or shut down, the effects of the aging mechanisms are considered negligible. The pressure tube service life for the Darlington NGS is planned for 235,000 EFPH to demonstrate margin on the projected EFPH values at scheduled refurbishment outages. The table below provides the most recent EFPH projections for the Darlington units at their planned refurbishment outages. Darlington Unit Approximate EFPH at planned refurbishment outage Unit 1 222,000 Unit 2 188,000 Unit 3 208,000 Unit 4 227,000 CNSC staff have verified that OPG has established programs in place to monitor the fitness for service of PTs and spacers to support the continued safe operation for the pre-refurbishment service life of the Darlington NGS to 235,000 EFPH. Operating beyond 235,000 EFPH is not a cliff-edge effect but is an indicator of when further assessment will be necessary. Given OPG plans to refurbish the Darlington NGS before 235,000 EPFH, further assessment to demonstrate operating beyond this point is not required. In the meantime, PTs are continually monitored and continued fitness for service must be demonstrated. CNSC staff will continue to follow up on OPG s activities related to maintaining the fitness for service of the pressure tubes at the Darlington NGS. As part of the continued improvement of the engineering models, OPG has committed to continuing research and development on PT aging effects. The purpose of the program is not to validate the current results, but rather to better understand and quantify uncertainties in the models and current restrictions on the reactor operating conditions where the models are applicable. Much of the research is focused on enhancing understanding of the physical basis for the linkage between hydride formation and its effect on fracture toughness. Feeders To ensure the continued validation of fitness for service assessment of feeders, OPG established a Life Cycle Management Plan (LCMP) for feeders where inservice inspection and maintenance programs are specified in a detailed manner. The fitness for service of feeders at Darlington is verified through periodic inspection program (PIP) in accordance with CSA N CNSC staff conducted technical reviews of OPG submissions, including inspection reports and the disposition of findings, and confirmed that structural integrity of feeders has been maintained with sufficient safety margins. e-doc (Word) July 2015 e-doc (PDF)

64 15-H8 Unprotected OPG has the capability to replace any feeder when it is found not to meet the fitness for service requirements. All feeders will be replaced during each unit s refurbishment outage. Steam Generators The LCMP for the steam generators has been established to ensure that the Darlington NGS steam generators continue to operate reliably. The steam generators are inspected and maintained on a three year outage cycle to address degradation before it has an impact on safe operation. Inspections include eddy current and ultrasonic inspection of the steam generator tubes, inspection of specific components such as the divider plates, and the routine in-service and periodic inspection applied to pressure boundary related equipment. Steam generator maintenance includes routine water lancing (tube sheet in particular), and chemical cleaning when needed. The materials used in the steam generator construction combined with operating practices have not resulted in degradation that would limit the operating life of the steam generators to less than proposed life extension of the Darlington units. Therefore the steam generators will not be replaced during refurbishment. The provisions established in the LCMP are expected to ensure that the condition of the steam generators is monitored and properly maintained for the extended plant life. Concrete Containment Structures OPG has established an aging management plan for the concrete containment structures to ensure that fitness for service of these structures is maintained. The aging management plan for concrete containment structures evaluates and describes the aging mitigation activities to ensure they provide protection against the degradation mechanisms of the concrete containment structures. Periodic inspection and testing of the concrete containment structures are conducted in accordance with the requirements of CSA N287.7 In-service examination and testing requirements for concrete containment structures in CANDU nuclear power plants and the approved station periodic inspection programs. During the current licence period, CNSC staff did not identify any compliance issues affecting safety in this area. CNSC staff continue to monitor this area as part of the compliance program. Concrete Integrity Alkaline-Aggregate Reaction During the public hearing for the CEAA EA for Darlington refurbishment and continued operations, some intervenors expressed concerns regarding the possible degradation of concrete in the reactor structures at the Darlington NGS due to the alkaline aggregate reaction (AAR) which was observed at Hydro-Quebec s Gentilly-II NGS. To address this concern, OPG has submitted to CNSC staff an evaluation of the integrity of the concrete structures at the Darlington NGS [59] and CNSC staff took an action to update the Commission on this issue as part of this relicensing process. e-doc (Word) July 2015 e-doc (PDF)

65 15-H8 Unprotected AAR involves the formation of an alkali-silica gel which is caused by a chemical reaction between the alkalis contained in the cement paste and certain forms of silica within the aggregates. The expansive alkali-silica gels cause visible mappattern cracking on the concrete surface with dark discoloration of the cement paste surrounding the cracks which can be detected by visual inspection. The existing PIPs for concrete containment structures at the Darlington NGS can detect AAR. OPG performs non-destructive examination (NDE) such as visual inspection, impact hammer test for concrete as the first level of NDE for concrete inspection. Based on the results from the inspections, no signs of AAR have been identified and reported by OPG in the concrete containment structures at the Darlington NGS. As part of the IIP [20], OPG has committed to review historical records and to investigate the specific AAR prevention measures that were taken in the selection of aggregates during the construction of the Darlington NGS. This action will provide further confirmation that AAR degradation is not expected to occur at the Darlington NGS in the future. Concrete Inspection Results OPG conducts visual inspections of the concrete containment structures at the Darlington NGS on a periodic basis. The current inspection cycles for the main containment structures and the vacuum building are six years and twelve years, respectively. The table below shows the year of the last inspection for the concrete containment structures. Darlington NGS Concrete Containment Structures Year of Last Inspection Last Inspected Unit 1 Unit 2 Unit 3 Unit 4 Vacuum Building Some minor degradation such as fine cracks, localized spalling and other construction anomalies were reported by OPG. In some cases, repairs and or replacements are carried out or additional evaluations are provided and submitted by OPG to CNSC staff for acceptance. The inspection results obtained to date indicate that the concrete containment structures at the Darlington NGS are in good condition and the degradations observed do not affect the structures to perform their design function. Leakage Rate Tests OPG conducts leakage rate tests of the concrete containment structures at the Darlington NGS in accordance with the requirements of CSA N In addition, OPG conducts regularly on-power safety related system tests at a reduced pressure for the concrete containment structures. Based on the results from the leakage rate tests and the on-power tests to date, the concrete containment structures at Darlington NGS have demonstrated good performance and their e-doc (Word) July 2015 e-doc (PDF)

66 15-H8 Unprotected leakage rate remain below the operational leakage rate targets and the safety analysis limit. Conclusion on Concrete Integrity The concrete containment structures at the Darlington NGS are in good condition; the extensive inspections and testing that were completed have not identified any significant degradation, and the concrete containment structures are expected to perform their design function when called upon. OPG continues to perform the required periodic inspection and testing activities for the concrete containment structures in accordance with the requirements of the CSA N287.7 and approved station PIPs. CNSC staff are satisfied that OPG has adequate measures in place to monitor and manage the aging of the concrete containment structures at Darlington NGS. Periodic Inspection and Testing OPG is required to implement periodic inspection programs (PIPs), in accordance with the applicable CSA standards, to monitor the continued fitness for service of pressure boundary components, containment structures and their components. The on-going assurance of fitness for service of these SSCs is verified, in part, through PIP activities. CNSC staff reviewed and accepted OPG s periodic inspection programs (PIPs) at the Darlington NGS for the major pressure boundary components, containment structures and their components and confirmed that those programs are in compliance with the requirements of CSA N285.4 Periodic inspection of CANDU nuclear power plant components, CSA N285.5 Periodic inspection of CANDU nuclear power plant containment components, and CSA N287.7 In-service examination and testing requirements for concrete containment structures in CANDU nuclear power plants. OPG s implementation of PIPs at the Darlington NGS is subject to on-going verification by CNSC staff. Compliance verification activities carried out by CNSC staff include the review and acceptance of the governing PIP documents, fitness-for-service guidelines, inspection reports and dispositions of inspection findings, as necessary. In addition, CNSC staff conduct inspections on a periodic basis. OPG continues to satisfy regulatory requirements and expectations during the execution of the PIPs. Periodic inspection and leakage rate testing for the concrete containment structures are performed in accordance with the CSA N287.7 and OPG has demonstrated that the concrete containment structures continue to meet the design functions. OPG will be performing the next positive pressure leakage rate tests of the vacuum building and the main containment structure at the Darlington NGS in the fall of Balance of Plant OPG is required to implement inspection programs to verify the condition of balance of plant (BOP) pressure boundary systems (those outside of the scope of CSA N285.4) and civil structures (those outside the scope of CSA N287.7) that can impact safe operation. OPG has developed PIP documents for the BOP e-doc (Word) July 2015 e-doc (PDF)

67 15-H8 Unprotected safety-related civil structures in accordance with CSA N291 Requirements for safety-related structures for CANDU nuclear power plants. CNSC staff monitor OPG s activities through reviews of REGDOC (formerly S-99) reports and the conduct of inspections. OPG meets current regulatory expectations concerning the implementation of BOP pressure boundary components and civil structures inspection programs. OPG has been an active participant in the development of a CSA standard to establish consistent, industry wide practices for the BOP pressure boundary inspection program. OPG has also been involved with the revision of the CSA N291 to incorporate the latest knowledge and operation experience for the inspection of BOP civil structures. Chemistry Control OPG has a well-developed chemistry program at the Darlington NGS that meets CNSC requirements and expectations. In 2014, a CNSC staff inspection of OPG s chemistry control program at the Darlington NGS confirmed satisfactory implementation [60]. Fitness for Service for Refurbishment OPG will be replacing the pressure tubes, annulus spacers, calandria tubes, end fittings and feeders across all Darlington units as part of the refurbishment project and will be resetting aging management plans accordingly. OPG has prepared guidance documents to assist in establishing baseline performance data for new or modified equipment for use in aging management programs. OPG has also developed equipment lay-up specifications to govern surveillance and testing of equipment and systems that are put into a shutdown or lay-up state during refurbishment. OPG will continue to perform PIPs in accordance with existing PIP plans and schedules during refurbishment. CNSC staff continue to provide regulatory oversight in this area as part of the CNSC compliance program Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance OPG continues to demonstrate satisfactory performance in the fitness for service SCA at the Darlington NGS. OPG has periodic inspection programs in place to provide on-going assurance of the fitness for service of major components and concrete containment structures. Regulatory Focus for the Next Licence Period CNSC staff will continue to verify OPG s programs required to maintain the fitness for service of safety significant SSCs through desktop reviews of OPG s program documentation, OPG inspection reports and CNSC inspection activities. Specifically in regards to operation beyond 210,000 EFPH, CNSC staff will continue to verify OPG s activities to improve the probabilistic methodology used e-doc (Word) July 2015 e-doc (PDF)

68 15-H8 Unprotected to demonstrate LBB of PTs and OPG s approach to the inspection of spacers and the assessment of spacer integrity for the pre-refurbishment service life. Proposed Improvements OPG will be replacing the pressure tubes, annulus spacers, calandria tubes, end fittings and feeders across all Darlington units as part of the refurbishment project. In addition, OPG has committed to implement REGDOC-2.6.3, Aging Management which replaces RD-334 by July OPG will also be updating the CSA N285.4 periodic inspection program for pressure boundary systems and components to the 2014 edition of the standard with a target implementation date of July These timelines are acceptable to CNSC staff Conclusion Based on the information assessed, CNSC staff conclude that the implementation of the fitness for service SCA at the Darlington NGS continues to meet regulatory requirements. With respect to OPG s plans to operate beyond 210,000 EFPH at the Darlington NGS, CNSC staff have verified that OPG has developed appropriate engineering methodologies and inspection/maintenance programs to demonstrate pressure tube fitness for service beyond 210,000 EFPH up to the planned prerefurbishment service life of 235,000 EFPH. The scientific principles applied by OPG to pressure tube life management at Darlington are similar to those applied for Pickering and Bruce Power. OPG continues to adhere to the requirements of CSA N CNSC staff will continue to conduct regulatory oversight to ensure the continued safe operation of the power reactors and will update the Commission on fitness for service monitoring parameters for major components of units operating beyond 210,000 EFPH via the annual CNSC Staff Regulatory Oversight Report for Canadian Nuclear Power Plants. CNSC staff recommend that the Commission authorize OPG to operate the Darlington units beyond 210,000 EFPH, up to the proposed refurbishment outages to a maximum of 235,000 EFPH. OPG continues to implement and maintain effective programs to ensure fitness for service at the Darlington NGS in accordance with CNSC requirements. Licence condition 6.1 in the proposed licence pertains to implementing and maintaining programs to ensure fitness for service of SSCs. 4.7 Radiation Protection The radiation protection SCA covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations. This program must ensure that contamination levels and radiation doses received by individuals are monitored, controlled, and maintained as low as reasonably achievable (ALARA). e-doc (Word) July 2015 e-doc (PDF)

69 15-H8 Unprotected This CMD covers the following specific areas of radiation protection: Application of ALARA; Worker Dose Control; Radiation Protection Program Performance; Radiological Hazard Control; and Estimated Dose to Public Trends The following table indicates the annual safety performance ratings for this SCA from 2008 to The performance in this SCA has been steady with Darlington NGS receiving a rating of fully satisfactory since RADIATION PROTECTION Annual Safety Performance Ratings FS SA FS FS FS FS FS Comment OPG s performance in the radiation protection SCA continues to be fully satisfactory FS = fully satisfactory, SA = satisfactory Discussion The Radiation Protection Regulations require licensees to establish a radiation protection program to keep exposures ALARA, taking economic and social factors into account, through the implementation of a number of control programs, including: management control over work practices; personnel qualification and training; control of occupational and public exposures to radiation; and planning for unusual situations. During the 2012 licence renewal, CNSC staff reported that OPG had a highly effective radiation protection program at Darlington NGS that protected the health and safety of persons inside the facility and that ensured occupational exposures were below regulatory dose limits and were maintained ALARA. This conclusion was substantiated by various regulatory compliance verification activities conducted by CNSC staff over the licence period. During the current licence period, OPG has continued to implement the same radiation protection program that they developed in past years. e-doc (Word) July 2015 e-doc (PDF)

70 15-H8 Unprotected Application of ALARA OPG has a documented ALARA program that identifies the strategies in place at Darlington NGS to control dose and minimize exposures ALARA. This program integrates ALARA into planning, scheduling and work control, and employs current industry best practices and operating experience. The Darlington NGS has an active ALARA committee that operates as a steering group for the station s ALARA processes. This group meets at least quarterly to, among other responsibilities, establish ALARA priorities, review and approve the station s annual collective effective dose targets, review and approve a 5-Year ALARA plan, and review the station s ongoing ALARA performance. Darlington NGS 5-year ALARA plan includes current and long-range dose reduction initiatives. Additionally, weekly and monthly monitoring and tracking is performed of various ALARA performance metrics, including among others: station collective radiation exposure, collective internal radiation exposure, personal contamination events, unplanned exposures, unposted hazards and radiation protection-related unscheduled reports to the CNSC. Individual ALARA plans are also developed for all planned outage activities, which include dose reduction plans and rationalization for all dose targets assigned to the outages. Figures 3 and 4 in Addendum D.1 of this CMD illustrate the distribution of annual collective effective dose per operational state (routine versus outages) and the distribution of dose by internal and external doses. Annual collective effective dose is used as a tool for optimization of radiation protection in the control of occupational exposure and takes account of all individuals at the nuclear facility (staff, contractors and visitors). Annual collective effective dose is the sum of all doses to all individuals at the facility over the period of one year. The variations in annual collective effective dose from year to year are due primarily to the number and scope of maintenance outages. CNSC staff conducted an inspection of occupational ALARA planning and control at Darlington NGS in 2014 [61]. Overall, the inspection found that Darlington NGS was compliant with regulatory requirements to ensure exposures are maintained ALARA at all times. CNSC staff did identify a minor issue of low safety significance with the documentation of the ALARA program, but this has since been corrected by OPG. Worker dose control The radiation protection program at the Darlington NGS ensures that there are requirements in place to control doses received by workers so as not to exceed regulatory limits. OPG operates a CNSC licensed dosimetry service to monitor, assess, record and report doses of ionizing radiation received by employees, visitors and contractors as a result of activities at the Darlington NGS. Doses for individuals are reported to the National Dose Registry as normal practice. The available types of dosimetry, the criteria for use and procedures for use are implemented through the radiation protection program. The implementation of the radiation protection e-doc (Word) July 2015 e-doc (PDF)

71 15-H8 Unprotected program in the area of personnel dosimetry meets CNSC regulatory requirements and is found to be satisfactory. During the period from 2008 to 2014, there were no radiation exposures reported at the Darlington NGS that exceeded the annual regulatory dose limit for a nuclear energy worker (50 msv). The figures in Addendum D.1 of this CMD illustrate the dose distribution for nuclear energy workers (NEWs) for the years The average and maximum doses illustrated in Figure 2, along with the effective dose distribution data depicted in Figure 1 demonstrate that Darlington NGS is maintaining control over worker exposures; an average of 88% of monitored workers received less than 1 msv per year during the reported period, which is 2% of the regulatory limit. According to the Radiation Protection Regulations, action levels are a specific dose of radiation or other parameter that, if reached, may indicate a loss of control of part of a licensee s radiation protection program and trigger a requirement for specific action to be taken. In 2013, OPG reported that a worker at Darlington NGS Unit 2 received an unplanned tritium dose of approximately 2.1 msv, slightly (5%) above the 2 msv action level. CNSC staff are satisfied that OPG adequately investigated and implemented corrective actions to prevent reoccurrence and that there was no loss of control of the radiation protection program. In 2013, CNSC staff conducted an inspection [62] that focused on worker dose control at Darlington NGS. The inspection determined that Darlington NGS was compliant with the regulatory requirements to measure and record doses received by workers. Several areas for improvement of low safety significance were identified, all of which OPG has addressed to the satisfaction of CNSC staff. Radiation protection program performance OPG applies its corporate radiation protection program at the Darlington NGS site. This program satisfies the requirements of the Radiation Protection Regulations and includes a number of performance indicators to monitor radiation protection program performance. The radiation protection program and its supporting procedures are maintained current in consideration of operating experience and industry best practices. In 2013 and 2014, CNSC staff verified the effectiveness of OPG s implementation of its radiation protection program at Darlington NGS through validation against OPG s objectives, goals, targets, and continuous improvement initiatives. There were no negative findings in this area. Positive findings were noted in the setting and monitoring of exposures. CNSC staff consider that the radiation protection program documents and the oversight applied in implementing and continuously improving this program have been effective in protecting workers. e-doc (Word) July 2015 e-doc (PDF)

72 15-H8 Unprotected Radiation protection program performance is discussed on an on-going basis with Darlington NGS staff during CNSC-Darlington NGS radiation protection quarterly update meetings. Year-to-date and current monthly performance are shared by OPG and any areas of concern are discussed. CNSC staff are satisfied that OPG s implementation of its radiation protection program at Darlington NGS meets all applicable regulatory requirements and doses to workers and members of the public are below regulatory dose limits. Radiological hazard control OPG s radiation protection program ensures that there are adequate measures in place to monitor and control radiological hazards. This includes, but is not limited to: contamination control, radiation dose rate control and airborne radiation monitoring and control. Contamination control at Darlington NGS ensures that contamination is prevented from leaving radiological controlled areas, and that the spread of contamination within these areas is minimized. This is achieved by establishing radiological zones with prescribed contamination levels, routine contamination monitoring, classifying areas according to their radiation hazard potential, ensuring each radiological area is posted, restricting access to authorized personnel, and monitoring personnel and material prior to leaving contaminated or potentially contaminated areas. Loose contamination is not tolerated within the station with the exception of identified contamination control areas. At the last licence renewal, CNSC staff reported that long-term corrective action plans in place at the Darlington NGS to resolve two low safety significant items regarding radiological hazard control remained open. CNSC staff are satisfied that OPG has since completed these corrective actions and the original findings are now closed. During compliance inspections conducted in the current licence period [63, 64], CNSC staff identified additional areas for improvement of negligible safety significance in radiological hazard control. CNSC staff are satisfied that all of the findings have been resolved. CNSC staff are satisfied that OPG has adequate measures to control the radiological hazards at Darlington NGS. There were no contamination action level exceedances reported to the CNSC during the current licence period. Estimated Dose to Public OPG implements a radiation protection program to prevent uncontrolled release of contaminants or radioactive materials from the site. e-doc (Word) July 2015 e-doc (PDF)

73 15-H8 Unprotected The following table presents annual effective doses to a member of the public from licensed activities conducted at the Darlington NGS from 2008 to 2014: MAXIMUM EFFECTIVE DOSE TO A MEMBER OF THE PUBLIC Dose Statistic Regulatory Limit Maximum Effective Dose (μsv) μsv/y (Natural Background 2300 μsv/y) The Environmental Assessment Information Report (EAIR) in Addendum E of this CMD details the methodology used by OPG to calculate the maximum effective dose to a member of the public, and provides further analysis from CNSC staff. The dose to the public resulting from operations at the Darlington NGS continues to be well below the annual allowable dose limit of 1000 μsv/y. Radiation Protection for Refurbishment OPG s licence renewal application has confirmed that the refurbishment of the Darlington NGS will be performed in compliance with its corporate radiation protection program. This includes a commitment for all workers, including OPG employees and contractors, to follow OPG s radiation protection procedures. Further, OPG has confirmed that they will retain accountability for radiation protection training of all workers, again both OPG employees and contractors. OPG s radiation protection program is well-defined and aims to control occupational and public exposure to levels that are ALARA and to prevent uncontrolled release of contamination or radioactive materials. Included in the program are measures for identifying and controlling radiological hazards (contamination limits, zoning, monitoring, posting, decontaminating), measures for protecting workers (training, work planning, provision of protection equipment, oversight) and measures for identifying and controlling worker doses (dose limits, monitoring, work planning, dosimetry, access control). OPG has recognized it will encounter unique radiological hazards with respect to the Darlington NGS refurbishment activities, and has identified the need to take additional measures to adequately address these concerns. OPG has developed radiation protection strategies for refurbishment, including among many others, the removal of major radiological source terms like the fuel and water in the primary heat transport and moderator systems, the subsequent reduction in the size of radiological and contamination control areas associated with these major systems, the implementation of temporary shielding to reduce the remaining radiological hazards, the erection of contamination control areas and zone boundaries as close as possible to contaminated areas in order to keep contamination at its source, and the development of nuclear refurbishment specific radiological work plans and work permits for the work to be performed on these systems and in these areas. e-doc (Word) July 2015 e-doc (PDF)

74 15-H8 Unprotected In addition, OPG has confirmed that the refurbishment activities will comply with OPG s radiation protection action levels and administrative dose limits currently defined for Darlington NGS. Based on the above commitments, CNSC staff are satisfied that implementation of the radiation protection program at the Darlington NGS during refurbishment activities will ensure adequate provision for the protection of persons from radiation at Darlington NGS and that Darlington NGS performance will meet regulatory requirements Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance OPG s past performance at the Darlington NGS has been steady under the RP SCA, with Darlington NGS receiving a fully satisfactory rating in six of the last seven years. Regulatory Focus for the Next Licence Period CNSC staff will continue to monitor OPG s compliance with the ALARA principles, applicable regulatory requirements and standards pertaining to radiation protection. Regulatory oversight will continue to be accomplished through completion of compliance verification activities. As learned from past refurbishment activities with other licensees, CNSC staff will augment these baseline activities with enhanced scrutiny of the radiation protection training and performance of contractor staff as well as oversight of refurbishment work. Proposed Improvements There are currently no foreseen changes to OPG s radiation protection program or to any of the specific areas listed under it as they relate to the operating units at Darlington NGS. However, as indicated by OPG in its licence renewal application, changes to the station due to refurbishment activities will result in new radiation protection strategies. Similarly, OPG has identified that adjustments may need to be made to ensure ample resources are available to adequately implement the radiation protection program for the refurbishment activities. It is expected that any changes will enable OPG to eliminate, shield and control radiation hazards to reduce collective dose, to achieve dose minimization, and to ensure adequate contamination control. CNSC staff will monitor any such changes to ensure improvements that have been made include adequate provision for the protection of persons from radiation at Darlington NGS Conclusion Based on CNSC staff s assessments of OPG s licence application, supporting documents and past performance, CNSC staff conclude that OPG has met or exceeded performance objectives and all applicable regulatory requirements e-doc (Word) July 2015 e-doc (PDF)

75 15-H8 Unprotected related to this SCA, and that OPG will continue to make adequate provision for the protection of persons from radiation at Darlington NGS. Licence condition 7.1 in the proposed licence pertains to implementing a radiation protection program. 4.8 Conventional Health and Safety The conventional health and safety SCA covers the implementation of a program to manage workplace safety hazards and to protect personnel and equipment. This CMD covers the following specific areas of conventional health and safety: Performance; Practice; and Awareness Trends OPG continues to maintain a conventional health and safety program in accordance with regulatory requirements. The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: CONVENTIONAL HEALTH AND SAFETY Annual Safety Performance Ratings FS FS FS FS FS FS SA Comment OPG s performance in the conventional health and safety SCA continues to be satisfactory FS = fully satisfactory, SA = satisfactory Discussion The Darlington NGS PROL requires OPG to implement and maintain a conventional health and safety program. CNSC staff have assessed that OPG has a highly effective health and safety program that provides safe work practices and conditions to achieve a high level of personnel safety at the Darlington NGS. OPG s conventional health and safety program is regulated by the Occupational Health and Safety Act (OHSA) of Ontario and the Labour Relations Act of Ontario. Performance OPG monitors several performance indicators such as accident severity frequency and accident severity rate to ensure that the objectives of the conventional health and safety program are met. Accident frequency is a measure of the sum of the number of lost-time injuries, medically treated injuries and fatalities per 200,000 person-hours worked at the station. e-doc (Word) July 2015 e-doc (PDF)

76 15-H8 Unprotected Accident severity rate is a measure of the total number of days lost due to injury for every 200,000 person-hours worked at the station. The table below shows the accident frequency and accident severity rate reported by OPG for the Darlington NGS from 2008 to Accident Frequency and Severity Rates - Darlington Year Accident Accident Frequency Severity Rate The results of these performance indicators are extremely low in comparison with other workplaces in Ontario and the electrical sector in general. Performance indicators for the conventional health and safety SCA are reported annually to the Commission as part of the CNSC Staff Regulatory Oversight Report for Canadian Nuclear Power Plants. Overall, CNSC staff are satisfied with OPG s performance in this area. Practice CNSC staff did not identify any major issues with OPG s compliance against the OHSA or the Labour Relations Act (Ontario). OPG s conventional health and safety program covers all of the major activities on site under the OHSA. Minor issues, such as housekeeping, are identified and promptly corrected by OPG. CNSC staff continue to monitor these activities as part of the compliance program. Since 2011, the CNSC has a Memorandum of Understanding with the Ontario Ministry of Labour (MOL) to cooperate and exchange information and technical expertise related to their respective areas of jurisdiction, such as occupational health and safety practices at nuclear facilities. There has been regular communication between CNSC staff and the MOL regional office regarding any issues at site. Awareness The conventional health and safety work practices and conditions at the Darlington NGS continued to achieve a high degree of personnel safety. There continues to be a safe and efficient working environment where situational awareness and safe work practices are encouraged. In 2014, the Annual Safety Performance rating for this SCA dropped to satisfactory. This decrease in rating was not due to a physical decline in safety performance or awareness, but due to continued citations of OPG not meeting its own internal governance in the area of scaffolding inspections and record keeping e-doc (Word) July 2015 e-doc (PDF)

77 15-H8 Unprotected [65]. OPG s corrective action plan to address this issue is being implemented to the satisfaction of CNSC staff and all actions will be complete by August Conventional Health and Safety for Refurbishment Refurbishment activities will be performed in accordance with the OHSA of Ontario. OPG has engaged contractors with proven records in the areas of health and safety programs and will be approving contractors health and safety submissions prior to work being performed. With respect to the accountabilities and responsibilities under OSHA, OPG will assume the role and responsibilities of constructor and refurbishment contractors will assume the role and responsibilities of employer. Refurbishment contractors will be working under the employer programs and procedures which allow supervisors and workers to work within the programs and procedures they are trained and experienced in. OPG will be providing oversight of the refurbishment contractor s occupational health and safety performance throughout the duration of the refurbishment project Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance CNSC staff have assessed that OPG continues to demonstrate satisfactory performance in the conventional health and safety SCA at the Darlington NGS. Regulatory Focus for the Next Licence Period CNSC staff will continue to focus on verifying compliance with the applicable documents and standards such as the OHSA. Proposed Improvements CNSC staff will continue to work with the MOL under the signed MOU to provide improved regulatory oversight in this area Conclusion Based on CNSC staff assessments of OPG s licence application, supporting documents and past performance, OPG s implementation of the conventional health and safety SCA has met and continues to meet applicable regulatory requirements. Licence condition 8.1 in the proposed licence pertains to implementing and maintaining a conventional health and safety program. e-doc (Word) July 2015 e-doc (PDF)

78 15-H8 Unprotected 4.9 Environmental Protection The environmental protection SCA covers programs that identify, control and monitor all releases of radioactive and hazardous substances and effects on the environment from facilities or as the result of licensed activities. This CMD covers the following specific areas of environmental protection: Effluent and Emissions Control (Releases); Environmental Management System (EMS); Assessment and Monitoring; Protection of the Public; and Environmental Risk Assessment Trends The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: ENVIRONMENTAL PROTECTION Annual Safety Performance Ratings SA SA SA SA SA SA SA Comment OPG s performance in the environmental protection SCA continues to be satisfactory SA = satisfactory Discussion OPG continues to implement and maintain a satisfactory environmental protection program that meets CNSC requirements. OPG engages in continuous improvement taking into consideration the results of monitoring activities, environmental risk assessments, standards and regulatory documents to ensure that all environmental protection programs meet their design objectives for the protection of the environment and the health of persons. Further information on CNSC staff s assessments is presented in the following subsections and the Environmental Assessment (EA) Information Report attached as Addendum E of this CMD. Effluent and Emissions Control (Releases) OPG continues to implement and maintain an effluent monitoring program at the Darlington NGS as required by the Class I Nuclear Facilities Regulations. OPG s effluent and emissions monitoring program defines the methods and procedures for controlling and monitoring radioactive and hazardous substances, identifies e-doc (Word) July 2015 e-doc (PDF)

79 15-H8 Unprotected and monitors discharge pathways for releases to the environment, and maintains releases below regulatory limits and action levels. CNSC staff conducted an inspection of this program [66] and concluded that the control, monitoring and reporting of releases at the Darlington NGS are welldeveloped and are in compliance with regulatory requirements. CNSC staff identified certain areas for improvement that have been adequately addressed by OPG. OPG has committed to implement CSA N Effluent Monitoring Programs at Class I Nuclear Facilities and Uranium Mines and Mills by December This timeline is acceptable to CNSC staff. Radiological Releases Radiological releases from the Darlington site operations are detailed in the Environmental Assessment Information Report (attached as addendum E) and continue to be well below 1% of the derived release limits (DRLs) for both air and water. Environmental Management System OPG has established and implemented an Environmental Management System (EMS) in accordance with CNSC REGDOC-2.9.1, Environmental Protection Policies, Programs and Procedures (formerly S-296 and G-296), and is registered to CSA ISO 14001: 2004 Standard, Environmental Management Systems Requirements with Guidance for Use. While registration / certification to this standard is not required by the CNSC, it is one measure of verification with CNSC requirements and expectations in that the certification indicates recognition of the OPG s EMS by a third party. OPG s EMS and its supporting governing documents establish the provision of the protection of the environment at the Darlington NGS and continual improvement of environmental performance as required by CNSC REGDOC Assessment and Monitoring OPG s environmental monitoring program is designed to measure environmental radioactivity and radiation in the vicinity of the Darlington NGS. Based on this program, environmental samples from different pathways of the food chain are collected from various offsite locations and analyzed. Data from the program are also used to assess public doses resulting from the routine operation of the station, and to verify predictions made in environmental risk assessments. Since the implementation of CSA N , Environmental Monitoring at Class I Nuclear Facilities and Uranium Mines and Mills in 2013, OPG expanded its program scope to encompass protection of both the public and the environment from nuclear substances, hazardous substances, and physical stressors. Review of OPG s results of the environmental monitoring programs reports for the period of [67-73] shows that the concentration of radionuclides in the environment resulted in very low doses to the public, well below the e-doc (Word) July 2015 e-doc (PDF)

80 15-H8 Unprotected regulatory dose limit of 1 msv per year. This is further described in the EA information report, attached as addendum E. Protection of the Public This specific area within the EP SCA is related to ensuring that members of the public are not exposed to unreasonable risk with respect to hazardous substances discharged from NPPs. At the Darlington site, systems that discharge conventional (non-radiological) contaminants to the environment are approved under the Ontario Ministry of Environment in the Environmental Certificates of Approvals. These approvals are issued in accordance with provincial legislation (e.g., Environmental Protection Act, Water Resources Act). CNSC staff receives reports of discharges to the environment (e.g. spills) through reporting requirements outlined in CNSC REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants (formerly S-99). CNSC staff review of these reports confirms that the environment and the public are protected from non-radioactive discharges to the environment from the Darlington NGS. Environmental Risk Assessment An Environmental Risk Assessment (ERA) is a systematic process used to identify, quantify and characterize the risk posed by contaminants and physical stressors in the environment on human and non-human biota, including the magnitude and extent of the potential effects. An ERA is composed of an ecological risk assessment and human health risk assessment. OPG completed an ecological risk assessment and human health risk assessment that was reviewed and accepted by CNSC staff as part of the Darlington Refurbishment and Continued Operations Environmental Assessment (EA) under the CEAA, With the publication of CSA N Environmental risk assessments at class I nuclear facilities and uranium mines and mills, OPG has developed an implementation plan to ensure the previous assessments meet the requirements outlined in the N288.6 standard. This plan involves a gap analysis to compare the requirements of N288.6 against the assessments from the Darlington Refurbishment and Continued Operations CEAA EA. Based on the outcome of the gap analysis, OPG will revise the ERA, as required, to meet N288.6 requirements. OPG has committed to complete this work by December This timeline is acceptable to CNSC staff. Environmental Protection for Refurbishment The Commission previously concluded that refurbishment and continued operations at Darlington NGS are not likely to cause significant adverse environmental effects, taking into account mitigation measures identified in the CEAA EA Screening Report [3]. OPG has since developed an EA follow-up program in consultation with CNSC staff, Fisheries and Oceans Canada (DFO), and other stakeholders to confirm that the predictions of environmental effects are accurate and that mitigation measures are effectively implemented [74]. The EA e-doc (Word) July 2015 e-doc (PDF)

81 15-H8 Unprotected mitigation and follow-up activities are included as commitments in the IIP, as further described in section 3.2 of this CMD. In preparation for refurbishment, OPG has developed specific guidance and plans to outline the actions required of all work groups, including contractors, to manage environmental aspects during refurbishment to meet the requirements of OPG s EMS. OPG s existing environmental protection programs will be in effect during refurbishment. CNSC staff will ensure throughout the undertaking of refurbishment activities that OPG s environmental protection programs continue to protect the public and the environment Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance Performance levels for this SCA have been consistent from year to year, with satisfactory ratings given throughout the licence period. Satisfactory ratings indicate that the licensee has implemented effective safety and control measures and is in compliance with regulatory requirements and expectations. OPG has continued to implement an effective environmental protection program and associated EMS in accordance with CNSC requirements. Regulatory Focus for the Next Licence Period During the proposed licence period, CNSC staff will focus on the implementation of the EA Follow up Program to ensure the predictions of environmental effects of the CEAA EA are accurate and that mitigation measures are effectively implemented. In addition, CNSC staff will continue to verify OPG s implementation of the CSA N288 series of standards. CNSC staff will continue to carry out the Independent Environmental Monitoring Program (IEMP) as further described in the EA Information Report, attached as Addendum E to this CMD. Proposed Improvements OPG has committed to implement CSA N and N by December 2015 and December 2016, respectively. These timelines are acceptable to CNSC staff and not an impediment to licence renewal. In addition, the CEAA EA mitigation measures and follow up activities have been included as commitments in the IIP Conclusion Based on CNSC staff assessments of OPG s licence application, supporting documentation and past performance, CNSC staff conclude that the implementation of OPG s environmental protection program at the Darlington NGS continues to meet regulatory requirements. e-doc (Word) July 2015 e-doc (PDF)

82 15-H8 Unprotected As documented in the EA Information Report attached as Addendum E, CNSC staff have concluded that OPG has and will continue to make adequate provision for the protection of the environment and the health of persons. Licence condition 9.1 in the proposed licence pertains to implementing and maintaining an environmental protection program Emergency Management and Fire Protection The emergency management and fire protection SCA covers emergency plans and emergency preparedness programs which exist for emergencies and for nonroutine conditions. This also includes any results of exercise participation. This CMD covers the following specific areas of emergency management and fire protection: Conventional Emergency Preparedness and Response; Nuclear Emergency Preparedness and Response; Fire Emergency Preparedness and Response; and Fire Protection Program Trends The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: EMERGENCY MANAGEMENT AND FIRE PROTECTION Annual Safety Performance Ratings FS FS SA SA SA SA SA Comment OPG continues to perform in a satisfactory manner for this SCA. The SCA grew in scope in 2010 to include fire protection and conventional emergency preparedness and response hence the change to a satisfactory rating does not reflect a reduction in performance but rather the results of incorporating more safety areas into this SCA FS = fully satisfactory, SA = satisfactory Discussion The Darlington NGS PROL requires OPG to implement and maintain an emergency preparedness program, and conduct exercises in accordance with CNSC regulatory document RD-353 Testing and Implementation of Emergency Measures. CNSC expectations for emergency preparedness programs are contained in G-225 Emergency Planning at Class I Nuclear Facilities and Uranium Mines and Mills. The PROL also requires OPG to implement and maintain a fire protection program in accordance with CSA N293 Fire Protection e-doc (Word) July 2015 e-doc (PDF)

83 15-H8 Unprotected for Nuclear Power Plants. CNSC staff have assessed that OPG continues to meet regulatory requirements and is performing satisfactorily with respect to this SCA. OPG has implemented a number of initiatives pertaining to this SCA which include: In response to the Fukushima event, OPG has acquired portable Emergency Mitigation Equipment and infrastructure to ensure water and power can be supplied in an emergency situation; Participation in a major exercise (Exercise Unified Response) which was completed in May 2014; Support for acquisition and installation of public alerting equipment; Distribution of Potassium Iodide (KI) tablets; and Installation of an automated near boundary gamma monitoring system. In addition, OPG will be installing the Safety Improvement Opportunities (SIOs) that were committed as part for CEAA EA for Darlington refurbishment and continued operations. The SIOs were selected based on risk insights gained from PSA to improve overall safety margins and increase plant robustness to cope with severe beyond design basis accidents. Further information on the SIOs is provided in section 5.5 of this CMD. The following sections provide further details on the specific areas of emergency management and fire protection. Conventional Emergency Preparedness and Response OPG continues to maintain conventional emergency response programs at the Darlington NGS. Emergency Response personnel are available on site 24 hours a day to respond to any type of emergency. Training and equipment continue to be maintained for medical response, hazardous materials and other conventional hazards that may be present. CNSC staff conclude that OPG s conventional emergency response programs meet regulatory requirements. Nuclear Emergency Preparedness and Response In order to respond effectively to an emergency, licensees must establish and maintain a consolidated emergency plan with an associated emergency preparedness program and must conduct simulated emergencies to ensure their staff is capable of responding. To evaluate the emergency preparedness of a licensee, CNSC staff assess the licensee s emergency plan and preparedness program as well as the results of simulated emergency exercises. Emergency Management is governed by the Ontario Power Generation Consolidated Nuclear Emergency Plan (CNEP) and all other supporting programs and plans as well as the results of all emergency exercises. CNSC staff have reviewed the CNEP and have concluded that that it meets the regulatory requirements and expectations contained in RD-353 and G-225. e-doc (Word) July 2015 e-doc (PDF)

84 15-H8 Unprotected CNSC staff reviews of the nuclear emergency plan and preparedness program at the Darlington NGS have confirmed that all components of the emergency response plan are in place, meet regulatory requirements and are in a state of readiness. In May 2014, OPG participated in a major exercise called Exercise Unified Response (EUR), with a strategic goal to assess the preparedness of OPG, government and non-government to respond to a nuclear accident. This was a national, full scale, multi-jurisdictional exercise based on a NPP emergency with offsite consequences. The exercise demonstrated a number of best practices and identified opportunities for improvement for nuclear emergency response. OPG is incorporating lessons learned from this exercise in current plans, procedures, and training. An update on the EUR was provided to the Commission in CMD 14- M72.1 [75] on November 5, Equipment or Facility Upgrades OPG has procured emergency mitigating equipment (EME) at the Darlington NGS that is stored outside the protected area for use in case of severe accidents. An automated near boundary radiation monitoring system has been installed around the plant boundary to provide real-time radiation measurement and reduce the need for manual radiation surveys in an emergency. 14 public alerting sirens are currently installed and tested around the Darlington NGS site. The sirens are strategically located to ensure the audible alerts are heard and testing has confirmed that the sirens provide sufficient coverage. An update on the public alerting system for the Durham Region was provided to the Commission in CMD 12-M17 [76] on March 28, OPG has issued a new emergency preparedness public information document to residents and businesses within the 10 km radius of the Darlington NGS. The document provides guidance to the public on how to prepare for and what to do in the unlikely event of a nuclear emergency. OPG is working with stakeholders to pre-distribute potassium iodide (KI) tablets to all residents, businesses, and institutions within the 10 km radius of the Darlington NGS and pre-stock KI tablets out to the 50 km radius by December 31, An update on the pre-distribution of KI tablets was presented to the Commission in CMD 15-M13 [77] on March 26, CNSC staff conducted an emergency preparedness inspection at the Darlington NGS in 2014 and confirmed satisfactory performance [78] according to CNSC regulatory requirements. In addition, CNSC staff witnessed emergency response and EME deployment during an August 2013 exercise and during EUR in Overall, CNSC staff conclude that OPG meets CNSC regulatory expectations and the direction given by the Commission in this area. e-doc (Word) July 2015 e-doc (PDF)

85 15-H8 Unprotected Fire Emergency Preparedness and Response OPG s fire response program is well managed and satisfies regulatory requirements and expectations. Fire training occurs on site and off site for live fire training. OPG s fire training facility at Wesleyville provides training to OPG fire responders, as well as fire fighters from other nuclear power stations and municipal fire departments. Firefighting equipment at Darlington NGS meets requirements and is well maintained. OPG performs drills and exercises on a regular basis and include mutual aid exercises with municipal responders to ensure interoperability in case emergencies requiring outside assistance were to arise on site. OPG continues to maintain its fire response program through multiple oversight initiatives which include internal program reviews, industry peer reviews and audits by independent third parties. CNSC staff continue to monitor this area as part of the compliance program. Fire Protection Program Fire protection at the Darlington NGS is achieved through the implementation of a comprehensive fire protection program to minimize the risk to the health and safety of persons and to the environment from fire, through appropriate fire protection system design, fire safe operation and fire prevention. There were no reportable events during the licence period that had an effect on OPG s fire protection program at the Darlington NGS or its implementation. OPG s independent third party audit of the fire protection program and annual plant condition inspections resulted in no findings that had an impact on the performance of the fire protection program. The fire protection program at Darlington NGS meets regulatory requirements and OPG is performing satisfactorily with respect to this SCA. Emergency Management and Fire Protection for Refurbishment OPG has indicated that it will use existing plans, procedures and protocols to manage the changes to the Darlington site and the introduction of an expanded work force for the refurbishment project. Refurbishment contractors will be trained by OPG on emergency response actions when working at the Darlington site. The application and management of the emergency preparedness program will continue to be monitored by CNSC staff as part of the compliance program Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance OPG continues to demonstrate that it has satisfactory emergency preparedness and fire protection programs at the Darlington NGS. OPG has enhanced its emergency preparedness and response capabilities by using lessons learned from the Fukushima event and Exercise Unified Response. e-doc (Word) July 2015 e-doc (PDF)

86 15-H8 Unprotected Regulatory Focus for the Next Licence Period CNSC staff continue to review and monitor OPG s progress and development of the changes and improvements to its emergency response capabilities including: CNSC Regulatory Document REGDOC , Nuclear Emergency Preparedness and Response; KI pre-distribution within the 10 km Primary Zone; and implementation of refurbishment project changes to the Darlington NGS that may affect emergency preparedness and response. Proposed Improvements OPG has committed to implement CNSC regulatory document REGDOC , Nuclear Emergency Preparedness and Response by December This timeline is acceptable to CNSC staff Conclusion OPG has sufficient provisions at the Darlington NGS for preparedness and response capability that would mitigate the effects of accidental releases of nuclear substances and hazardous substances on the environment and the health and safety of persons. CNSC staff are satisfied that OPG has made adequate preparations to respond to an emergency. OPG s emergency management and fire protection programs at the Darlington NGS meet regulatory requirements. Licence condition 10.1 in the proposed licence pertains to implementing and maintaining an emergency preparedness program. Licence condition 10.2 in the proposed licence pertains to implementing and maintaining a fire protection program Waste Management The waste management SCA covers internal waste-related programs which form part of the facility s operations up to the point where the waste is removed from the facility to a separate waste management facility. The Waste Management SCA also covers the planning for decommissioning. This CMD covers the following specific areas of waste management: Waste Characterization; Waste Minimization; Waste Management Practices; and Decommissioning Plans. e-doc (Word) July 2015 e-doc (PDF)

87 15-H8 Unprotected Trends The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: WASTE MANAGEMENT Annual Safety Performance Ratings Not Rated Not Rated SA SA SA SA FS Comment OPG continues to perform in a satisfactory manner for this SCA. Waste management was first assessed separately as an SCA in Based on compliance verification activities in 2014, CNSC staff determined that the waste minimization procedures and practices were fully satisfactory which resulted in a fully satisfactory rating for this SCA, an improvement from previous years. SA = satisfactory, FS = fully satisfactory Discussion A waste management program covers internal waste processes which form part of the facility s operations up to the point where wastes are transferred to another licensed facility. OPG minimizes production of wastes through various plans, programs and procedures while additionally minimizing impacts from such wastes on workers and the environment. Key aspects of an acceptable waste management program can be found in CSA N294 Decommissioning of facilities containing nuclear substances, and CSA N Management of low- and intermediate-level radioactive waste. CNSC staff presented a report on the regulatory performance of OPG s waste management facilities (Darlington, Pickering and Western) in CMD 15-M22 on June 17, 2015 [2] which concluded that OPG s waste management facilities meet regulatory requirements. Details of CNSC staff assessment of OPG s waste management program at the Darlington NGS are presented in the following subsections. Additional information related to OPG s management of radioactive waste can also be found in section 3.5 of the EAIR, included as Addendum E of this CMD. Waste Characterization and Minimization OPG has a nuclear waste management program to minimize, control and properly dispose of radioactive waste. Specifically, OPG increases employee awareness, removes packaging materials before goods are brought into active areas, segregates metal waste for recycling and uses launderable Personal Protective Equipment (PPE) when possible. OPG also identifies the waste stream for characterization of waste. Finally, the waste management program at the Darlington NGS also sets out roles and responsibilities of staff, defines record keeping requirements and includes a change control process and a listing of all e-doc (Word) July 2015 e-doc (PDF)

88 15-H8 Unprotected associated procedures. CNSC staff have assessed that OPG s nuclear waste management program meets the requirements set out in CSA N292.3 and N294. CNSC staff have introduced CSA N Management of low- and intermediatelevel radioactive waste in the draft LCH as compliance verification criteria for the waste management SCA. CNSC staff have assessed that OPG s nuclear waste management program meets the requirements set out in CSA N Waste Management Practices Low and intermediate level radioactive waste are generated during day-to-day operations and during planned or unplanned outages. All low and intermediate level wastes generated during day-to-day operations are eventually transferred to OPG s Western Waste Management Facility for processing and storage. In relation to spent nuclear fuel, after leaving the reactor it is transferred into the irradiated fuel bays on site where it is stored for a minimum of ten years. Dry storage containers from the Darlington Waste Management Facility (DWMF) are placed into the irradiated fuel bays and loaded with spent nuclear fuel, capped, sealed with temporary transfer clamps and lifted out of the irradiated fuel bays. They are then dewatered, decontaminated and transferred back to the DWMF. OPG has effective processes in place for hazardous waste management. A CNSC staff inspection conducted in 2012 confirmed satisfactory performance [79]. Decommissioning Plans The CNSC expects that future decommissioning of a nuclear facility will be considered in all phases of its life cycle. In practice, this consideration takes the form of a Decommissioning Plan (DP), which is a requirement of the Class I Nuclear Facilities Regulations. Licensees are required to maintain an acceptable DP that sets out the manner by which the nuclear facility will be decommissioned in the future. The DP must be kept current to reflect any changes in the site or facility, and meet the requirements of CSA N and CNSC Regulatory Guide G-219, Decommissioning Planning for Licenced Activities. The licensee s submitted DP is reviewed and assessed by CNSC staff in accordance with these documents, and if found acceptable, CNSC staff make its recommendations to the Commission for acceptance. The DP and the associated cost estimate forms the basis of the Financial Guarantee. The DP for the Darlington NGS meets regulatory requirements and was last revised and presented to the Commission in CMD 12-H11.1 [80]. It remains in effect for this facility, and is updated by OPG on a five-year cycle. The financial guarantee for the Darlington NGS is described in section 5.4 of this CMD. Waste Management for Refurbishment The management of refurbishment waste has been safely carried out for previous refurbishment projects, including the refurbishments at Bruce Power Units 1 and 2 and at Point Lepreau NGS. OPG has considered the lessons learned from these projects to the management of refurbishment waste for the Darlington NGS. e-doc (Word) July 2015 e-doc (PDF)

89 15-H8 Unprotected During refurbishment, retube waste (i.e. fuel channel components including pressure tubes, calandria tubes, annulus spacers and end fittings) will be removed from the reactors, placed in shielded flasks and transferred to a new dedicated Retube Waste Processing Building (RWPB) located within the protected area on the Darlington NGS site, east of the Unit 4 powerhouse. Upon arrival at the RWPB, the shielded flasks will be unloaded into one of two independent waste processing lines for volume reduction, segregation, and packaging. The intermediate level radioactive waste will be packaged in large, heavily shielded Retube Waste Containers (RWCs). Each RWC containing intermediate level waste will be enclosed within another container, referred to as the Darlington Storage Overpack that provides additional shielding. These containers will then be transferred, via truck, and stored at a new dedicated Retube Waste Storage Building (RWSB) located on OPG property adjacent to the Darlington Waste Management Facility (DWMF). The RWSB is licensed separately under the DWMF Waste Facility Operating Licence (WFOL) Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance OPG continues to demonstrate that it has a satisfactory waste management program at the Darlington NGS. Regulatory Focus for the Next Licence Period During the proposed licence period, CNSC staff will focus on the oversight of activities at the RWPB and RWSB during refurbishment. In addition, CNSC staff will continue to verify compliance with the applicable regulatory documents and standards. Proposed Improvements CNSC staff have introduced CSA N-292.3, Management of low- and intermediate-level radioactive waste in the draft LCH as compliance verification criteria for the waste management SCA Conclusion Based on CNSC staff s assessments of OPG s licence application, supporting documents and past performance, CNSC staff conclude that OPG s implementation of the waste management program continues to meet regulatory requirements. CNSC staff also conclude that the Decommissioning Plan submitted by OPG regarding the Darlington NGS meets regulatory requirements. Licence condition 11.1 in the proposed licence pertains to implementing and maintaining a waste management program. Licence condition 11.2 in the proposed licence pertains to implementing and maintaining a decommissioning strategy. e-doc (Word) July 2015 e-doc (PDF)

90 15-H8 Unprotected 4.12 Security The security SCA covers the programs required to implement and support the security requirements stipulated in the regulations, in the licence or in expectations for the licensed facility or activity. This CMD covers the following specific areas of security: Facilities and Equipment; Security Practices; Response Arrangements; Drills and Exercises; and Cyber Security Trends OPG has attained and continues to perform at a fully satisfactory level at the Darlington NGS. The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: SECURITY Annual Safety Performance Ratings SA SA SA SA SA FS FS Comment This SCA has been rated satisfactory each year from 2008 to 2012 and fully satisfactory in 2013 and 2014 FS = fully satisfactory, SA = satisfactory Discussion The Nuclear Security Regulations (NSRs) provide the minimum requirements for security measures at the Darlington NGS. In addition OPG implements and maintains a security program in accordance with the following CNSC regulatory documents: REGDOC , High Security Sites: Nuclear Response Force; REGDOC , Site Access Security Clearance; RD-321, Criteria for Physical Protection Systems and Devices at High- Security Sites; RD-361, Criteria for Explosive Substance Detection, X-Ray Imaging and Metal Detection Devices at High-Security Sites; and RD-363, Nuclear Security Officer Medical, Physical, and Psychological Fitness. e-doc (Word) July 2015 e-doc (PDF)

91 15-H8 Unprotected OPG has improved its security program over the current licence period at the Darlington NGS. OPG is compliant with regulatory requirements and continues to improve its security program with the introduction of enhanced technologies to facilitate protected area entry searches. OPG s security programs are subject to annual inspections by CNSC staff and biennial major security exercises. Inspections over the current licence period revealed a number of program strengths with only minor areas for improvement which were adequately addressed by OPG in a timely fashion. OPG has submitted an acceptable updated site security report and its annual threat and risk assessment for the Darlington NGS is in accordance with regulatory requirements. Facilities and Equipment Effectiveness of the development and implementation of the program, for the security systems and devices, is evident in the quarterly security reports. OPG continues to make the necessary investments to maintain this specific area and to meet regulatory requirements. Major equipment upgrades are complete and operational. These upgrades provide significant improvements in terms of delay, detection, assessment, response and deterrence capabilities. The protected area barrier has also been upgraded in most areas. Security Practices The implementation of security practices at Darlington NGS is assessed as fully satisfactory. OPG continues to have a highly effective security clearance process which was subject to inspection in The results of the inspection revealed that OPG was compliant in this area and was recognized for a number of good practices. OPG also has satisfactory processes and procedures in support of access control and other areas of security. OPG has improved adherence to security procedures through strong oversight and coaching activities. OPG complies with reporting requirements for security and has updated its site security report, and threat and risk assessment in accordance with the NSRs. Response Force Arrangements The nuclear response force (NRF) program at Darlington NGS is fully satisfactory. OPG continues to maintain a NRF program through the implementation of an effective training program. The program continues a transition to an in-house nuclear response force. OPG previously used Durham Regional Police Services as its onsite response force. OPG s program in support of the NRF is in accordance with CNSC regulatory standard S-298, Nuclear Response Force, and is transitioning to CNSC REGDOC , High Security Sites: Nuclear Response Force which has superseded S-298. There have been no significant adverse findings as a result of routine inspection activities or reportable events regarding the NRF during the current licence period. OPG has in place a Memorandum of Understanding (MOU) with Durham Regional Police e-doc (Word) July 2015 e-doc (PDF)

92 15-H8 Unprotected Service in support of its need for an effective off site response force. Durham Regional Police Service continues to perform the task of the offsite response force and participates in site familiarization visits and exercises at the site. Drills and Exercises OPG has implemented an effective training, drill and exercise program that includes realistic scenarios, acceptable frequency, tracking of participation, feedback sessions, follow-up on recommendations and management review/signoff. This program now includes the collective and integrated training of both the NRF and the nuclear security officers. The major security exercises conducted over the current licence period met the requirements of the NSRs, and resulted in OPG undertaking additional training activities to address areas for improvement that were identified to enhance its response. The exercises were effective in demonstrating operability between the armed and unarmed nuclear security officers and also involved both on and off site response forces, as well as its integral emergency response team. Communication and command across multiple disciplines were exercised. Cyber Security Computer-based systems and equipment are employed in safety-related, security and emergency preparedness applications at the Darlington NGS. While computer technology benefits safe plant operation, it is susceptible to cyber-attacks that may affect plant safety and security as well as emergency preparedness. Therefore, it is essential to deal with potential cyber vulnerabilities that could negatively impact operability of safety systems, plant physical security provisions and emergency preparedness. For this reason, in 2008 CNSC staff directed OPG to conduct a self-assessment of its cyber security provisions and that improvements be made as required. Following the self-assessment, OPG initiated the implementation of cyber security governance for sustaining the cyber security program at the Darlington NGS. In 2012, OPG completed the implementation of a systematic cyber security program at Darlington NGS. Based on the assessed information and an inspection conducted in January 2015, CNSC staff concluded that OPG s cyber security program meets CNSC expectations and provides adequate provisions for the protection of computer-based assets at the Darlington NGS. Security for Refurbishment OPG is constructing a refurbishment project office on the west side of the protected area to accommodate the increased work flows associated with the project. The facility will form part of the protected area barrier and will be constructed and equipped to meet the requirements of the NSRs. Further, it will be equipped with the necessary devices to conduct ingress and egress search activities as required by the regulations. e-doc (Word) July 2015 e-doc (PDF)

93 15-H8 Unprotected Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance OPG has strengthened its security program at the Darlington NGS through the licence period and is well-positioned for the next licence period. CNSC staff compliance verification activities have demonstrated some minor opportunities for improvement but these did not compromise the facility security measures. Of these opportunities for improvement, all have been addressed satisfactorily. Regulatory Focus for the Next Licence Period In preparation for refurbishment, OPG has enhanced its entry search process and is constructing additional facilities to handle the increased number of persons. CNSC staff focus will be to monitor these activities related to refurbishment and their impacts on security, and verify compliance with regulatory requirements through routine inspections. Proposed Improvements OPG continues to improve its security program at the Darlington NGS with the addition of new technologies for protected area entry search equipment and the planned construction of a refurbishment project office on the west side of the protected area to accommodate the increased work flows associated with the project Conclusion CNSC staff conclude that OPG has a fully satisfactory security program in place at the Darlington NGS that meets regulatory requirements and makes adequate provisions for the maintenance of national security. Licence condition 12.1 in the proposed licence pertains to implementing and maintaining security program Safeguards and Non-Proliferation The safeguards and non-proliferation SCA covers the programs and activities required for the successful implementation of the obligations arising from the Canada/IAEA safeguards agreements as well as other measures arising from the Treaty on the Non-Proliferation of Nuclear Weapons. The scope of the non-proliferation program for OPG is limited to the tracking and reporting of foreign obligations and origins of nuclear material. This tracking and reporting assists the CNSC in the implementation of Canada s bilateral Nuclear Cooperation Agreements with other countries. In addition, the import and export of controlled nuclear substances, equipment and information identified in the Nuclear Non-proliferation Import and Export Control Regulations require separate authorization from the CNSC, consistent with section 3(2) of the General Nuclear Safety and Control Regulations. e-doc (Word) July 2015 e-doc (PDF)

94 15-H8 Unprotected This CMD covers the following specific areas of safeguards and nonproliferation: Nuclear Material Accountancy and Control; Access and Assistance to the IAEA; Operational and Design Information; and Safeguards Equipment, Containment and Surveillance Trends OPG continues to implement and maintain a program at the Darlington NGS to ensure the effective implementation of both safeguards measures and nuclear nonproliferation commitments. OPG has also demonstrated in the licence application that these programs will be maintained throughout the next licence period. The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: SAFEGUARDS AND NON-PROLIFERATION Annual Safety Performance Ratings FS SA SA SA SA SA SA Comment OPG s performance in this SCA continues to be satisfactory. Non-Proliferation was added to this SCA in 2012 so that compliance ratings from are for the former Safeguards SCA only. FS = fully satisfactory, SA = satisfactory Discussion OPG has an effective safeguards program at the Darlington NGS that conforms to measures required by the CNSC to meet Canada s international safeguards obligations as well as other measures arising from the Treaty on the Non- Proliferation of Nuclear Weapons. The CNSC regulatory mandate includes ensuring conformity with measures required to implement Canada s international obligations on the peaceful uses of nuclear energy. Pursuant to the Treaty on the Non-Proliferation of Nuclear Weapons, Canada has entered into a Comprehensive Safeguards Agreement and Additional Protocol with the IAEA (hereafter, the safeguards agreements). The objective of the safeguards agreements is for the IAEA to provide annual assurance to Canada and to the international community that all declared nuclear material is in peaceful, non-explosive uses and that there is no indication of undeclared material. The CNSC provides the mechanism, through the NSCA regulations and a licence condition, for the IAEA to implement the safeguards agreements. Conditions for e-doc (Word) July 2015 e-doc (PDF)

95 15-H8 Unprotected the application of IAEA safeguards are contained in the PROL and criteria in order to meet the conditions are contained in the LCH. Safeguards for Refurbishment During refurbishment, OPG will be required to continue to implement a program at the Darlington NGS, which ensures the effective implementation of both safeguards measures and nuclear non-proliferation commitments with respect to Canada s international obligations, including submitting all necessary accountancy and operational reports. The IAEA will continue to undertake inspections at the Darlington NGS, including those relating to verification of changes to the reactors and/or site during refurbishment Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance During the current licence period, OPG provided the CNSC and IAEA with all reports and information necessary to comply with the safeguards regulatory requirements for the Darlington NGS, including those related to nuclear material accounting and reporting. In addition to equipment upgrades and maintenance, the IAEA performed inspections and verifications, including one short-notice random inspection, one physical inventory verification, and one design information verification. The CNSC also performed an evaluation of the Darlington NGS s preparedness for the physical inventory verification in 2014, since it was not selected by the IAEA for this type of inspection that year. In all cases, OPG provided the IAEA and CNSC with the necessary access and assistance to perform their activities, and complied with all regulatory requirements at the Darlington NGS. There were no reportable events or action notices issues as a result of these inspections. OPG s program for safeguards and non-proliferation at the Darlington NGS continues to meet CNSC requirements and expectations. Regulatory Focus for the Next Licence Period CNSC staff will continue to monitor and ensure that OPG continues to comply with its safeguards obligations at the Darlington NGS as outlined in the NSCA, regulations and the operating licence. Proposed Improvements The CNSC has recently launched the Nuclear Materials Accountancy Reporting (NMAR) e-business system. The system is used by licensees to electronically report to the CNSC inventories and movements of nuclear material subject to safeguards. For an efficient and secure method of transmitting nuclear materials accountancy reports to the CNSC, it is expected that OPG adopts the NMAR e- business system for use at the Darlington NGS. e-doc (Word) July 2015 e-doc (PDF)

96 15-H8 Unprotected Conclusion Based on CNSC staff assessments of OPG s licence application, supporting documents and past performance, OPG s implementation of the safeguards and non-proliferation SCA at the Darlington NGS has met and continues to meet all applicable regulatory requirements. Licence condition 13.1 in the proposed licence pertains to implementing and maintaining a safeguards program Packaging and Transport The packaging and transport SCA covers programs for the safe packaging and transport of nuclear substances to and from the licensed facility. This CMD covers the following specific areas of packaging and transport: Packaging and Transport; Package Design and Maintenance; and Registration for Use Trends OPG continues to demonstrate compliance with the Packaging and Transport of Nuclear Substances Regulations and the Transportation of Dangerous Goods Regulations at the Darlington NGS. OPG is performing satisfactorily in the safety area of packaging and transport at the Darlington NGS. The following table indicates the annual safety performance ratings for this SCA from 2008 to 2014: PACKAGING AND TRANSPORT Annual Safety Performance Ratings Not rated Not rated SA SA SA SA SA Comment Packaging and transport was first assessed separately as an SCA in Aspects of this SCA were previously included in the areas of performance assurance and radiation protection. OPG continues to maintain satisfactory performance in this packaging and transport SCA. SA = satisfactory Discussion OPG has developed and implemented a packaging and transport program for activities at all OPG operated sites to ensure compliance with the Packaging and Transport of Nuclear Substances Regulations and the Transportation of Dangerous Goods Regulations for all shipments leaving the site. OPG s packaging and transport program also covers elements of package design, e-doc (Word) July 2015 e-doc (PDF)

97 15-H8 Unprotected package maintenance, and the registration for use of certified packages as required by the regulations. Details of CNSC staff s assessment are presented in the following paragraphs. The Packaging and Transport of Nuclear Substances Regulations apply to the packaging and transport of nuclear substances, including the design, production, use, inspection, maintenance and repair of packages, and the preparation, consigning, handling, loading, carriage and unloading of packages. OPG is required to have appropriate training for personnel involved in the handling and transport of dangerous goods at the Darlington NGS, and is required to issue a training certificate to those workers in accordance with the Transportation of Dangerous Goods Regulations. There were no significant events reported under the Packaging and Transport of Nuclear Substances Regulations for consignments transported to and from the Darlington NGS from 2010 to CNSC staff conducted packaging and transport inspections in 2012 [81] and 2013 [82]. As a result of these inspections, there were no issues reported. It was concluded that packaging and transportation of nuclear substances at OPG fully met CNSC requirements and expectations. Packaging and Transport for Refurbishment During refurbishment, OPG will continue to implement its packaging and transport program. Retube waste will be placed into purpose-built retube waste containers (RWCs). When ready for transport, a reinforced lid and impact protection will be added to the containers. These containers will then be transferred, via truck, and stored at a new Retube Waste Storage Building (RWSB) located on OPG property adjacent to the Darlington Waste Management Facility (DWMF). The RWSB is licensed separately under the DWMF Waste Facility Operating Licence (WFOL) Summary A summary of past performance, regulatory focus and proposed improvements are presented in the following subsections. Past Performance OPG is performing satisfactorily in the packaging and transport SCA at the Darlington NGS. OPG continues to demonstrate compliance with the Packaging and Transport of Nuclear Substances Regulations and the Transportation of Dangerous Goods Regulations and, as such, obtained a satisfactory rating for the period of 2010 to Regulatory Focus for the Next Licence Period CNSC staff will continue to ensure that shipments transported to and from the Darlington NGS are in compliance with both the Packaging and Transport of Nuclear Substances Regulations and the Transportation of Dangerous Goods Regulations. e-doc (Word) July 2015 e-doc (PDF)

98 15-H8 Unprotected Proposed Improvements Revised Packaging and Transport of Nuclear Substances Regulations are expected to be published in the near future. Although only small changes are being made to the regulatory requirements, these revised regulations may have a small impact as OPG will need to review its packaging and transport program to ensure continued compliance with the revised regulations Conclusion Based on CNSC staff assessments of OPG s licence application, supporting documents and past performance, OPG s implementation of the packaging and transport SCA has met and continues to meet all applicable regulatory requirements. Licence condition 14.1 in the proposed licence pertains to implementing and maintaining a packaging and transport program. e-doc (Word) July 2015 e-doc (PDF)

99 15-H8 Unprotected 5. OTHER MATTERS OF REGULATORY INTEREST 5.1 Aboriginal Consultation The common law duty to consult with Aboriginal groups applies when the Crown contemplates actions that may adversely affect potential or established Aboriginal and/or treaty rights. The CNSC, as an agent of the Crown and as Canada s nuclear regulator recognizes and understands the importance of building relationships and consulting with Canada s Aboriginal peoples. The CNSC ensures that all of its licensing decisions under the NSCA uphold the honour of the Crown and considers Aboriginal peoples potential or established Aboriginal and/or treaty rights pursuant to section 35 of the Constitution Act, Discussion This proposed licence renewal involves activities occurring on an existing fencedin site with restricted access. Based on previous requests to be kept informed of activities at the Darlington NGS and through CNSC staff research, the following First Nation and Métis groups were identified as having an interest in this licence renewal application: Williams Treaties First Nations (Alderville First Nation, Chippewa Indians of Christian Island (Beausoleil First Nation), Chippewa Indians of Georgina Island, Curve Lake First Nation, Chippewa Indians of Rama First Nation, Hiawatha First Nation (Mississauga Indians of Rice Lake), Mississauga Indians of Scugog Island First Nation); Mississaugas of the New Credit First Nation; Mohawks of the Bay of Quinte; Saugeen Ojibway Nation (SON) (Saugeen First Nation and the Chippewas of Nawash Unceded First Nation); Association of Iroquois and Allied Indians; Six Nations of the Grand River; Chiefs of Ontario; Union of Ontario Indians; and Métis Nation of Ontario (MNO). In July 2013, CNSC staff sent these groups a request for comment on the draft EA Follow-up Program for the refurbishment and continued operation of the Darlington NGS. The aforementioned groups were provided advanced notice of the 30-day public comment period, a compact disc (CD) copy of the draft EA Follow-up Program, and information on how to provide comments. No comments were received from any of the groups. CNSC staff also sent letters of information on March 14, 2014 to the above groups, which included information on the licence renewal application, availability of funding through CNSC s Participant Funding Program (PFP), how e-doc (Word) July 2015 e-doc (PDF)

100 15-H8 Unprotected to participate in the regulatory review process including the Commission hearing, and encouraged groups to advise the CNSC of views they may have in relation to this licence renewal application. In March 2014, follow-up phone calls were conducted with the groups to ensure they had received the letters and to answer any questions. On July 31, 2014 the CNSC informed all identified Aboriginal groups regarding the Commission s decision to amend the Darlington NGS PROL for a 12 month period, including changes to the hearing dates. With respect to the section 35 (2) Fisheries Act authorization, Fisheries and Oceans Canada (DFO) is the Crown Consultation Coordinator for the authorization. Where appropriate, CNSC staff will continue to share information with DFO on issues or concerns raised by First Nation and Métis groups with respect to the fisheries authorization, heard by CNSC staff, through its Aboriginal consultation activities. However, to date the CNSC has not been made aware of any concerns from the identified Aboriginal groups in relation to the fisheries authorization process. The Fisheries Act authorization was issued by DFO to OPG on June 24, Upon request, on June 17, 2014, CNSC staff met with the Williams Treaties First Nations at the Darlington NGS site and on July 18, 2014 met with the Mississaugas of the New Credit First Nation in Hagersville, Ontario in order to discuss the Darlington NGS licence renewal. On April 29, 2015 CNSC staff participated in a day-long session hosted by OPG with representatives of the Williams Treaties First Nations, the Mississaugas of the New Credit First Nation, the Mohawks of the Bay of Quinte and the Métis Nation of Ontario at the Darlington NGS to provide an update on the Darlington NGS licence renewal process and discuss any concerns that the groups may have in relation to the licence renewal application. CNSC staff made a presentation and answered questions. To date, the identified Aboriginal groups have raised concerns including the length of the licence term requested by OPG (i.e. the longer licence term could reduce the number of meaningful opportunities to participate for Aboriginal communities), the period of time provided to the public to review CMDs and the desire to be more involved in OPG and/or CNSC environmental monitoring programs. However, no concerns have been raised to date directly related to impacts on potential or established Aboriginal and/or treaty rights. CNSC staff are committed to continuing to engage with the identified First Nation and Métis groups and will provide an update to the Commission at the public hearing regarding any discussions or activities conducted following the finalization of the CMD. e-doc (Word) July 2015 e-doc (PDF)

101 15-H8 Unprotected Conclusion First Nation and Métis groups who may have an interest in the licence renewal application were identified early in the review process, provided information about the project, encouraged to participate in the Commission s public hearing, and to apply for funding through CNSC's Participant Funding Program. Since the Commission public hearing in December 2012 regarding the EA for the proposal to refurbish and continue to operate the Darlington NGS, no related issues or concerns related to impacts on Aboriginal and/or treaty rights have been raised by the identified First Nation and Métis groups during CNSC staff consultation activities. Based on the information received and reviewed to date, CNSC staff are of the opinion that this licence renewal application will not cause adverse impacts to any potential or established Aboriginal and/or treaty rights. The identified First Nation and Métis groups have been encouraged to participate in the licence renewal application review process and in the Commission public hearing to advise the Commission directly of any concerns they may have in relation to this licence application. 5.2 Other Consultation As per its normal public information process, CNSC staff informed the public via the CNSC website, and other methods, that a public hearing will be held for the application to renew the Darlington NGS operating licence Discussion The CNSC made available up to $75,000 through its Participant Funding Program (PFP) to assist members of the public, Aboriginal groups, and other stakeholders in providing value-added information to the Commission through informed and topic-specific interventions. This funding was used to review OPG s Darlington licence renewal application and other relevant documentation specifically related to the application, and to prepare for and participate in the Commission s public hearing. The public, Aboriginal groups and other stakeholders were informed of the availability of participant funding through a series of public communications: Posting of the PFP Funding Announcement on the PFP section of the CNSC website; Public information bulletin to subscribers of the CNSC website; Advertisements in local radio, on-line and print media; and Notification by letter to potentially interested Aboriginal groups. The deadline for applications was April 28, A Funding Review Committee (FRC), independent from CNSC staff, reviewed the funding applications received, and made recommendations on the allocation of funding to eligible applicants. e-doc (Word) July 2015 e-doc (PDF)

102 15-H8 Unprotected Based on recommendations from the FRC, the CNSC awarded a total of $65, in participant funding to the following recipients, who are required to submit a written intervention and make an oral intervention at the Commission s public hearing: Society of Professional Engineers and Associates; Women in Nuclear; North American Young Generation in Nuclear; Mississaugas of New Credit First Nation; Mohawks of the Bay of Quinte; Lake Ontario Water Keeper; and Northwatch. In accordance with section 17 of the Canadian Nuclear Safety Commission Rules of Procedure, a Notice of Public Hearing [82] has been issued and posted on the CNSC website inviting written comments and requests for appearances before the Commission. Hearing Part One: August 19, 2015 Place: Time: CNSC public hearing room, 14 th floor, 280 Slater Street, Ottawa, Ontario As set by the agenda published prior to the hearing date Hearing Part Two: November 2-5, 2015 Place: Hope Fellowship Church, 1685 Bloor Street, Courtice, Ontario Time: As set by the agenda published prior to the hearing date The public hearing will be webcast live and then archived for 90 days on the CNSC website at nuclearsafety.gc.ca. Members of the public who have an interest or expertise in this matter, or information that may be useful to the Commission, are invited to comment on OPG s application on hearing Part Two. Requests to intervene must be filed with the Secretary of the Commission by September 28, 2015 online at nuclearsafety.gc.ca/eng/the-commission/intervention. e-doc (Word) July 2015 e-doc (PDF)

103 15-H8 Unprotected Pursuant to the Canadian Nuclear Safety Commission Rules of Procedure, the request must include the following information: a written submission of the comments to be presented to the Commission; a statement setting out whether the requester wishes to intervene by a written submission only or by both a written submission and oral presentation; and the requester s name, address and telephone number. Agendas and information on the hearing process, including how to participate in the public hearings, are available at the CNSC website: nuclearsafety.gc.ca, under section Hearings. The Notice of Public Hearing was: distributed by and shared on Facebook; shared on Facebook with over 760 subscribers; and advertised in the Toronto Star, Clarington This Week, Oshawa This Week, L Express de Toronto and Aboriginal Multi-Media Society online. Information about the regulatory process for the renewal of OPG's operating licence for the Darlington NGS was communicated to stakeholders and Aboriginal groups through various methods by the CNSC Conclusion Based on the above information, CNSC staff have encouraged the public to participate in the Commission s public hearing. The CNSC provided assistance to interested members of the public, Aboriginal Groups, and other stakeholders, through the PFP, to prepare for and participate in the Commission s public hearing. 5.3 Cost Recovery It is a requirement of the NSCA under paragraph 24(2)(c), that the licence application is accompanied by the prescribed fee. The Cost Recovery Fees Regulations (CRFR) set out the specific requirements based on the activities to be licensed. An applicant for a Class I facility Licence is subject to Part 2 of CRFR, which is based on Regulatory Activity Plan Fees Discussion OPG is in good standing with respect to CRFR requirements for the Darlington NGS. OPG s licence renewal application for the Darlington NGS is not a new application, and as such OPG is not required to submit the initial fee of $25,000 as described in paragraph 7(1)(a), which are only for initial applicants. In this case, OPG is subject to subsection 5(2), which relates to quarterly invoices sent to licensees. e-doc (Word) July 2015 e-doc (PDF)

104 15-H8 Unprotected Conclusion After assessing CNSC records, CNSC staff conclude that OPG is in good standing with respect to CRFR requirements for the Darlington NGS. Based on OPG s previous performance, there are no concerns over payment of future cost recovery fees. 5.4 Financial Guarantees The Darlington NGS PROL requires OPG to maintain a financial guarantee for the future decommissioning of the Darlington NGS which is acceptable to the Commission. CNSC Regulatory Guides G-219, Decommissioning Planning for Licensed Activities and G-206, Financial Guarantees for Decommissioning of Licensed Activities provides guidance on calculating the financial guarantees Discussion OPG maintains a consolidated financial guarantee for decommissioning its Ontario assets which includes the Darlington NGS, the Bruce A and B NGS, the Pickering NGS, as well as the Darlington, Pickering and Western Waste Management facilities. Based on OPG s most recent annual report for the CNSC Financial Guarantee, the total value of the available financial guarantee stands at $17,004 million. The financial guarantee that was accepted by the Commission in 2012 [80] for these facilities includes: segregated funds established pursuant to the Ontario Nuclear Funds Agreement (ONFA) between OPG and the Province of Ontario (the ONFA Funds ); the trust fund for the management of spent fuel established pursuant to the Nuclear Fuel Waste Act (the NFWA Trust ); and the Provincial Guarantee pursuant to the Provincial Guarantee Agreement between the CNSC and the Province of Ontario. Currently, the financial guarantee is in effect and sufficient to fund the future decommissioning of OPG s Class I facilities as anticipated by its Decommissioning Plans. OPG is required to review and revise the Decommissioning Plans, the associated cost estimates and the proposed financial guarantee by June 30, 2017, for the next five-year cycle Conclusion CNSC staff are satisfied that OPG s financial guarantee meets the guidance as set out in CNSC Regulatory Guide G-206, Financial Guarantees for the Decommissioning of Licensed Activities. Licence condition G.5 in the proposed licence pertains to financial guarantees. e-doc (Word) July 2015 e-doc (PDF)

105 15-H8 Unprotected 5.5 Improvement Plan and Significant Future Activities (including Fukushima Actions) This section focuses on planned improvements at the station, including an update on the status of the Fukushima Action Items Discussion Integrated Implementation Plan As discussed in detail in section 3 of this CMD, OPG has completed an Integrated Safety Review (ISR), Global Assessment Report (GAR), and Integrated Implementation Plan (IIP) as set out CNSC Regulatory Document RD-360 Life Extension of Nuclear Power Plants. CNSC staff have reviewed and accepted the ISR, GAR and IIP and concluded that OPG s assessments for refurbishment and life extension meet regulatory requirements and expectations. Completion of the IIP actions has been included as a licence condition in the proposed PROL. Safety Improvement Opportunities (SIOs) The IIP includes the implementation of the safety improvement opportunities (SIOs), that OPG committed to install as part of the EA for the Darlington refurbishment and continued operations completed under the CEAA. The SIOs were selected for implementation using risk insights gained from PSA to improve overall safety margins and increase plant robustness to cope with severe beyond design basis accidents. The SIOs are further described below. Containment Filtered Venting System (CFVS). The purpose of the CFVS is to provide controlled and filtered emergency venting of containment to prevent over pressurization and assure containment integrity in the highly unlikely event of a severe beyond design basis accident. The planned inservice date for the CFVS is scheduled for mid Shield Tank Overpressure Protection (STOP). The purpose of this modification is to enhance the relief capacity of the shield tank surrounding each unit s calandria vessel to prevent shield tank failure and to limit the containment over pressurization in the highly unlikely event of a severe beyond design basis accident. All units will have the STOP modification installed prior to the completion of the first refurbishment outage in A third Emergency Power Generator (EPG3). EPG3 will increase the defence in depth of the emergency power reliability if any one EPG is not available. The planned in service date for EPG3 is scheduled for early Powerhouse Steam Venting System (PSVS) enhancements. The purpose of the PSVS is to protect plant systems by venting steam in the unlikely event of a steam line break in the powerhouse. The PSVS enhancements are related to duplication of the programmable controller logic of the current PSVS to improve reliability. The planned in service date for the PSVS modification is scheduled for e-doc (Word) July 2015 e-doc (PDF)

106 15-H8 Unprotected Independent source of emergency water supply to the heat transport system. This modification involves installing permanent fire water pumps and a permanent line from the emergency service water system to the heat transport system for emergency water injection to the heat transport system. Each unit will have this modification installed during its refurbishment outage. Other Station and Site Infrastructure Improvements In addition to the activities described above, OPG is making further improvements to the plant and to the site infrastructure to improve station reliability and to support the refurbishment project. These improvements include: Inspections and repairs of the four turbine generator sets and the replacement of analog control systems with new digital control systems; Mechanical cleaning, water lancing, inspection and maintenance work of the steam generators; Construction of a new heavy water storage facility; Replacement of the existing auxiliary building heating system; Construction of a re-tube waste processing and storage building; Replacement of the existing water treatment plant; Construction of new shop and office facilities to support refurbishment activities; and Improvements in site infrastructure such as sewer, water, electrical power distribution and site roads to support the new facilities. CNSC staff s view is that OPG s improvement plans to the station and to the site infrastructure are comprehensive. CNSC staff continue to monitor the station and site infrastructure improvement initiatives as part of the compliance program. Update on Fukushima Action Items All of the Fukushima Action Items (FAIs) have been closed at the Darlington NGS. OPG is the first NPP licensee in Canada to have closed all FAIs. OPG has strengthened reactor defence-in-depth and enhanced its emergency response capabilities at the Darlington NGS in response to lessons learned from the Fukushima nuclear accident. The following key actions are noteworthy: Emergency Mitigating Equipment (EME) including portable diesel pumps and diesel generators/portable uninterruptible power supplies are now available to supply essential fuel cooling through multiple paths and to supply power to key monitoring equipment in the highly unlikely event of a severe beyond design basis accident. Further enhancements are being made to streamline and simplify EME deployment and to provide additional EME to allow additional capacity to re-power key station equipment. CNSC staff are tracking the implementation of the EME enhancements at the Darlington NGS as part of the compliance program. e-doc (Word) July 2015 e-doc (PDF)

107 15-H8 Unprotected Hydrogen mitigating Passive Autocatalytic Recombiners (PARs) have been installed on all units. PARs are in addition to hydrogen igniters but do not require electrical power to operate. Emergency preparedness plans, procedures, training, and drills/exercises have been enhanced to include severe beyond design basis accidents. A major emergency preparedness exercise Exercise Unified Response was conducted in May 2014, to demonstrate OPG s capability to respond to a severe beyond design basis event. An automated radiation monitoring system has been installed around the plant boundary to provide real-time radiation measurement reducing the need for manual radiation surveys in the event of an accident. A mutual aid agreement has been established between Canadian nuclear operators to provide support in the event of an emergency. FAIs related to malevolent acts are addressed under a separate, protected CMD (CMD 14-M81) which was presented to the Commission on December 17, Photographs of the EME at the Darlington NGS are presented on the following pages. e-doc (Word) July 2015 e-doc (PDF)

108 15-H8 Unprotected Figure 4: Darlington Emergency Mitigating Equipment (EME) storage facility located outside the protected area boundary at high elevation Figure 5: Emergency water supply pumps take lake water from the forebay, which can supply specific systems with cooling water e-doc (Word) July 2015 e-doc (PDF)

109 15-H8 Unprotected Figure 6: CNSC staff reviews the EME generator deployment at Darlington NGS during Exercise Unified Response (EUR) in May Once deployed, the EME generator provides power to key monitoring equipment. Figure 7: Portable Uninterruptible Power Supplies provide power to key monitoring equipment. e-doc (Word) July 2015 e-doc (PDF)

110 15-H8 Unprotected Conclusion CNSC staff are satisfied with OPG s proposed station improvement initiatives for the Darlington NGS. CNSC staff are of the opinion that OPG s proposed improvements to the plant and the site infrastructure are comprehensive. CNSC staff will continue to monitor the implementation of OPG s improvement initiatives as part of the compliance program. 5.6 Licensee Public Information Program A public information and disclosure program (PIDP) is a regulatory requirement for licence applicants. The primary goal of the program, as it relates to the licensed activities, is to ensure that information related to the health, safety and security of persons and the environment, and other issues associated with the lifecycle of nuclear facilities are effectively communicated to the public, in order to improve their level of understanding. As a component, the program shall include a commitment to and protocol for ongoing, timely communication of information related to the licensed facility during the course of the licence period. The public information program and its disclosure protocol shall be commensurate with the public s perception of risk and the level of public interest in the licensed activities. It may be further influenced by the complexity of the nuclear facility s lifecycle and activities, and the risks to public health and safety and the environment perceived to be associated with the facility and activities Discussion CNSC staff have assessed that OPG has a well-established PIDP that meets the regulatory requirements of RD/GD 99.3 Public Information and Disclosure. The program ensures information about the health, safety and security of persons and the environment, and other issues associated with the lifecycle of its facilities are effectively communicated to the public. OPG s PIDP: identifies clear goals and measurable objectives in terms of dissemination of information to targeted audiences; targets multiple audiences such as local residents, elected and government representatives, media, business leaders, youth, interest groups, and community organizations; recognizes the importance of actively providing updates and briefings to First Nations and Métis leaders and communities; is informed by ongoing dialogue with elected representatives, media monitoring activities and public opinion research, thereby gauging the level of public interest and perception; identifies specific products tailored to different audiences by providing various means for them to obtain information; includes a public disclosure protocol, which provides the criteria used to determine whether an event will be posted on its website; e-doc (Word) July 2015 e-doc (PDF)

111 15-H8 Unprotected makes use of tools to assess the success of its implementation, such as public opinion surveys, benchmarking, web analysis and community member feedback, in order to identify potential areas for improvement; provides contact information for members of the public who want to obtain additional information; and incorporates public crisis communication as a key aspect of its approach to responding to emergencies. In 2015, OPG submitted an annual report on the implementation of its PIDP in In reviewing the report and OPG s licence application, CNSC staff have identified a number of best practices. These best practices include the dissemination of information pertaining to the licence renewal process and refurbishment activities through various means, including tours of the new Darlington Energy Complex, a training facility built for the refurbishment of Darlington and distribution of a Nuclear Safety Guide to provide information about what to do in the unlikely event of a nuclear emergency. Going forward, CNSC staff will ensure that OPG maintains its demonstrated commitment to continuous improvement in communicating with the public Conclusion CNSC staff are satisfied that OPG s PIDP meets regulatory requirements as set out in RD/GD 99.3, Public Information and Disclosure. CNSC staff will continue to assess OPG s ongoing implementation and monitor changes to its program. Licence condition G.6 in the proposed licence pertains to implementing and maintaining a public information and disclosure protocol. 5.7 Nuclear Liability Insurance As required under subsection 15(1) of the Nuclear Liability Act, the operator shall, with respect to each nuclear installation of which he is the operator, maintain with an approved insurer insurance against the liability imposed on him by this Act, consisting of: (a) basic insurance for such term and for such amount not exceeding seventyfive million dollars as may be prescribed with respect to that nuclear installation by the Canadian Nuclear Safety Commission, with the approval of the Treasury Board, and (b) supplementary insurance for the same term and for an amount equal to the difference, if any, between the amount prescribed under paragraph (a) and seventy-five million dollars, and containing such terms and conditions as are approved by the Minister. e-doc (Word) July 2015 e-doc (PDF)

112 15-H8 Unprotected Discussion Under policy OF021, the Nuclear Insurance Association of Canada has provided a limit of liability of $50 million and under policy EL031CA14, the European Liability Insurance for Nuclear Industry has provided a limit of liability of $25 million. This policy is valid from January 1, 2015 to January 1, 2016, unless amended or cancelled, and it is expected to continue to be renewed each year, consistent with past practice, so long as the Nuclear Liability Act remains in force. OPG submitted a copy of the Certificate of Insurance No issued by Marsh Canada Limited [9] Conclusion CNSC staff are satisfied with OPG s provision to fulfill its obligation under the Nuclear Liability Act. 5.8 Fisheries Act Authorization On June 24, 2015, Fisheries and Oceans Canada issued a section 35(2) Fisheries Act authorization to OPG for the operation of the Darlington NGS. Further information can be found in the EA Information Report in Addendum E of this CMD. 5.9 Tritium Removal Facility The current Darlington NGS PROL authorizes OPG to operate the Darlington NGS, which includes the tritium removal facility (TRF) housed in the heavy water management building (HWMB) located on the site. The TRF and HWMB maintain low tritium levels at Darlington and other Ontario CANDU reactors, and maintain isotopic purity requirements for heavy water at the Darlington NGS Discussion CNSC staff conduct routine compliance inspections of the HWMB and the TRF during their planned maintenance outages [84, 85]. These inspections found no significant safety issues. CNSC staff provided recommendations to OPG for continued improvements during subsequent outages. Areas that were previously identified by CNSC staff as requiring further improvement [86] have been resolved. In 2014, the availability of the TRF was adversely impacted due to impurity ingress in one of the TRF systems. The increased number of restarts due to the degraded operability of the TRF resulted in higher emissions in 2014 compared to previous years but still well below regulatory limits and action levels. OPG has developed an acceptable action plan to address this issue and CNSC staff are monitoring its implementation. OPG has developed a lifecycle management plan for the TRF to improve equipment reliability. OPG is in the process of reviewing various options to extend the operating of life of the TRF to coincide with the end of the Darlington NGS extended plant life. Work is progressing to refine the TRF life extension e-doc (Word) July 2015 e-doc (PDF)

113 15-H8 Unprotected scope and determine the feasibility of life extension implementation. In the application for licence renewal, OPG indicates that a decision to continue with TRF life extension is expected by 2017 and that life extension of the TRF is being addressed separately from the refurbishment program of the station Conclusion CNSC staff are satisfied with the operation of the TRF. Based on the information assessed, CNSC staff conclude that the operations at the TRF continue to meet regulatory requirements. Licence condition 15.1 pertains to the operation of the TRF at the Darlington NGS Previous Commitments Raised by the Commission The record of proceedings, including reasons for decision for the Darlington refurbishment and continued operations EA [3] and 22 month PROL renewal [5] directed CNSC staff to complete a number of actions in support of this licensing process. CNSC staff have completed these actions as requested. The table below provides an information map as to where the requested information can be found within this CMD, or other CMDs previously presented to the Commission. Previous Commitments Raised by the Commission to CNSC Staff Item Action CMD Section 1. Update by CNSC staff to the Refer to Addendum E of this CMD. Commission concerning proposed updates to the allowable levels of radiation in foodstuffs during emergencies. 2. Update by CNSC staff to the Commission regarding the Integrated Implementation Plan (IIP). Refer to section 3.2 and Addendum F of this CMD. 3. Update by CNSC staff to the Commission on the assessment of health and environmental consequences of severe accident scenarios. 4. Update by CNSC staff to the Commission on the discussions or issues raised by Aboriginal groups. 5. Update by CNSC staff to the Commission regarding concrete integrity at the Darlington NGS. Refer to CMD 14-M30 [87] presented to the Commission on June 19, 2014 and CMD 15-M10 [88] presented to the Commission on March 26, Also refer to Addendum E of this CMD. Refer to section 5.1 of this CMD. Refer to section of this CMD. 6. Update by CNSC staff on OPG s Refer to section of this CMD. e-doc (Word) July 2015 e-doc (PDF)

114 15-H8 Unprotected Item Action CMD Section implementation strategy for compliance with CNSC Regulatory Document RD-310 Safety Analysis for Nuclear Power Plants. 7. Update by CNSC staff on its analysis and findings concerning robustness analysis for malevolent aircraft crash. 8. Update by CNSC staff on its development of an independent environmental monitoring program (IEMP) Proposed Licence Period Refer to section of this CMD and protected CMD 14-M81 presented to the Commission on December 17, Refer to CMD 15-M15 [89] presented to the Commission on March 25, Refer to Addendum E of this CMD for Darlington specific IEMP results. As outlined in the application for licence renewal, OPG is requesting a licence term to December 1, 2028 to cover the refurbishment of the four units and completion of the IIP commitments. OPG acknowledges that this is a longer licence term than has been traditionally granted to a Canadian licensee but requests that this be considered. OPG s rationale for requesting a longer licence is based on the completion of the ISR and allowance of sufficient time to complete the proposed refurbishment outages and other IIP commitments on all units within a single licence term. As outlined in Section 3.3, OPG is planning to stagger the refurbishment outages with Unit 2 being refurbished first from 2016 to 2019, followed by Unit 3 from 2019 to 2022, Unit 1 from 2021 to 2024, and Unit 4 from 2022 to OPG has committed that for unit specific work, all IIP activities will be completed by the first planned maintenance outage following the refurbishment outage. This plan takes the completion of IIP commitments for Unit 4 out to In support of its request for a longer licence term, OPG commits to appearing before the Commission at the end of each refurbishment outage in addition to its annual appearance before the Commission for the annual CNSC Staff Regulatory Oversight Report for Canadian Nuclear Power Plants. CNSC staff acknowledge that OPG s request for a 13 year licence term better aligns with the planning cycle of the Darlington NGS. The length of the licence term does not impact the effectiveness of CNSC staff s compliance program or the authority of the Commission to suspend, revoke, or replace the licence including the establishment of new licence conditions at any time. In April 2015, the CNSC published regulatory document REGDOC-2.3.3, Periodic Safety Reviews [90] which now supersedes regulatory document RD- 360, Life Extension of Nuclear Power Plants. REGDOC-2.3.3, builds upon the ISR process outlined in RD-360 and includes a requirement for a safety review to e-doc (Word) July 2015 e-doc (PDF)

115 15-H8 Unprotected be completed every 10 years throughout the lifetime of the NPP. The ISR performed by OPG in accordance with RD-360 is considered to be equivalent to the first periodic safety review (PSR). As outlined in CMD 15-M12 [91],with the introduction of periodic safety reviews (PSRs) to the CNSC regulatory framework, CNSC staff have recommended transitioning to operating licences for NPPs that are valid for 10 years, as compared to the current five year licence period, and a PSR done every 10 years to coincide with licence renewals. As such, for the Darlington NGS, CNSC staff recommend a licence period of 10 years and have included a licence condition in the proposed licence requiring OPG to perform a PSR in accordance with REGDOC in support of OPG s next licence application. The draft LCH provides additional detail regarding expectations for the PSR including timeframes for submissions of the PSR basis document, global assessment and IIP. CNSC staff will continue to update the Commission on the performance of the Darlington NGS, including updates on the refurbishment project and completion of IIP commitments, as part of the annual CNSC Staff Regulatory Oversight Report for Canadian Nuclear Power Plants. CNSC staff will also continue to update the Commission on the performance of the Darlington NGS as part of the routine status reports on power reactors and through event initial reports as necessary Delegation of Authority The Commission has the authority to issue licences as per subsection 24(2) of the NSCA. A PROL is a Class IA licence under Part IV of the CNSC classes of licences and can only be issued by the Commission. However, the Commission can delegate certain consent approvals to another person to oversee changes to licensed activities, facilities and operations that are governed by licence conditions and the licensing basis. Clause (iii) in Part V Explanatory Notes in the PROL indicates that the LCH includes information regarding delegation of authority. During the licence period, there are day-to-day licensing and compliance decisions that need to be made within the licensing basis that are necessary to further enhance the licensee s performance and implement new requirements. It is necessary that CNSC staff be allowed to carry out this responsibility in order to provide adequate regulatory oversight of changes that are administrative in nature or are less significant and do not require a PROL amendment or Commission approval. There are two proposed licence conditions in the Darlington PROL that contain the phrase a person authorized by the Commission : LC 3.2 (Restart after a serious process failure); and LC 15.4 (Removal of regulatory hold points). e-doc (Word) July 2015 e-doc (PDF)

116 15-H8 Unprotected With respect to licence condition 3.2, CNSC staff recommend that the Commission delegate the authority for consent to restart a reactor after a serious process failure to the following CNSC staff: Director, Darlington Regulatory Program Division; Director General, Directorate of Power Reactor Regulation; and Executive Vice-President and Chief Regulatory Operations Officer. For reference, this delegation of authority was previously granted by the Commission for the Darlington NGS [5]. Regulatory Hold Points With respect to licence condition 15.4 (removal of regulatory hold points), as further described in section 3.4 of this CMD, CNSC staff recommend that the Commission delegate the authority to remove regulatory hold points for the return to service of each unit undergoing refurbishment to the Executive Vice President and Chief Regulatory Operations Officer, Regulatory Operations Branch. For reference, similar delegation of authority was previously granted by the Commission for the Bruce Power Units 1 and 2 and Point Lepreau refurbishment projects [23, 24]. Prior to releasing a regulatory hold point, CNSC staff will verify compliance and provide a report to the Executive Vice President and Chief Regulatory Operations Officer, Regulatory Operations Branch. Based on the review of this report, the Executive Vice President and Chief Regulatory Operations Officer, Regulatory Operations Branch will issue a record of decision. The same process was used successfully for the Bruce Power Units 1 and 2 and Point Lepreau refurbishment projects. For Darlington, the four regulatory hold points for the return to service of each unit undergoing refurbishment are: 1. prior to fuel load; 2. prior to guaranteed shutdown state (GSS) removal; 3. prior to exceeding 1% full power; and 4. prior to exceeding 35% full power Licence Conditions Handbook The LCH associated with the PROL provides compliance verification criteria used to determine whether the conditions listed in the licence have been met and, as indicated earlier, includes information regarding the delegation of authority. In addition, the LCH sets out how CNSC staff will assess the licensee s compliance with the licence. It provides details associated with each licence condition, such as: applicable standard or regulatory document, regulatory interpretation, compliance verification criteria, version-controlled documents, licensee s written notification documents and guidance. This structure allows e-doc (Word) July 2015 e-doc (PDF)

117 15-H8 Unprotected more freedom for the facility to evolve and update its documentation within the licensing basis; therefore CNSC staff recommend that the Commission consider the LCH in making its decision on the renewal of the Darlington NGS and accept that the Director General, Directorate of Power Reactor Regulation will be the sole process owner for modifying this staff-level document during the licence period. 6. OVERALL CONCLUSIONS AND RECOMMENDATIONS CNSC staff have concluded the following with respect to paragraphs 24(4)(a) and (b) of the Nuclear Safety and Control Act (NSCA), in that OPG: 1. is qualified to carry on the activities authorized by the licence; and 2. in carrying out the licensed activities, has made, and will continue to make adequate provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed. Therefore, CNSC staff recommend that the Commission: 1. accept CNSC staff s conclusions and exercise its authority under the NSCA to renew the licence to authorize OPG to refurbish and continue to operate the Darlington NGS from January 1, 2016 to December 31, 2025; 2. authorize OPG to operate the Darlington NGS beyond 210,000 EFPH, up to the proposed refurbishment outages to a maximum of 235,000 EFPH; and 3. authorize the delegation of authority as set out in section 5.12 of this CMD. e-doc (Word) July 2015 e-doc (PDF)

118 15-H8 Unprotected REFERENCES 1. CNSC Record of Proceedings, Including Reasons for Decision, Ontario Power Generation - Application for the Renewal of the Licence for the Darlington Waste Management Facility, March, 2013, e-doc Commission Member Document, CMD 15-M22, Regulatory Oversight Report for Ontario Power Generation Inc. s Darlington, Pickering and Western Waste Management Facilities, June , e-doc CNSC Record of Proceedings, Including Reasons for Decision, Ontario Power Generation - Environmental Screening Regarding the Proposal to Refurbish and Continue to Operate the Darlington Nuclear Generating Station, March, 2013, e-doc CNSC Environmental Assessment Screening Report, The Refurbishment and Continued Operation of the Darlington Nuclear Generating Station, Municipality of Clarington, Ontario, March 2013, e-doc CNSC Record of Proceedings, Including Reasons for Decision, Ontario Power Generation - Application to Renew the Power Reactor Operating Licence for the Darlington Nuclear Generating Station, February 2013, e-doc OPG letter, B. 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, e-doc OPG letter, B. Duncan to M. Leblanc, Darlington NGS Request for Amendment of the Darlington Nuclear Generating Station Power Reactor Operating Licence Expiry Date, June 18, 2014, e-doc CNSC Record of Proceedings, Including Reasons for Decision, Ontario Power Generation - Application to Amend the Power Reactor Operating Licence for the Darlington Nuclear Generating Station, July 29, 2014, e-doc OPG letter, B. Duncan to M. Leblanc, Darlington NGS Additional Information in Support of Application for Renewal of Darlington s Power Reactor Operating Licence (PROL) 13.01/2015, January 30, 2015, e-doc CNSC Regulatory Document, RD-360, Life Extension of Nuclear Power Plants, February 2008, e-doc IAEA Safety Standards Series, Specific Safety Guide, SSG-25, Periodic Safety Review of Nuclear Power Plants, 2013, e-doc OPG procedure, Nuclear Refurbishment Integrated Safety Review Darlington, N-PROC-LE-0005 R003, e-doc CNSC letter, F. Rinfret to D. Reiner, CNSC Assessment Darlington Integrated Safety Review Code Reviews, July 5, 2013, e-doc e-doc (Word) July 2015 e-doc (PDF)

119 15-H8 Unprotected 14. CNSC letter, F. Rinfret to D. Reiner, CNSC Assessment Darlington Integrated Safety Review Safety Factor Reports, February 18, 2014, e-doc CNSC letter, F. Rinfret to D. Reiner, CNSC Assessment of Darlington Integrated Safety Review Final ISR Report, March 31, 2014, e-doc OPG letter, D. Reiner and B. Duncan to F. Rinfret, Request for CNSC Acceptance of the Darlington NGS Global Assessment Report (GAR) and Integrated Implementation Plan (IIP), December 2, 2013, e-doc CNSC letter, F. Rinfret to D. Reiner, Request for CNSC Acceptance of the Darlington NGS Global Assessment Report (GAR) and Integrated Implementation Plan (IIP), April 17, 2014, e-doc OPG letter, D. Reiner and B. Duncan to F. Rinfret, Darlington NGS - Request for CNSC Acceptance of Updated Integrated Implementation Plan (IIP), October 31, 2014, e-doc CNSC letter, F. Rinfret to D. Reiner and B. Duncan, Darlington NGS Request for CNSC Acceptance of Updated Integrated Implementation Plan (IIP) Revision 001, December 22, 2014, e-doc OPG letter, D. Reiner and B. Duncan to F. Rinfret, Darlington NGS Request for CNSC Acceptance of Integrated Implementation Plan (IIP) Revision 002, April 27, 2015, e-doc CNSC letter, F. Rinfret to D. Reiner and B. Duncan, Darlington NGS: Request for CNSC Acceptance of Updated Integrated Implementation Plan (IIP) Revision 002 and Protocol Closure, June 1, 2015, e-doc CNSC letter, F. Rinfret to D. Reiner, Darlington NGS A Refurbishment Return to Service Program Management Plan, March 14, 2014, e-doc CNSC Summary Record of Proceedings and Decision, Bruce Power Inc. Application to Renew the Power Reactor Operating Licence for the Bruce A Nuclear Generating Station and Approval to Reload Fuel for Bruce A Units 1 and 2, October 30, 2009, e-doc CNSC Record of Proceedings, Including Reasons for Decision, New Brunswick Power Nuclear Corporation Request for Approval to Reload Fuel and Restart the Point Lepreau Nuclear Generating Station, and Application to Renew the Power Reactor Operating Licence for the Point Lepreau Nuclear Generating Station, February 16, 2012, e-doc CNSC letter, F. Rinfret and M. Santini to B. Duncan and B. Phillips, CNSC review of OPG Business Model as documented, New Action Item 2013-OPG- 4432, November 18, 2013, e-doc CNSC letter, F Rinfret to B. Duncan and D. Reiner, Darlington NGS Integrated Safety Review Plant Condition Assessment Type II Inspection Report, DRPD-A , Action Item Closure, December 11, 2014, e-doc e-doc (Word) July 2015 e-doc (PDF)

120 15-H8 Unprotected 27. CNSC letter, P. Webster to B. Duncan, Darlington NGS A Type II Compliance Inspection Report, Document Control and Records Management, Report #DRPD-A , Action Item Number , July 23, 2013, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS A Final Response to CNSC Type II Compliance Inspection Report Document Control and Records Management Report # DRPD-A , Action Item , Action Notice AN2, August 7, 2013, e-doc CNSC letter, M. Santini & F. Rinfret to B. Phillips & B. Duncan, Darlington NGS A and Pickering NGS: CNSC Type II Compliance Inspection of the Human Performance Program, Report # OPG , May 16, 2014, e-doc CNSC letter, F. Rinfret and M. Santini to B. Duncan and B. Phillips, Darlington and Pickering NGS CNSC Type II Compliance Inspection Report, Non-Licensed Operators Training Program, Report #OPG , New Action Item 2014-OPG-4907 and Closure of Action Item 2011-OPG- 2299, June 27, 2014, e-doc CNSC Regulatory Guide G-323, Ensuring the Presence of Sufficient Qualified Staff at Class I Nuclear Facilities Minimum Staff Complement, e-doc CNSC Regulatory Guide G-278, Human Factors Verification and Validation Plans, e-doc CNSC Letter, F. Rinfret to B. Duncan, DRPD-A , CNSC Type II Inspection Report: Darlington NGS A - Hours of Work Limits, October 4, 2013, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS A Implementation of Rod Based Guaranteed Shutdown State, July 9, 2013, e-doc CNSC letter, M. Santini and P.A. Webster to W.M. Elliot, CNSC Review of OPG Status Update on Fukushima Action Items, October 23, 2012, e-doc CNSC letter, F. Rinfret to M. Elliott, Darlington RD-310 Gap Assessment and Implementation Plan -Action Item 2010OPG-O5, May 3, 2013, e-doc CNSC Integrated Action Plan on the Lessons Learned from the Fukushima Daiichi Nuclear Accident, August 2013, CNSC letter, F. Rinfret to M. Elliott, Darlington Loss-of-Moderator-Heat-Sink Analysis, Action Item 2010OPG-05, March 12, 2014, e-doc CNSC letter, M. Santini and F. Rinfret to M. Elliott, Closure of Action Item 20110PG-01 - TUF Validation Work, March 25, 2014, e-doc e-doc (Word) July 2015 e-doc (PDF)

121 15-H8 Unprotected 40. OPG Problem Report D , Review of Recent Study Suggests Higher Coolant Void Reactivity, October 18, 2012, e-doc CNSC letter, G. Rzentkowski to W.M. Elliot, CNSC Large Loss of Coolant Accident Interim Position, March 25, 2011, e-doc CNSC letter, M. Santini and PA. Webster to W.M. Elliot, CNSC Review of OPG Probabilistic Safety Assessment Submissions Closure of Action Item 2011OPG-04, New Action Item 2011OPG-2956, December 22, 2011, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS: Assessment of Seismic Events Leading to Consequential Internal Flood or Internal Fire Closure of Action Item , November 7, 2014, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS Request for Acceptance of Fire Hazard Assessment (FHA) and Fire Safe Shutdown Analysis (FSSA) Reports, Closure of Action Item , January 30, 2015, e-doc CNSC letter, Darlington and Pickering NGS: Request for re-categorization of CANDU Safety Issue AA3: Computer Code and Plant Model Validation, New Action Item 2014-OPG-5632, December 10, 2014, e-doc CNSC letter, G. Rzentkowski to W.M. Elliot, Closure of Generic Action Item 00G001 Channel Voiding during a Large Loss of Coolant Accident OPG New Action Item 2012OPG-3317, July 16, 2012, e-doc CNSC letter, M. Santini and F. Rinfret, Darlington and Pickering NGS: Scaling Assessment for Channel Voiding, Closure of Action Item 2012OPG- 3317, September 5, 2014, e-doc CNSC letter, G. Rzentkowski to W.M. Elliot, Darlington and Pickering NGS Large LOCA Safety Margins Assessment of the Proposed Composite Analytical Approach, January 7, 2015, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS: CNSC Type II Compliance Inspection Report, DRPD , Environmental Qualification Program, New Action Item January 21, 2015, e-doc CNSC letter, F. Rinfret to B. Duncan DRPD-A , CNSC Type II Inspection Report: DNGS A Implementation of Pressure Boundary Program, Action Item , December 4, 2013, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS Type II Compliance Inspection Report, DRPD , Electrical Power Systems, New Action Item , November 7, 2014, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS Type II Compliance Inspection Report, Preservation of Seismic Design Basis, Report # DRPD , Action Item , June 25, e-doc e-doc (Word) July 2015 e-doc (PDF)

122 15-H8 Unprotected 53. CNSC letter, P. Webster & M. Santini to W.M. Elliott, Design Codes and Standards Effective Dates for OPG Nuclear Fleet, June 22, 2012, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS A - Type II Compliance Inspection Report, Maintenance Work Execution, Report # DRPD-A , New Action Item , January 10, 2014, e-doc CNSC letter, P.A. Webster to S.A. Seedhouse, Darlington Nuclear Generating Station A Type II Software Maintenance Inspection, New Action Item , June 7, 2011, e-doc CNSC Regulatory Document RD-334 Aging Management for Nuclear Power Plants, June 2011, e-doc CNSC Regulatory Document REGDOC Aging Management, March 2014, CNSC letter, M. Santini & F. Rinfret to W.M. Elliott, Approach to Fitness for Service Assessment for Pressure Tubes New Action Item 2014-OPG-4782, March 4, 2014, e-doc OPG letter, D. Reiner to F. Rinfret, Darlington NGS Update on Concrete Integrity, April 24, 2015, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS Type II Compliance Inspection Report: DRPD Chemistry Control Program, New Action Item October 30, 2014, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS - Type II Compliance Inspection Report, Radiation Protection - Occupational ALARA Planning and Control, Report # DRPD , Action Item , June 23, 2014, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS A - Type II Compliance Inspection Report, Radiation Protection- Worker Dose Control, Report # DRPD-A , Action Item July 24, 2013, e-doc CNSC letter, F. Rinfret to B. Duncan, CNSC Type II Compliance Inspection Report: OPG Darlington Nuclear Generating Station DRPD Quarterly Field Inspection Report First Quarter Fiscal Year , New Action Item , August 28, 2014, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS: Quarterly Field Inspection Reoprt, Second Quarter, Fiscal Year , DRPD , Action Item , December 10, 2014, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS: Scaffolding Program, Action Item , October 8, 2014, e-doc e-doc (Word) July 2015 e-doc (PDF)

123 15-H8 Unprotected 66. CNSC letter, P. Webster to B. Duncan, Darlington Nuclear Generating Station A Type II Compliance Inspection Report, Effluent Monitoring Program, Report #DRPD-A , New Action Item , June 15, 2012, e-doc OPG letter, P. F. Tremblay to T.E. Schaubel & P.A. Webster, 2008 Results of Radiological Environmental Monitoring Programs, April 22, 2009, e-doc OPG letter, L. Swami to T.E. Schaubel & P.A. Webster, 2009 Results of Radiological Environmental Monitoring Programs, April 26, 2010, e-doc OPG letter, L. Swami to T.E. Schaubel & P.A. Webster, 2010 Results of Radiological Environmental Monitoring Programs, April 21, 2011, e-doc OPG letter, L. Swami to M. Santini & P.A. Webster, 2011 Results of Radiological Environmental Monitoring Programs, April 26, 2012, e-doc OPG letter, B. Reuber to M. Santini & F. Rinfret, 2012 Results of Radiological Environmental Monitoring Programs, April 23, 2013, e-doc OPG letter, B. Reuber to M. Santini & F. Rinfret, 2013 Results of Environmental Monitoring Programs, April 25, 2014, e-doc OPG letter, B Reuber to M. Santini & F. Rinfret, 2014 Results of Environmental Monitoring Program, April 24, 2015, e-doc OPG letter, D. Reiner and B. Duncan to F. Rinfret, OPG Submission of the DNGS Environmental Assessment Follow-up Program (Revision 001), October 2, 2013, e-doc Commission Member Document, CMD 14-M72.1, Exercise Unified Response Update, November 5, 2014, e-doc Commission Member Document, CMD 12-M17, Update on the Public Alerting System for Pickering City and the Durham Region, March 28, 2012, e-doc Commission Member Document, CMD 15-M13, Distribution of Potassium Iodide (KI) Tablets, March 10, 2014, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS Type II Compliance Inspection Report, Testing of the Implementation of Emergency Measures and Compliance with Consolidated Nuclear Emergency Plan (CNEP), Report # DRPD-A , New Action Item , January 10, 2014, e-doc CNSC letter, P.A. Webster to B. Duncan, Darlington NGS A Type II Compliance Inspection Report, Hazardous Waste Management, Report #DRPD-A , December 21, 2012, e-doc Commission Member Document, Ontario Power Generation Inc. s Consolidated Financial Guarantee, October 24, 2012, e-doc e-doc (Word) July 2015 e-doc (PDF)

124 15-H8 Unprotected 81. CNSC letter, P.A. Webster to B. Duncan, Darlington NGS A Transportation of Class 7 Dangerous Goods Inspection Report # DRPD-A , October 29, 2012, e-doc CNSC letter, M. Santini to G. Jager, Pickering NGS-A and B: Type II Compliance Inspection Report: Packaging and Transportation of Nuclear Substances at Pickering Nuclear, Report # PRPD-PICKAB-163, March 1, 2013, e-doc CNSC Notice of Public Hearing, May 26, 2015, e-doc CNSC letter, P. A. Webster to B. Duncan, Darlington NGS A Type II Compliance Inspection Report, Heavy Water Management Building and Tritium Removal Facility T1201 Outage, Report #DRPD-A , September 7, 2012, e-doc CNSC letter, F. Rinfret to B. Duncan, Darlington NGS - CNSC Type II Inspection Report: Tritium Removal Facility T1301 Planned Maintenance Outage, DRPD , April 24, 2014, e-doc CNSC letter, P. A. Webster to S. Seedhouse, Darlington NGS A - CNSC Compliance Inspection Report, Darlington Tritium Removal Facility Outage, DRPD-SO-2009-T , New Action Items and , July 13, 2009, e-doc Commission Member Document, CMD 14-M30, "Study of Consequences of a Hypothetical Severe Nuclear Accident and Effectiveness of Mitigation Measures, June 4, 2014, e-doc Commission Member Document, CMD 15-M10, An Update on Consequences of a Hypothetical Severe Nuclear Accident and Effectiveness of Mitigation Measures, March 9, 2015, e-doc Commission Member Document, CMD 15-M15, Independent Environmental Monitoring Program (IEMP), March 25, 015, e-doc CNSC Regulatory Document, REGDOC-2.3.3, Periodic Safety Reviews, April 2015, Commission Member Document, CMD 15-M12, REGDOC-2.3.3, Periodic Safety Reviews, March 10, 2014, e-doc e-doc (Word) July 2015 e-doc (PDF)

125 15-H8 Unprotected GLOSSARY Acronym AAR AI AIA AIMS ALARA BDBA BE BOP BTI CAA CANDU CEAA CMD CNEP CNSC COG CSA CSI CFVS CRFR CT CVC DFO DRL DWMF EIR EME EPC Term Alkaline Aggregate Reaction Action Item Authorized Inspection Agency Abnormal Incidents Manual As Low As Reasonably Achievable Beyond Design Basis Accident Below Expectations Balance of Plant Business Transformation Initiative Composite Analytical Approach Canada Deuterium Uranium Canadian Environmental Assessment Act Commission Member Document Consolidated Nuclear Energy Plan Canadian Nuclear Safety Commission CANDU Owners Group Canadian Standards Association Candu Safety Issue Containment Filtered Venting System Cost Recovery Fees Regulations Calandria Tube Compliance Verification Criteria Fisheries and Oceans Canada Derived Release Limit Darlington Waste Management Facility Event Initial Report Emergency Mitigating Equipment Engineer, Procure Construct e-doc (Word) July 2015 e-doc (PDF)

126 15-H8 Unprotected EPG EFPH EMS EOP EPRI EQ ERA ERO EUR FAI FCLMP FHA FRC FS FSSA GAI GAR GSS HTS HWMB IAEA IEMP I&C IIP ISR KI LBB LCH LCMP LOCA LRF Emergency Power Generator Equivalent Full Power Hours Environmental Management System Emergency Operating Procedures Electric Power Research Institute Environmental Qualification Environmental Risk Assessment Emergency Response Organization Exercise Unified Response Fukushima Action Item Fuel Channel Life Management Project Fire Hazard Assessment Funding Review Committee Fully Satisfactory Fire Safe Shutdown Analysis Generic Action Item Global Assessment Report Guaranteed Shutdown State Heat Transport System Heavy Water Management Building International Atomic Energy Agency Independent Environmental Monitoring Program Instrumentation and Control Integrated Implementation Plan Integrated Safety Review Potassium Iodide Leak Before Break Licence Conditions Handbook Life Cycle Management Plan Loss of Coolant Accident Large Release Frequency e-doc (Word) July 2015 e-doc (PDF)

127 15-H8 Unprotected msv MOL MOU MWe NDE NEW NGS NOP NPP NRCan NRF NSCA NSR OHSA OP&Ps OPEX OPG PARs PIDP PIP PFP PRA PROL PSA PSHA PSR PSVS PT R&D RD RWC Millisievert Ministry of Labour Memorandum of Understanding Megawatts Non-Destructive Examination Nuclear Energy Worker Nuclear Generating Station Neutron Overpower Protection Nuclear Power Plant Natural Resources Canada Nuclear Response Force Nuclear Safety and Control Act Nuclear Security Regulations Occupational Health and Safety Act Operating Policies and Principles Operating Experience Ontario Power Generation Inc. Passive Autocatalytic Recombiners Public Information and Disclosure Program Periodic Inspection Program Participant Funding Program Probabilistic Risk Assessment Power Reactor Operating Licence Probabilistic Safety Assessment Probabilistic Seismic Hazard Analysis Periodic Safety Review Powerhouse Steam Venting System Pressure Tube Research and Development Regulatory Document Retube Waste Container e-doc (Word) July 2015 e-doc (PDF)

128 15-H8 Unprotected RWPB RWSB SA SAMG SAT SBLOCA SCA SCDF SDC SIO SOE SSC STOP TBq TCC TSSA TPR TRF TUF WFOL Retube Waste Processing Building Retube Waste Storage Building Satisfactory Severe Accident Management Guidelines Systematic Approach to Training Small Break Loss of Coolant Accidents Safety and Control Area Severe Core Damage Frequency Shutdown Cooling Safety Improvement Opportunity Safe Operating Envelope Structures, Systems and Components Shield Tank Overpressure Protection Terabecquerel Training Change Control Technical Standards and Safety Authority Third Party Review Tritium Removal Facility Two Unequal Fluids Waste Facility Operating Licence e-doc (Word) July 2015 e-doc (PDF)

129 15-H8 Unprotected A. RISK RANKING The CNSC uses a risk-informed regulatory approach in the management and control of regulated facilities and activities. CNSC staff have therefore established an approach based on CSA guideline, CAN/CSA-Q850, Risk Management: Guideline for Decision Makers, to risk rank specific issues, events and areas of regulatory interest. This process conforms to other international standards as well, such as IAEA Safety Guides GS-G-1.3, Regulatory Inspection of Nuclear Facilities and Enforcement by the Regulatory Body, and GS-G-1.2, Review and Assessment of Nuclear Facilities by the Regulatory Body. This approach, referred to as the CNSC Risk Informed Decision Making Process, has been applied to each SCA at a generic level to determine relative risk rankings as they relate to the given facility and activity types. The following matrix provides a high-level overview of risk ranking, and the management and monitoring approach associated with the various degrees of risk. APPROACH TO ASSESSING AND MANAGING POTENTIAL RISK CONSEQUENCE MANAGEMENT/MONITORING APPROACH Significant Impact Moderate Impact Considerable management of risk is required Occasional monitoring Must manage and monitor risk with occasional control Management effort is recommended Low Impact Random monitoring Regular monitoring Probability of Occurrence Extensive management is essential. Constant monitoring and control Management effort and control is required Manage and monitor Unlikely to Occur Might Occur Expected to Occur RISK RANKING SCALE L Low Risk M Moderate Risk H High Risk Due to the complex nature of power reactors, this simplified approach gives insufficient differentiation between the areas reviewed. Therefore, the CNSC Risk Informed Decision Making process has been applied to generate relative risk rankings for the purpose of determining a risk estimate for each SCA. The table below gives the relative risk rankings (normalized weight factor) for the SCAs determined by this process. e-doc (Word) July 2015 e-doc (PDF)

130 15-H8 Unprotected Functional Area Safety and Control Area Normalized Weight Factor Management System Management Human Performance Management Operating Performance Facility and Equipment Safety Analysis Physical Design Fitness for Service Core Control Processes Radiation Protection Conventional Health and Safety Environmental Protection Emergency Management and Fire Protection Waste Management* Security* Safeguards and Non-Proliferation* Packaging and Transport* *These rating are averages used for this exercise and subject to change Over the span of a year, individual inspection findings at a facility are risk ranked as high, medium or low. When these are combined, a rating for each specific area can be found for that year. These specific area ratings can then be grouped to determine a risk ranking for an entire SCA. Then the annual integrated plant rating is found by integrating the scores for the individual SCAs and factoring in licensee s past performance, the weighing factors, and expert judgment. Generally, a high-risk SCA would be subject to increased regulatory scrutiny and control (e.g., high frequency of inspection) while a low-risk SCA would generally require minor verification and control. These risk rankings are not static and will change over time for a given facility and activities (e.g. phase, age, condition of plant, evolution of program knowledge and understanding, etc.). e-doc (Word) July 2015 e-doc (PDF)

131 15-H8 Unprotected B. RATING LEVELS The following rating levels reflect a recent transition in the rating terminology used by the CNSC. PREVIOUS RATING LEVEL DESCRIPTION (CMD 02-M5) NEW RATING LEVEL DESCRIPTION A Exceeds expectations FS Fully Satisfactory B Meets expectations SA Satisfactory C Improvement is required BE Below Expectations D E This area is seriously compromised UA Unacceptable Breakdown Fully Satisfactory (FS) Safety and control measures implemented by the licensee are highly effective. In addition, compliance with regulatory requirements is fully satisfactory and compliance within the SCA or specific area exceeds requirements and CNSC expectations. Compliance is stable or improving, and any problems or issues that arise are promptly addressed. Satisfactory (SA) Safety and control measures implemented by the licensee are sufficiently effective. In addition, compliance with regulatory requirements is satisfactory. Compliance within the area meets requirements and CNSC expectations. Any deviation is only minor, and any issues are considered to pose a low risk to the achievement of regulatory objectives and CNSC expectations. Appropriate improvements are planned. Below Expectations (BE) Safety and control measures implemented by the licensee are marginally ineffective. In addition, compliance with regulatory requirements falls below expectations. Compliance within the area deviates from requirements or CNSC expectations to the extent that there is a moderate risk of ultimate failure to comply. Improvements are required to address identified weaknesses. The licensee or applicant is taking appropriate corrective action. Unacceptable (UA) Safety and control measures implemented by the licensee are significantly ineffective. In addition, compliance with regulatory requirements is unacceptable, and is seriously compromised. Compliance within the overall area is significantly below requirements or CNSC expectations, or there is evidence of overall non-compliance. Without corrective action, there is a high probability that the deficiencies will lead to an unreasonable risk. Issues are not being addressed effectively, no appropriate corrective measures have been taken, and no alternative plan of action has been provided. Immediate action is required. e-doc (Word) July 2015 e-doc (PDF)

132 15-H8 Unprotected C. SAFETY AND CONTROL AREA FRAMEWORK C.1 Safety and Control Areas Defined The safety and control areas identified in section 2.3, and discussed in summary in sections 4.1 through 4.14 are comprised of specific areas of regulatory interest which vary between facility types. The following table provides a high-level definition of each SCA. Functional Area Management Facility and Equipment SAFETY AND CONTROL AREA FRAMEWORK Safety and Control Area Management System Human Performance Management Operating Performance Safety Analysis Physical Design Fitness for Service Definition Covers the framework which establishes the processes and programs required to ensure an organization achieves its safety objectives and continuously monitors its performance against these objectives and fostering a healthy safety culture. Covers activities that enable effective human performance through the development and implementation of processes that ensure that licensee staff is sufficient in number in all relevant job areas and that licensee staff have the necessary knowledge, skills, procedures and tools in place to safely carry out their duties. This includes an overall review of the conduct of the licensed activities and the activities that enable effective performance. Maintenance of the safety analysis that supports that overall safety case for the facility. Safety analysis is a systematic evaluation of the potential hazards associated with the conduct of a proposed activity or facility and considers the effectiveness of preventative measures and strategies in reducing the effects of such hazards. Relates to activities that impact on the ability of systems, components and structures to meet and maintain their design basis given new information arising over time and taking changes in the external environment into account. Covers activities that impact on the physical condition of systems, components and e-doc (Word) July 2015 e-doc (PDF)

133 15-H8 Unprotected SAFETY AND CONTROL AREA FRAMEWORK Functional Area Core Control Processes Safety and Control Area Radiation Protection Conventional Health and Safety Environmental Protection Emergency Management and Fire Protection Waste Management Security Safeguards and Non-Proliferation Definition structures to ensure that they remain effective over time. This includes programs that ensure all equipment is available to perform its intended design function when called upon to do so. Covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations. The program must ensure that contamination levels and radiation doses received by individuals are monitored, controlled and maintained as low as reasonably achievable (ALARA). Covers the implementation of a program to manage workplace safety hazards and to protect personnel and equipment. Covers programs that identify, control and monitor all releases of radioactive and hazardous substances and effects on the environment from facilities or as the result of licensed activities. Covers emergency plans and emergency preparedness programs which exist for emergencies and for non-routine conditions. This also includes any results of exercise participation. Covers internal waste-related programs which form part of the facility s operations up to the point where the waste is removed from the facility to a separate waste management facility. Also covers the planning for decommissioning. Covers the programs required to implement and support the security requirements stipulated in the regulations, in their licence, in orders, or in expectations for their facility or activity. Covers the programs and activities required for the successful implementation of the obligations arising from the Canada/IAEA safeguards agreements as well as all other measures arising from the Treaty on the Non- Proliferation of Nuclear Weapons. e-doc (Word) July 2015 e-doc (PDF)

134 15-H8 Unprotected Functional Area SAFETY AND CONTROL AREA FRAMEWORK Safety and Control Area Packaging and Transport Definition Programs that cover the safe packaging and transport of nuclear substances to and from the licensed facility. C.2 Specific Areas for Nuclear Power Plants The following table identifies the specific areas that comprise each SCA for the Darlington NGS: Functional Area SPECIFIC AREAS FOR THIS FACILITY TYPE Safety and Control Area Specific Areas Management Management System Management system Organization Performance assessment, improvement and management review Operating experience (OPEX) Change management Safety culture Configuration management Records management Management of contractors Business continuity Human Performance Management Operating Performance Human performance program Personnel training Personnel certification Initial certification examinations and requalification tests Work organization and job design Fitness for duty Conduct of licensed activity Procedures Reporting and trending Outage management performance Safe operating envelope Severe accident management and recovery Accident management and recovery e-doc (Word) July 2015 e-doc (PDF)

135 15-H8 Unprotected Functional Area Facility and Equipment Core Control Processes SPECIFIC AREAS FOR THIS FACILITY TYPE Safety and Control Area Specific Areas Safety Analysis Deterministic safety analysis Hazard analysis Probabilistic safety analysis Criticality safety Severe accident analysis Management of safety issues (including R&D programs) Physical Design Design governance Site characterization Facility design Structure design System design Component design Fitness for Service Equipment fitness for service / equipment performance Maintenance Structural integrity Aging management Chemistry control Periodic inspection and testing Radiation Protection Application of ALARA Worker dose control Radiation protection program performance Radiological hazard control Estimated dose to public Conventional Health and Safety Environmental Protection Performance Practices Awareness Effluent and Emissions Control (releases) Environmental Management System (EMS) Assessment and Monitoring Protection of the Public Environmental Risk Assessment e-doc (Word) July 2015 e-doc (PDF)

136 15-H8 Unprotected Functional Area SPECIFIC AREAS FOR THIS FACILITY TYPE Safety and Control Area Emergency Management and Fire Protection Waste Management Security Safeguards and Non- Proliferation Packaging and Transport Specific Areas Conventional Emergency Preparedness and Response Nuclear Emergency Preparedness and Response Fire Emergency Preparedness and Response Waste Characterization Waste Minimization Waste Management Practices Decommissioning Plans Facilities and Equipment Response Arrangements Security Practices Drills and Exercises Nuclear Material Accountancy and Control Access and Assistance to the IAEA Operational and Design Information Safeguards Equipment, Containment and Surveillance Import and Export Package Design and Maintenance Packaging and Transport Registration for Use e-doc (Word) July 2015 e-doc (PDF)

137 15-H8 Unprotected D. SUPPORTING DETAILS D.1 Radiation Protection Details of effective doses to workers from activities conducted at the Darlington NGS for the period are provided below. Effective Dose to Workers Figure 1 presents the annual effective dose distribution per dose range at the Darlington NGS for the period On average, most workers (~88%) received an annual effective dose below 1 msv. Figure 1 Effective Dose Distribution to Workers Dose data provided by OPG Based on Darlington NGS tri-cycle outage schedule, there were two outages per year in 2010 and 2013, and one outage per year for each of the others. The numbers of workers receiving higher doses in these years reflect this fact. For 2013, in addition to the two planned outages, Darlington NGS also experienced four unplanned outages. In addition to the number of outages, the nature of the higherhazard radiological work performed during the outages combined to yield an increased number of workers receiving higher doses. e-doc (Word) July 2015 e-doc (PDF)

138 15-H8 Unprotected Figure 2 shows that the maximum individual effective dose during the period was msv; this occurred in 2010, which was a two outage year. This dose was received by a worker supporting instrument line and feeder cabinet inspection work. The average effective worker doses, considering non-zero results only, ranged from 1.16 to 2.25 msv between 2008 and Again, the increase in values being a reflection of the increased number of outages and the nature of the work performed. Figure 2 Maximum and Average Effective Dose to the Workers *Average non-zero dose Dose data provided by OPG Collective Dose to Workers Figures 3 and 4 illustrate the distribution of annual collective effective dose per operational state (routine versus outage) and the distribution of dose by internal and external doses for Darlington NGS. As mentioned previously, based on Darlington NGS tri-cycle outage schedule, there were two outages per year in 2010 and 2013, and one outage per year for each of the others. The performance of two extended planned outages and four forced outages in 2013 account for higher collective doses compared to other years. The high dose maintenance and inspection activities performed during the 2013 and 2014 planned outages included single fuel channel replacement, boiler inspections, feeder inspections, and primary heat transport valve maintenance. The dose e-doc (Word) July 2015 e-doc (PDF)

139 15-H8 Unprotected associated with this challenging outage work accounted for approximately (~)91% of the total station dose in 2013, and ~ 82% in In contrast, routine operations accounted for ~9% and ~18% of the total collective dose in the respective years. Additionally, for 2013, internal dose was only ~13% of the total collective dose while in 2014 it was ~ 15%. Figure 3: Collective effective dose to workers by operational state for Darlington NGS Dose data provided by OPG e-doc (Word) July 2015 e-doc (PDF)

140 15-H8 Unprotected Figure 4: Internal and external dose to workers for Darlington NGS Dose data provided by OPG e-doc (Word) July 2015 e-doc (PDF)

141 Environmental Assessment Information Report: Ontario Power Generation Darlington Nuclear Generating Station Licence Renewal June 2015 e-doc: (WORD) e-doc: (PDF)

142 REVISION HISTORY The following table identifies the revision history of this document. Revision number Change Summary of changes Date 000 Initial release N/A 001

143 June 2015 Environmental Assessment Information Report EXECUTIVE SUMMARY The Canadian Nuclear Safety Commission (CNSC) conducts environmental assessments (EA) under the Nuclear Safety and Control Act (NSCA) for all projects in accordance with its mandate to ensure the protection of the environment and the health of persons. This EA Information Report (EA Report), written by CNSC staff for the Commission and the public, describes the findings of the EA under the NSCA completed for the application by Ontario Power Generation (OPG) to renew their existing CNSC operating licence for, and complete proposed refurbishment activities on all units of, the Darlington Nuclear Generating Station (NGS). This EA under the NSCA includes CNSC staff s assessment of the licence renewal application and the documents submitted in support of the application, annual monitoring reports, the results of previous studies, compliance verification activities conducted at the Darlington NGS, as well as the findings of CNSC s Independent Environmental Monitoring Program. This EA Report focuses on items that are of current public and regulatory interest such as radiological releases to the environment, public dose, and updates on actions previously requested by the Commission with respect to specific environmental components. CNSC staff s findings from this EA under the NSCA include, but are not limited to, the following: OPG s environmental protection programs meet CNSC regulatory requirements. The maximum effective dose to a member of the public from activities conducted at the Darlington site remains less than 1% of the regulatory limit of 1 millisievert (msv) per year. OPG s radiological releases to the environment (air and water) remain well below the derived release limits. The results of the CNSC s Independent Environmental Monitoring Program confirm that the public and the environment in the vicinity of the Darlington site are protected from the releases of the facility. Based on the EA under the NSCA conducted for this application, CNSC staff conclude that OPG has and will continue to make adequate provision for the protection of the environment and the health of persons. i

144 June 2015 Environmental Assessment Information Report TABLE OF CONTENTS EXECUTIVE SUMMARY... i 1. INTRODUCTION Purpose Background REGULATORY OVERSIGHT Environmental Protection Programs Environmental Assessment Reviews UPDATE ON THE STATUS OF THE ENVIRONMENT Previous Actions Requested by the Commission Fisheries Act Authorization Thermal Effects Studies Groundwater Protective Action Levels in Foodstuffs During Emergencies Human Health Estimated Dose to the Public Radiation and Incidence of Cancer Risk Tritium and Potential Health Impacts Radiological Releases Accidents and Malfunctions Management of Radioactive Waste CNSC INDEPENDENT ENVIRONMENTAL MONITORING PROGRAM IEMP for Darlington Site Results CONCLUSION ACRONYMS REFERENCES... 31

145 June 2015 Environmental Assessment Information Report 1. INTRODUCTION 1.1. Purpose The purpose of this environmental assessment (EA) Information Report (EA Report) is to document the results of the EA conducted under the Nuclear Safety and Control Act (NSCA) for the application by Ontario Power Generation (OPG) to renew their existing licence for, and complete proposed refurbishment activities on all units of, the Darlington Nuclear Generating Station (NGS). The EA under the NSCA was conducted to determine whether OPG has and will continue to make adequate provision for the protection of the environment and the health of persons. This EA Report is based on information submitted by OPG and work completed by Canadian Nuclear Safety Commission (CNSC) staff, and includes the following: regulatory oversight (section 2) update on the status of the environment (section 3) Independent Environmental Monitoring Program results (section 4) 1.2. Background The Darlington NGS is located in the Province of Ontario on the north shore of Lake Ontario, in the Municipality of Clarington and Regional Municipality of Durham. The facility is owned and operated by the licensee, OPG, a Canadian corporation, whose head office is located in Toronto, Ontario. The Darlington NGS (figure 1) consists of four 881 megawatt Canada Deuterium Uranium (CANDU) reactors which came into service between 1990 and The Darlington site is also home to a Tritium Removal Facility (TRF) which is designed to reduce levels of radioactive tritium from the heavy water used in the moderator and primary cooling circuit. The Darlington power reactor operating licence, PROL 13.01/2015, expires on December 31, OPG has submitted an application for the renewal of the operating licence and to complete the proposed refurbishment activities on all units of the Darlington NGS. Refurbishment is a multi-year program to enable the replacement of life-limiting components such as fuel channels, and to make safety improvements to the plant, programs, and processes. 1

146 June 2015 Environmental Assessment Information Report Figure 1: Aerial photo of Darlington NGS 2. REGULATORY OVERSIGHT The CNSC regulates nuclear facilities and activities in Canada to prevent unreasonable risk to the environment in a manner that is consistent with Canadian environmental policies, acts (including the NSCA) and regulations, and with Canada s international obligations. To meet the CNSC s stringent regulatory requirements, OPG is responsible for implementing and maintaining environmental protection programs that identify, control and monitor all releases of radioactive and hazardous substances and effects on the environment, including the public, from the Darlington NGS. The environmental protection programs must comply with, or have implementation plans in place to comply with, the requirements set out in: CNSC Regulatory Document REGDOC 2.9.1, Environmental Protection Policies, Programs and Procedures [1] CSA N Update No 1., Guidelines for calculating derived release limits for radioactive material in airborne and liquid effluents for normal operation of nuclear facilities [2] CSA N , Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills [3] CSA N , Effluent Monitoring Program at Class I Nuclear Facilities and Uranium Mines and Mills [4] CSA N , Environmental risk assessment at Class I nuclear facilities and uranium mines and mills [5] OPG is required to submit to the CNSC an annual environmental monitoring report that details the results of the environmental protection programs related to the operations of the Darlington 2

147 June 2015 Environmental Assessment Information Report NGS. The monitoring programs include both radiological and hazardous substances and quantify the effect on human and non-human biota. These annual reports are publicly accessible on OPG s external website ( CNSC staff reviewed and assessed OPG s environmental protection programs against regulatory requirements mentioned above. Furthermore, CNSC staff completed regular compliance verification activities (e.g., inspections, audits, reviews) to ensure OPG s environmental protection programs continue to meet CNSC regulatory requirements. Based on these reviews and inspections, CNSC staff conclude that OPG has made adequate provisions for the protection of the environment and the health of people. The following sections provide information on CNSC s regulatory oversight of environmental protection programs at the Darlington NGS. Further information can be found in section 4.9 of the Darlington Licence Renewal Commission Member Document (CMD) 15-H8 [6] and the draft Licence Condition Handbook (LCH) found in Part Two of the CMD Environmental Protection Programs This section covers the following environmental protection programs: Environmental Risk Assessment Environmental Management System Effluent and Emissions Monitoring Environmental Monitoring Environmental Risk Assessment In order to design and validate the core environmental protection programs (e.g., environmental management systems, effluent and emissions monitoring and control, environmental monitoring), an Environmental Risk Assessment (ERA) must be completed. An ERA is a systematic process used to identify, quantify and characterize the risk posed by contaminants and physical stressors in the environment on human and non-human biota, including the magnitude and extent of the potential effects. An ERA is composed of an ecological risk assessment and human health risk assessment. OPG completed an ERA that was reviewed and accepted by CNSC staff as part of the Darlington Refurbishment and Continued Operations Environmental Assessment (EA) conducted under the Canadian Environmental Assessment Act, 1992 (CEAA 1992). For further information on the EA, please refer to section 2.2 of this EA Report. With the publication of CSA standard N288.6 [5] in 2012, OPG has developed an implementation plan to ensure the previous ERAs meet the requirements outlined in this standard. This plan involves a gap analysis to compare the requirements of N288.6 against the ERA from the Darlington Refurbishment and Continued Operations CEAA EA. Based on the outcome of the gap analysis, OPG will revise the ERA, as required, to meet N288.6 requirements. OPG has committed to complete this work by December This timeline is acceptable to CNSC staff. 3

148 June 2015 Environmental Assessment Information Report Environmental Management System An Environmental Management System (EMS) provides a framework for action with respect to environmental protection. This includes the overall management of the prevention of unreasonable risk to the environment through integrated activities. Such activities include the management of releases (radiological and non-radiological releases), wastes (all levels of radioactive waste), training and public information. As a whole, an EMS addresses effective control measures on releases and wastes to prevent or mitigate environmental effects in the context of pollution prevention. The demonstration of the effectiveness of controls through effluent and environmental monitoring activities/programs is a major element of an EMS. OPG has established and implemented an EMS in accordance with CNSC REGDOC-2.9.1, Environmental Protection Programs, Policies and Procedures [1], and is registered to the CSA ISO 14001: 2004 Standard, Environmental Management Systems Requirements with Guidance for Use. While registration / certification to this international standard is not required by the CNSC, it is one measure of verification with CNSC requirements and expectations in that the certification indicates recognition of the OPG s EMS by a third party. OPG s EMS and its supporting governing documents establish the provision of the protection of the environment at the Darlington NGS and continual improvement of environmental performance as required by CNSC REGDOC Effluent and Emissions Control and Monitoring Effluent and emissions monitoring is the primary indicator of performance in terms of releases to air, surface waters, groundwater and soils from both facility operations and waste management activities. This type of monitoring addresses both the nature and quantities of releases of nuclear and hazardous substances (including wastes). OPG continues to implement and maintain an effluent and emissions monitoring program at the Darlington NGS as required by the Class I Nuclear Facilities Regulations. OPG also has an effluent control program that defines the methods and procedures for controlling and monitoring radioactive and hazardous substances, identifying and monitoring discharge pathways for releases to the environment, and maintaining releases within pre-established limits. Through reviews and inspections of OPG s effluent and emissions control and monitoring programs, CNSC staff are confident that the control, monitoring and reporting of releases at the Darlington NGS are well developed and are in compliance with regulatory requirements. Furthermore, OPG has committed to implement the new CSA standard N [4] by December 1, This timeline is acceptable to CNSC staff. Environmental Monitoring An environmental monitoring program is designed to measure radioactivity and radiation in the vicinity of the Darlington NGS. Based on this program, environmental samples from different pathways of the food chain are collected from various offsite locations and analyzed. Data from the program are also used to assess public doses resulting from the routine operation of the Darlington NGS, and to verify predictions made in ERAs. OPG continues to implement and maintain an environmental monitoring program at the Darlington NGS. Since the implementation of the CSA standard N [3] in 2013, OPG 4

149 June 2015 Environmental Assessment Information Report expanded its program scope to encompass protection of both the public and the environment from nuclear substances, hazardous substances, and physical stressors. Through reviews and inspections of OPG s environmental monitoring program, CNSC staff are confident that OPG continues to meet regulatory requirements and have concluded that OPG has made adequate provisions for the protection of the environment and the health of persons Environmental Assessment Reviews In March 2013, an EA under the CEAA 1992 was completed for the proposed refurbishment and continued operation of the Darlington NGS. The CNSC and Fisheries and Oceans Canada (DFO) were the Responsible Authorities (RAs) for the EA. As part of the Responsible Resource Development initiative, the CEAA 1992 was repealed when the new Canadian Environmental Assessment Act, 2012 (CEAA 2012) came into force on July 6, In accordance with subsection 124 (2) of the CEAA 2012, the Minister of the Environment designated the Darlington NGS Refurbishment and Continued Operation EA to be completed under the requirements of the CEAA CNSC and DFO staff prepared an EA Screening Report [7] on the Refurbishment and Continued Operation of the Darlington NGS. All project activities and works required for the refurbishment and life extension of the Darlington NGS are part of the scope of work assessed in the EA Screening Report. The Commission issued a Record of Proceedings, including Reasons for Decision for the Darlington Refurbishment and Continued Operations EA [8] concluding that the project, taking into account the implementation of appropriate mitigation measures identified, is not likely to cause significant adverse environmental effects. The Commission also requested a number of actions to be completed by OPG and CNSC staff in support of this licence renewal. The EA-related actions are addressed in section 3. DFO, as the other RA for this EA, reached the same conclusion of no likely significant adverse environmental effects. EA Follow-up Monitoring Program The CEAA EA identified the need for an EA follow-up monitoring program (FUMP) designed to verify the EA predictions and the effectiveness of mitigation measures. OPG has developed an EA FUMP in consultation with CNSC staff, DFO and Environment Canada (EC) to ensure that it provides adequate controls for the protection of the environment and the public [9]. The public and Aboriginal groups were also provided the opportunity to review the draft EA FUMP through a 30-day public consultation period held by the CNSC. OPG continues to work with CNSC, DFO and EC staff on the detailed sampling plans for the EA FUMP elements. The EA FUMP includes the following program elements, as listed in table 1. 5

150 June 2015 Environmental Assessment Information Report Table 1: Follow-up program elements Program element Environmental component Description of follow-up program element 1 Surface water Review the Darlington NGS effluent monitoring program relative to the applicable CSA standards and subsequent confirmation through applicable ERA results to verify EA predictions related to liquid effluents. 2 Surface water Conduct a Stormwater Control Study for areas subject to refurbishment activities within the Protected Area during the Refurbishment of the first unit for two representative storm events (spring and summer storm) to confirm that the Project has not adversely affected storm water quality. Expected timing and duration Coordinate with OPG s review of new standards against current programs. One season of monitoring during the Refurbishment Phase. Determine need for additional monitoring based on results. 3 Aquatic habitat / biota Analyze the stormwater based on historical findings, including, but not limited to, Municipal/Industrial Strategy for Abatement (MISA) parameters such as total suspended solids, total phosphorus, aluminum, iron, oil and grease, ammonia, ammonium and biological oxygen demand. Monitor data on cooling water discharge temperature and plume characteristics and interpret in relation to fish habitat and susceptibility of Valued Ecosystem Component (VEC) species. Compare temperature criteria and other assessment metrics based on Griffiths (1980) with the results of the CANDU Owners Group (COG) study examining thermal effects to round whitefish eggs (underway by others). Two monitoring periods (not withstanding any additional monitoring to be developed as part of an adaptive management plan): one winter season (November to April) during the Refurbishment Phase one winter season (November to April) following restart of all reactors The comparison with the COG study will occur once the study is published). 6

151 June 2015 Environmental Assessment Information Report Program Environmental element component 4 Aquatic habitat / biota 5 Malfunctions and accidents 6 Effects of the environment on the project Description of follow-up program element Monitor entrainment and impingement mortality associated with Darlington NGS intake. Design changes related to safety improvement opportunities (SIOs) will reduce accident frequency achievable. The assignment of probabilities to represent the SIO design changes is judged to be sufficient to approximate the reduction in accident frequency achievable. Per the requirements of CNSC S-294, the station probabilistic risk assessment (PRA) will be updated to reflect the detailed design and asinstalled configuration prior to bringing refurbished units back on-line. Undertake a full review of available documentation regarding fill materials and their liquefaction potential in the Protected Area. Should sufficient verification not be realized for the prediction of low liquefaction potential, undertake a liquefaction assessment of fill materials as appropriate. Expected timing and duration Program will comprise three components (not withstanding any additional monitoring to be developed as part of an adaptive management plan): entrainment monitoring with larger sample size and invertebrate component prior to refurbishment outage benthic invertebrate community study prior to refurbishment outage impingement and entrainment two years of monitoring following restart of all reactors Prior to bringing refurbished units back on-line with updates provided to CNSC as part of this process. Prior to bringing refurbished units back on-line. 7

152 June 2015 Environmental Assessment Information Report In addition to the CEAA EA, another element of refurbishment planning was the completion of an Integrated Safety Review (ISR) of the Darlington NGS in accordance with the CNSC Regulatory Document RD-360, Life Extension of Nuclear Power Plants [10]. The results of the EA (e.g., mitigation, follow-up) and the ISR are incorporated into an Integrated Implementation Plan (IIP) that describes the program for corrective actions and safety improvements. CNSC staff have reviewed the IIP [11] to ensure OPG has captured all EA mitigation measures and EA FUMP elements. These elements will be implemented and completed in the appropriate timeframe committed to in the IIP based on the EA Screening Report and EA FUMP. Further information can be found in section 3 of the Darlington Licence Renewal CMD 15-H8 [6]. 3. UPDATE ON THE STATUS OF THE ENVIRONMENT The following sections of the EA Report include summaries of project-environment interactions that were assessed by CNSC staff and were deemed to be of specific public and/or regulatory interest including radiological releases to the environment, public dose calculations, and updates on actions previously requested by the Commission. It should be noted that all environmental components are regularly reviewed through mandatory reporting and CNSC compliance verification activities. These reviews were used by CNSC staff to reach its conclusion that OPG continues to make adequate provisions at the Darlington NGS to protect the environment and health of persons Previous Actions Requested by the Commission The Record of Proceedings, including Reasons for Decision for the Darlington Refurbishment and Continued Operations EA [8] directed CNSC staff and OPG to provide the Commission with updates on a number of ongoing environmental activities in support of this licensing process. CNSC staff have completed these actions and do not consider that there are any gaps with respect to their findings as a result of the detailed and comprehensive review. Therefore, CNSC staff have reached the conclusion that OPG continues to make adequate provisions at the Darlington NGS to protect the environment and health of persons. The requested information on these actions can be found in the sections that follow Fisheries Act Authorization As described in paragraph 38 of the Record of Proceedings, including Reasons for Decision for the Darlington Refurbishment and Continued Operations EA [8], the Commission discussed a Fisheries Act authorization to address ongoing fish loss from the Darlington NGS operations. In anticipation of the hearings for this application, OPG provided an update on its progress in applying for a Fisheries Act authorization to the Commission on December 22, 2014 [12]. The following provides a summary of this update as well as the status of DFO s review of the application. CNSC staff and DFO confirmed in the EA Screening Report [7] on the Refurbishment and Continued Operation of the Darlington NGS, that the once-through cooling water system results in relatively low estimated losses of fish from impingement and entrainment and concluded that the residual adverse effect is minor in nature and not significant. During the EA process, OPG committed to applying for an authorization under the Fisheries Act for the ongoing fish loss. On August 27, 2014, OPG submitted an application for a Fisheries Act authorization to DFO. On January 19, 2015, DFO staff requested further information and documentation from OPG in 8

153 June 2015 Environmental Assessment Information Report relation to details of the monitoring plan as part of offsetting measures. DFO received this additional information from OPG in February and March On June 24, 2015, the Minister of Fisheries and Oceans Canada issued a paragraph 35(2)(b) Fisheries Act authorization to OPG for the authorization to carry on with the activities that result in serious harm to fish, arising from the continual intake of cooling water and the impingement and entrainment of fish from Lake Ontario. The authorization includes conditions to be complied with in relation to mitigation and offsetting measures and standards, monitoring and reporting. The authorization is valid from its date of issuance to December 31, The authorization is not linked to this current Darlington NGS licence application (and therefore, does not impact or impede on the decision for this licence application) Thermal Effects Studies As described in paragraph 53 of the Record of Proceedings, including Reasons for Decision for the Darlington Refurbishment and Continued Operations EA [8], the Commission discussed OPG s intention to continue to undertake studies to update their understanding of the potential thermal effects from the diffuser at the Darlington NGS. In anticipation of the hearings for this application, the Commission requested that OPG provide an update on these studies. OPG provided this update to the Commission on December 22, 2014 [12]. The following provides a summary of this update as well as the status of CNSC staff s review. CNSC staff and DFO concluded in the EA Screening Report [7] on the Refurbishment and Continued Operation of the Darlington NGS, that thermal effects on round whitefish were minor in nature and not significant. OPG confirmed its intention to continue to undertake studies to update their understanding of the potential thermal effects from the cooling water discharge. As part of the EA FUMP, OPG is developing a thermal monitoring program to be implemented during continued operations. This includes consideration of the results of a research study on thermal effects on round whitefish eggs published by the CANDU Owners Group (COG) in 2014 [13]. OPG has also continued to participate in the Round Whitefish Action Plan with CNSC, DFO, EC and the Ontario Ministry of Natural Resources and Forestry (OMNRF). A key aspect of this initiative includes consideration of a round whitefish population study. This study, led by the OMNRF commenced in 2014 with OPG working collaboratively with OMNRF to collect samples of round whitefish in the vicinity of the Darlington and Pickering NGSs. The results of this study will allow for a better understanding of the population dynamics of this species in Lake Ontario and help inform this species ongoing management. CNSC staff will update the Commission on the status of this study as part of the annual CNSC Staff Regulatory Oversight Report for Canadian Nuclear Power Plants Groundwater As described in paragraph 65 of the Record of Proceedings, including Reasons for Decision for the Darlington Refurbishment and Continued Operations EA [8], the Commission requested that OPG provide an update on the work completed to characterize the 2009 spill that occurred at the Darlington NGS in anticipation of the hearings for this application. OPG provided this update to the Commission on December 22, 2014 [12]. The following provides a summary of this update as well as the status of CNSC staff s review. On December 21, 2009, an overflow of the Emergency Cooling Injection (ECI) Injection Water Storage Tank (IWST) occurred at the Darlington NGS inside the Protected Area between the 9

154 June 2015 Environmental Assessment Information Report Power House and Vacuum Building. Upon discovery of the spill, the Darlington NGS Emergency Response Team immediately placed yard drain covers to prevent further seepage of spilled water and recovered the remaining standing water. Increased sampling results at the Water Supply Plants following the spill showed no impacts to the drinking water source. In November 2011, OPG conducted a Phase II Environmental Site Assessment (ESA) study to characterize and delineate potential contamination in soil and groundwater resulting from the 2009 spill. During the assessment, OPG installed additional groundwater monitoring wells in and around the spill area, conducted hydraulic tests, updated the site-wide groundwater flow and contaminant transport model, and sampled and analyzed the groundwater monitoring data in both new and existing wells. The Phase II ESA study determined that the contamination associated with the IWST spill event is slowly migrating west through the subsurface gravel and granular fill materials around the generating station or through the shallow bedrock below the generating station foundation. The path of the contamination is predominantly directed toward the forebay on the north and west side of the plant. As a result of the reduction in concentration over time and groundwater flow path, and the dilution contribution of the lake and groundwater, the study concluded no measurable change observed in the lake or at the nearest drinking water supply plant (Bowmanville Water Supply Plant) which is east of, and 7 km from, the Darlington NGS. The Final Report [14] of the Phase II ESA study was submitted to CNSC staff in February The report concluded that no adverse human health or environmental impacts resulting from the groundwater tritium plume are expected. CNSC staff reviewed the Final Report and is in agreement with the approach and OPG s conclusion that there are no human health or environmental impacts from the groundwater tritium plume due to the IWST spill. Groundwater monitoring is included in OPG s environmental monitoring program and results will continue to be submitted annually to CNSC staff for review Protective Action Levels in Foodstuffs During Emergencies As described in paragraph 98 of the Record of Proceedings, including Reasons for Decision for the Darlington Refurbishment and Continued Operations EA [8], the Commission directed CNSC staff to provide an update concerning the initiative to update the allowable levels of radiation in foodstuffs during emergencies. The status of this initiative is provided below. The fundamental goal behind emergency planning and response is protecting the public from the potential harmful effects of radiation exposure resulting from an unplanned release of radiation to the environment. In the event of a nuclear emergency, response organizations will be called upon to provide advice and guidance on measures that should be taken by the public in order to reduce or avoid unnecessary dose. These measures, referred to as countermeasures or protective actions, include the consideration of sheltering, evacuation, administration of stable iodine and the restriction of food and water that is contaminated. The Canadian Guidelines for the Restriction of Radioactively Contaminated Food and Water Following a Nuclear Emergency [15] are in place to restrict the ingestion of contaminated foodstuffs. The Canadian Guidelines for Intervention During an Emergency that relate to other countermeasures are also in place [16]. 10

155 June 2015 Environmental Assessment Information Report These guidelines, published by Health Canada, have been developed with two principal objectives: to minimize the health risk associated with the consumption of contaminated foodstuffs to preserve public confidence in the safety of the commercial food supply These guidelines apply solely to the control of commercial foodstuffs and public drinking water supplies resulting from a nuclear emergency. These guidelines are currently under review by Health Canada, and CNSC staff have already reviewed a draft version of the revised guidelines and provided comments. Intervention and Action Levels Intervention and action levels are derived based on Health Canada guidelines. Intervention levels are expressed in terms of a dose that is expected to be avoided over time by a specific protective action or countermeasure. In the case of restriction on commercial foodstuffs and water, Health Canada has chosen an intervention level of approximately 3 millisievert (msv) divided equally between the following three food groups: fresh liquid milk, drinking water and other commercial foods and beverages. Each food group has an intervention level of 1 msv. This means that if the contamination of a food group would result in a dose of approximately 1 msv or greater, intervention in the form of the withdrawal of food and water from sale or distribution would be taken. Note that an intervention level of 3 msv is well within the guidance from the International Commission on Radiological Protection (ICRP) which recommends that during the emergency phase, doses be kept below the range of msv. Further, 3 msv is well below any dose that would result in adverse health effects. Action levels are directly measurable quantities that are derived based on the intervention level. Note: The term action levels in this context is not the same as the one referred to in section 3.3 of this report; however, the concepts are broadly similar in that exceeding an action level triggers the need for action. In this case, action levels for food and water correspond to an activity concentration of a radionuclide that would lead to a dose of approximately 1 msv. Table 2 lists recommended action levels for radionuclides of potential significance to dose from ingestion of contaminated food and water. 11

156 June 2015 Environmental Assessment Information Report Table 2: Recommended action levels for radionuclides of potential significance to dose from the ingestion of contaminated food Action levels (Bq/kg) * Radionuclide Fresh liquid milk Other commercial Public drinking foods and beverages water Sr Sr Ru Ru I Cs-134, Cs Pu-238, Pu-239, Pu- 240, Pu-242, Am * Bq/L for drinking water Table 3: Recommended action levels for radionuclides of lesser significance to dose from the ingestion of contaminated food Action levels (Bq/kg) * Radionuclide Fresh liquid milk Other commercial Public drinking foods and beverages water H-3 30, , ,000 C-14 3,000 10,000 3,000 Cr-51 30, ,000 10,000 Fe-55 1,000 3,000 1,000 Fe-59, Co , Zn-65, Y , Zr-95 1,000 3,000 1,000 Nb-95 1,000 10,000 1,000 Mo-99 10,000 30,000 10,000 Ag-110m 300 1, Te-132 1,000 3,000 1,000 Ba-140 1,000 10,000 1,000 La-140 3,000 10,000 1,000 Ce-141 1,000 3,000 1,000 Ce Np Np-239 3,000 30,000 3,000 Pu , Pu * Bq/L for drinking water Guidelines implemented to protect the general population must protect the most sensitive in the population. Therefore, action levels for each radionuclide of concern (shown in tables 2 and 3) were calculated for six age groups, using age specific consumption rates and ingestion dose 12

157 June 2015 Environmental Assessment Information Report coefficients 1. However, to achieve practical and straightforward guidelines a single action level was chosen for each radionuclide based on the most restrictive of all six age groups. In order to reflect uncertainties and simplify implementation, the calculated action levels were grouped into similar categories and assigned representative single values. Authority Health Canada, under the Food and Drugs Act has the primary responsibility for the safety of all domestic and imported food for sale in Canada. This authority applies in the event of contamination of commercial food supply. Thus, the guidelines for food described in this section would be implemented in the case of an emergency. However, in the case of drinking water the authority lies within provincial, territorial or municipal jurisdiction. Therefore, provinces may choose to adopt the guidelines in whole or in part, or develop their own criteria. Harmonization of any applicable guidelines is encouraged. The Canadian Food Inspection Agency is responsible for monitoring and enforcing the food and safety standards and guidelines established by Health Canada Human Health Estimated Dose to the Public CNSC s Radiation Protection Regulations set dose limits on the amount of radiation the public and nuclear energy workers (NEWs) can receive. In particular, the amount of radiation NEWs can receive is from occupations relating to radiation activities or facilities. These regulations require every licensee to implement a radiation protection program that keeps the amount of exposure to ionizing radiation as low as reasonably achievable (ALARA). Radiation dose limits are set in accordance with recommendations of the International Commission on Radiological Protection, as well as International Atomic Energy Agency (IAEA) standards and guides. In Canada, the CNSC sets the dose limits for NEWs and the public. The effective dose limit for members of the public is 1 msv per year. The effective dose for NEWs is 50 msv per year and 100 msv every 5 years. More information on radiation and radiation doses can be found on the CNSC website at: nuclearsafety.gc.ca/eng/resources/radiation/index.cfm. As mentioned in section 2.1 above, OPG submits on an annual basis an environmental monitoring report that details the results of its environmental protection programs, including the estimated annual dose to the public. Doses are calculated for potential critical groups identified in site specific surveys. Although doses are calculated for several potential critical groups, only the group and age class with the highest dose is reported as the official site public dose in a given year. Table 4 below presents the maximum effective dose to a member of the public from activities conducted at the Darlington NGS from 2008 to The 6 age groups are: 3 months, 1 year, 5 year, 10 year, 15 year, and adult. These are based on age categorizations recommended by the ICRP [17] 13

158 June 2015 Environmental Assessment Information Report Table 4: Dose statistics to public for Darlington NGS ( ) Maximum effective dose to a member of the public Dose statistic Regulatory limit Maximum effective dose (μsv) % Dose limit msv/year (1000 μsv/y) The estimated maximum effective dose to a member of the public ranged from 0.6 to 1.3 μsv/year [18, 19, 20, 21, 22, 23, 24]. Based on the information provided by OPG, the public dose remains less than 1% of the regulatory limit of 1 msv/year Radiation and Incidence of Cancer Risk The CNSC completed in 2013 an ecological study on populations living near Ontario's three nuclear power plants (NPPs). The purpose of the Radiation and Incidence of Cancer Around Ontario Nuclear Power Plants from 1990 to 2008 study (the RADICON study) [25] was to: determine the radiation doses to members of the public living within 25 km of the Pickering, Darlington, and Bruce NPPs compare cancer cases among these people with the general population of Ontario from 1990 to 2008 The most important finding of the RADICON study is that there is no evidence of clusters, or groups, of childhood leukemia around the three Ontario NPPs. The rates of cancer incidence for children aged 0 4 and aged 0 14 were similar to the general Ontario population. The main strength of the RADICON study is the use of detailed public dose information around each NPP that was generated from radiological release and environmental monitoring data. Overall, for all ages, there is no consistent pattern of cancer across the populations living near the three facilities studied. While this type of study cannot determine the causes of the cancer, excess cancers (increase in cancer above what s expected in Ontario) are unlikely to be due to radiation as radiation doses from NPPs to members of the public are extremely low at least 100 to 1,000 times lower than natural background radiation and public dose limits. Radiation doses are a minor risk factor compared to the high prevalence of major risk factors like tobacco, poor diet, obesity and physical inactivity, which account for about 60% of all cancer deaths in developed countries. These factors represent a public health concern throughout Ontario, including the communities located near NPPs. Other important Ontario studies [26, 27] found that once these main risk factors were taken into account, there was no evidence of a cancer risk due to environmental factors like radiation. Given the high frequency of these factors, the current scientific understanding of radiation risk, and the miniscule public doses, it is not realistic to attribute any excess cancers to the radiation doses from NPPs found in these communities. 14

159 June 2015 Environmental Assessment Information Report Table 5 below shows annual doses from natural background radiation and from the Darlington NPP to hypothetical individuals 2 and critical groups 3. Table 5: Annual doses from Darlington NPP to hypothetical individuals and critical groups NPP Dose from natural background Range of doses to hypothetical individuals ( ) Highest estimated dose to critical groups ( ) Darlington msv/y a msv/y b, c msv/y a from b nursing infant c Data from At Darlington NPP, from 1985 to 2002, the highest dose to a hypothetical individual was msv/year. This dose is at least 100 times lower than the annual regulatory public dose limit of 1 msv/year, and remains well below natural background levels. It was also observed that almost all exposure is contained within 5 km from the centre point of the facility, much of which is located above the facility itself. Based on 2006 census data for the Durham Region, only 0.01% of the population living within a 25 km radius is located within 5 km of the Darlington NPP [28, 29].Therefore, the majority of the members of the public are exposed to little or no radiation from Darlington NPP emissions. The methodology used in the RADICON study - that is, the use of detailed public dose information around each NPP that was generated from radiological releases and environmental monitoring data - is an improvement from recent epidemiological studies of childhood cancer, such as the German, UK, Swiss and Finnish studies [30, 31, 32, 33, 34], which used distance from an NPP as a substitute for radiation dose. Doses closest to the NPPs were not consistently higher than doses further away. Many factors influence doses to the public as a result of the operation of a NPP, including prevailing wind directions and lifestyle characteristics (i.e., diet and lifestyle habits) of the surrounding communities. Therefore distance is not a good substitute for dose. To conclude, public radiation doses resulting from the operation of the NPPs are 100 to 1,000 times lower than natural background radiation and there is no evidence of childhood leukemia clusters around the three Ontario NPPs. All cancers for all age groups are well within the natural variation of the disease in Ontario. Thus, radiation is not a plausible explanation for any excess cancers observed within 25 km of any Ontario NPP. 2 Prior to 2003, calculations using maximum dose estimates to a hypothetical individual living near Darlington NPP were used. The dose received by a hypothetical individual was very conservative, since pathway exposure models assumed that the individual lived at the facility fence line and consumed only local food and water. 3 After 2003 for the Darlington NPP, a more realistic human receptor was defined as a critical group representing a uniform group of people whose location, age, habits, diet and other factors caused them to receive higher doses than other groups in the exposed population. 15

160 June 2015 Environmental Assessment Information Report Tritium and Potential Health Impacts Tritium Studies Project In January 2007, the Commission directed CNSC staff to initiate research studies on tritium releases in Canada, and to study and evaluate tritium processing facilities exercising the best practices around the globe. In response, the CNSC has undertaken several research projects under the banner of Tritium Studies Project. The objectives of the project were to: assemble data on the status and nature of impacts of tritium releases from all significant licensed facilities and activities in Canada review engineering control on releases from facilities producing, handling or managing tritium in Canada investigate the fate of tritium releases to the atmosphere conduct an independent staff review of the scientific literature to assess the health risk to workers and the public from exposures to tritium The results of these studies along with CNSC staff conclusions and recommendations are summarized in the Tritium Studies Project Synthesis Report released in 2010 and revised in 2011 [35]. Based on extensive epidemiological research, the findings with respect to health effects are that there is little evidence to suggest that there is an increase in cancer incidence or mortality to the public or workers exposed to tritium at current environmental or occupational levels. In Canada, doses to the public from tritium releases from nuclear facilities are far below the public dose limit. Doses from tritium exposures among people living near Canadian nuclear facilities are in the range of to 0.1 msv per year. These doses are not only well below the limit, but are also negligible compared to natural background radiation, including that from radon (approximately 2 to 3 msv per year depending upon geographic location). Canadian Nuclear Worker Study Most recently, Zablotska et al published A reanalysis of cancer mortality in Canadian nuclear workers ( ) based on revised exposure and cohort data [36]. The study found no evidence of radiation risk for over 42,000 workers employed by the three NPP companies (Hydro Quebec, Ontario Hydro and New Brunswick Power Corporation) and post-1964 Atomic Energy of Canada Limited (AECL) 4. The workers from the three NPP companies had tritium doses ranging from 0 to 149 msv (mean dose 4.70 msv) and workers from AECL had tritium doses ranging from 0 to 82 msv (mean dose of 0.64 msv). There was no evidence of increased risk of cancer from tritium exposure; in fact, the estimated risk (excess relative risk or ERR) from tritium exposure was negative with an ERR of AECL changed its name to Canadian Nuclear Laboratories (CNL) in

161 June 2015 Environmental Assessment Information Report 3.3. Radiological Releases Derived release limits (DRLs) are required for the purposes of protecting members of the public from unreasonable risk resulting from releases to radionuclides into the environment from the normal operation of the Darlington NGS. The DRL for a given radionuclide is the release rate that would cause the most highly exposed individual of the most highly exposed group to receive a dose equal to 1 msv per year (the regulatory annual dose limit). CNSC requires OPG to develop and use DRLs based on the CSA standard N [2]. Exceedances of DRLs trigger reporting to the CNSC, a formal investigation to be undertaken and enhanced regulatory oversight by the CNSC. OPG is also required to set action levels (ALs) which serve as an early warning system to alert licensees before regulatory dose limits are reached. ALs are precautionary levels and are set far below the actual DRLs. By definition, an AL is a specific dose of radiation or activity concentration, that, if reached, may indicate a loss of control of some part of a licensee s program, and triggers a requirement for specific action to be taken, including establishing the cause for reaching the action level, restoring the effectiveness of the program, and notifying the CNSC within the timeframes specified in the licence. OPG updated its DRLs at the Darlington NGS in accordance with CSA standard N [2]. The new DRLs [37] were reviewed and accepted by CNSC staff in May 2011 and are included in the proposed licence and draft LCH. OPG continues to implement and maintain effective environmental protection programs at Darlington NGS in accordance with CNSC requirements. OPG radiological releases to the environment (air and water) remained well below its respective DRLs during the period of 2008 to

162 June 2015 Environmental Assessment Information Report Figure 2 provides the radiological releases to air from Darlington NGS for 2008 to 2014 [18, 19, 20, 21, 22, 23, 24]. Figure 2: Darlington NGS - Radiological releases to air in (Bq) from 2008 to Emissions as %DRLs Emissions as % DRLs Tritium (HTO) Tritium (HT) Iodine-131 Noble Gas Radioactive Particulates Carbon-14 Radionuclides Emitted to Air Figure 3 provides the radiological releases to water from Darlington NGS for 2008 to 2014 [18, 19, 20, 21, 22, 23, 24]. Figure 3: Darlington NGS - Radiological releases to water in (Bq) from 2008 to Emissions as %DRLs Releases as % DRLs Tritium Gross Beta Gamma Carbon-14 Radionuclides Released to Water

163 June 2015 Environmental Assessment Information Report 3.4. Accidents and Malfunctions Severe Nuclear Accident Scenario The effects of a nuclear accident were considered as part of the EA for the proposed Refurbishment and Continued Operation of the Darlington NGS undertaken under the Canadian Environmental Assessment Act (CEAA) [7]. Consistent with accidents assessed in previous EAs and in accordance with the Commission-approved EA Scoping Information Document [38], a beyond-design-basis accident with an off-site release and an annual probability of occurrence of greater than 1 in 1,000,000 (10-6 ) was assessed. The use of a probability of occurrence of 10-6 as a cut-off point is consistent with an internationally accepted safety goal for limiting large releases from nuclear power plants. The safety goal is used to explicitly consider the risk to the public and environment that originates from accidents beyond the design basis. Accidents beyond this probability (e.g., frequency of 10-6 and lower) were not within the scope of the CEAA EA; however, were examined in response to the Fukushima Daïchi event through Fukushima-related initiatives under the CNSC regulatory framework. Further information with respect to updates on the Fukushima Action Items and implemented safety improvements can be found in section 5.5 of the Darlington Licence Renewal CMD-15-H8 [6]. The postulated accident assessed as part of the CEAA EA resulted in the potential need for sheltering up to 3 km from the source, which is just beyond the Darlington site boundary. No evacuation was needed. The results were that the collective dose was a small fraction (less than 1%) of the annual collective dose to the same population from background radiation. The assessment of significance on the residual effects of such an accident concluded that they were minor and not significant due to the low magnitude and duration. From a non-human biota perspective, the predicted doses from the acute phase of the representative nuclear accident were determined to be well below current United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) guidelines and no population level effects were expected. Furthermore, as another element of refurbishment planning, OPG conducted an Integrated Safety Review (ISR) of the Darlington NGS in accordance with the CNSC regulatory document RD 360 Life Extension of Nuclear Power Plants [10]. For further information, please see section 3 of the Darlington Licence Renewal CMD 15-H8 [6]. Under the ISR, the range of the assessed accident scenarios effectively extended to frequencies lower than that of 10-6 considered in Darlington Refurbishment and Continued Operation EA to fully assess the ability to control beyond design basis plant conditions, including prevention of accident progression and mitigation of the consequences of severe accidents. Further to the severe nuclear accident scenario considered in the Darlington Refurbishment and Continued Operations EA under CEAA, the Commission directed CNSC staff to undertake an assessment of health and environmental consequences of severe accident scenarios and to update the Commission accordingly [8]. The study, entitled Study of Consequences of a Hypothetical Severe Nuclear Accident and Effectiveness of Mitigation Measures [39], involved identifying and modelling a large release of radionuclides to the atmosphere from a hypothetical severe nuclear accident at the Darlington NGS; estimating the doses to individuals at various distances from the nuclear power plant, 19

164 June 2015 Environmental Assessment Information Report factoring in emergency response protective actions such as evacuation; and, finally, determining human health (i.e., increased risk of cancer) and environmental consequences (i.e., effects to wildlife) due to the resulting radiation exposure. The study is of a theoretical nature, using hypothetical severe accident scenarios. As directed by the Commission, the source term considered in this study is greater than the source term previously assessed in the Darlington Refurbishment and Continued Operations EA; it is greater by 4-5 orders of magnitude. Further, the source term used, is comparable to a severe accident scenario described in the Darlington NGS Probabilistic Risk Assessment [40] that has a probability of occurrence of 3.7 x 10-7 or 3.7 in 10 million - it was referred to as a Release Category 2 accident. For this study, a generic source term was derived based on the CNSC s large release safety goal of 1 x Becquerels of Cesium-137. This is the safety goal outlined in CNSC s recently published REGDOC-2.5.2, Design of New Nuclear Power Plants [41]. The safety goals, which are based on modern international recommendations, have been established to ensure plant design features are in place to limit the risk to society and the environment to acceptably low levels. With 1 x10 14 Becquerels of Cesium-137 as the source term basis, other radionuclides were added to the source term in a quantity scaled to the amount of Cesium-137 considered and reflective of radiological inventory of a Darlington reactor unit [39]. This source term was also increased four-fold to be comparable to a common cause event affecting all 4 units at Darlington, in order to be responsive to concerns raised during the EA hearings regarding multi-unit events, such as those at Fukushima. Though there was no probability associated with this increased source term, it would be expected to be much lower than 10-7 for this kind of multi-unit event. With respect to the human health results, the doses predicted in this study were comparable to those measured in Fukushima and equivalent to the IAEA International Nuclear Events Scale (INES) 7 event which is the highest level for a nuclear accident. The key study findings were that it would be nearly impossible to distinguish most radiation-induced cancers from baseline cancers examined in this study - that is all cancers combined, leukemia and adult thyroid cancer. Of note, childhood thyroid cancer is a radiation-induced cancer that could be distinguished from baseline cancers. Increased risk of childhood thyroid cancer was predicted for all scenarios. This led to the study recommendation that the consideration of sensitive receptors (i.e. children) continue to be an important aspect of emergency planning, such as potassium iodide pill administration. However, this study did not account for the inherent flexibility in emergency planning to deal with specific circumstances around an accident and the surrounding environment, which would effectively reduce these risks. Moreover, post-fukushima safety enhancements were not accounted for (e.g., emergency mitigating equipment), which would further reduce the probability of a severe accident such as those hypothetical scenarios examined in this study. With respect to environmental consequences, for non-human biota, like fish, birds and mammals, no acute effects would be expected. CNSC staff presented the results of this assessment as part of CMD 14-M30 [39] during the June 19, 2014 Commission Meeting. Public consultation was also undertaken on the draft study, with 505 submissions received. CNSC staff provided an update to the Commission on the results of 20

165 June 2015 Environmental Assessment Information Report the public consultation during the March 26, 2015 Commission Meeting [42]. In terms of next steps, CNSC staff are finalizing the study in order to publish it on CNSC s website, and concurrently, will be publishing the study findings in peer-reviewed literature Management of Radioactive Waste Low and Intermediate-Level Waste (L&ILW) Management The Low-Level Radioactive Waste (LLW) generated from the operation of the Darlington NGS and from the operation of the Darlington Waste Management Facility (WMF) is safely transported by road to the Western WMF for potential processing and interim storage. The Western WMF is located at the site of the Bruce NGSs. The Darlington and Western WMFs are subject to their own Waste Facility Operating Licences and are not linked to the current Darlington NGS licence application. LLW consists of materials that have become contaminated with nuclear substances during their use at the NGSs or waste management facility, such as mop heads, rags, paper towels, floor sweepings and tools. This type of waste is comprised of materials like: paper, plastics, metal, rubber and cotton. LLW can be safely handled without shielding [43]. OPG processes LLW for the purpose of volume reduction. Up to 30% of the LLW received at the Western WMF is incinerated, producing a stable form of ash waste. This waste minimization technique has the potential to reduce the storage volume of LLW 70-fold. For LLW not suitable for incineration, compaction may be performed resulting in a five-fold volume reduction. Some waste cannot be processed, such as contaminated tools, and is stored at the Western WMF without undergoing processing. The Intermediate-Level Radioactive Waste (ILW) generated from the operation of the Darlington NGS is also stored at the Western WMF. The ILW is loaded into specially reinforced and designed transport packages (certified by the CNSC) at the Darlington site before shipment to the Western WMF. ILW does not undergo further processing and consists mostly of used reactor components, as well as the resins and filters used to keep the reactor water systems clean. OPG has safely managed L&ILW for the Pickering, Darlington and Bruce reactors at the Bruce site for over 40 years. Currently, an estimated 94,000 cubic metres of L&ILW is stored at the Western WMF on an interim basis. Dose to the public from the operation of the Western WMF is not distinguishable from the dose to the public from the operation of the Bruce NGSs and is therefore reported as a consolidated dose. Over the past five years ( ), the highest annual dose potentially received by a member of the public from the Bruce site was msv (2010), which is less than 1 % of the annual dose limit of 1 msv [44]. Over the last five years, on average, workers at the Western WMF received an annual dose of 0.1 msv, which is also less than 1% of the regulatory limit of 50 msv/year (not to exceed 100 msv over the course of 5 consecutive years). Over the last five years, the highest annual dose received by a worker at the Western WMF was 1.8 msv (2012), which is less than 4% of the regulatory limit. The Western WMF has its own facility-specific DRLs for both airborne and liquid controlled releases. Over the last five years, controlled airborne releases for particulate were consistently 21

166 June 2015 Environmental Assessment Information Report below the derived release limits. The highest controlled release was for tritium in 2010 and was below 0.1% of the DRL. Also over the last five years, controlled liquid releases for tritium and gross beta-gamma were consistently below the DRLs. The highest controlled release was for gross beta-gamma in 2011 and was below 0.1% of the DRL. Compliance activities of verification, enforcement and reporting are in place to ensure that CNSC licensees exhibit a high level of compliance with the CNSC regulatory framework. These activities enable the CNSC to provide assurance to Canadians of the continuing compliance and safety performance of licensees. Based on these activities, including compliance inspections, CNSC staff ensure that OPG is safely managing L&ILW in compliance with regulatory requirements. Long-term Management of OPG s L&ILW OPG has recognized that, while its current approach to radioactive waste storage is safe, secure and environmentally responsible, a safe and long-term solution is required to dispose of the waste where it cannot pose a threat to the public or the environment. A long-term management approach has been proposed to ensure that radioactive waste can be kept safely contained and isolated from the environment without burdening future generations. The proposed long-term management approach is presently undergoing a separate review process which is not linked to this current Darlington NGS licence application. Further information on the proposed long-term management approach is provided below. The current project proposed by OPG is to prepare the site and construct a deep geological repository on the Bruce nuclear site within the Municipality of Kincardine. The purpose of the proposed repository is to safely isolate and contain L&ILW deep underground, ensuring protection of water and the environment. It would be buried 680 metres deep, in stable rock formations that are over 450 million years old. The proposed deep geological repository site is adjacent to the existing Western WMF that is owned by OPG and provides centralized storage for L&ILW from the operation of OPG-owned or operated reactors in Ontario. The Canadian Environmental Assessment Agency and the CNSC established a Joint Review Panel (JRP) in January 2012 to conduct both the EA and licence application review for the proposed project. On May 6, 2015, the JRP delivered its Report to the federal Minister of the Environment for review and decision under the Canadian Environmental Assessment Act, 2012 [45]. In its Report, the JRP concluded that the DGR Project is not likely to cause significant adverse environmental effects, provided the mitigation measures proposed and commitments made by OPG during the review, and the mitigation measures recommended by the Panel, will be implemented. The Minister of the Environment is currently seeking public comment (for 90 days: June 3 September 1) on potential conditions related to possible EA mitigation measures and follow-up requirements, before issuing a decision statement on whether the project may proceed. If permitted by the decision of the Minister of the Environment, the JRP will act as the Commission and decide whether to issue the requested licence. 22

167 June 2015 Environmental Assessment Information Report Used Nuclear Fuel Management In Canada, High Level Radioactive Waste (HLW) consists of irradiated nuclear fuel and other heat generating materials. Irradiated nuclear fuel is long lived and requires significant shielding and long-term isolation. Irradiated nuclear fuel is stored in the interim in both wet and dry storage. Upon discharge from the reactor at the Darlington NGS, the irradiated nuclear fuel is stored in an irradiated fuel bay for a minimum of 10 years. After the minimum time period in wet storage, the fuel is transferred to dry storage, and sealed in Dry Storage Containers (DSCs) at the Darlington WMF [43]. DSCs are free standing containers constructed of steel and concrete which provide shielding for the radioactivity and allow for heat dissipation from the radioactive decay of the irradiated fuel. DSCs are placed into the irradiated fuel bays and loaded with the fuel, capped, sealed with temporary transfer clamps and lifted out of the irradiated fuel bays. They are then dewatered, decontaminated and transferred back to the Darlington WMF. Once in the Darlington WMF, the lid and the base of the DSC are welded together, the weld is inspected, the DSC is then vacuum-dried, helium-backfilled to prevent corrosion, repainted if needed, the IAEA seals are put on and the DSC is sent to the storage building. The Darlington WMF has dedicated buildings for the processing and storage of DSCs. The Darlington WMF has the capacity to store all used fuel from the operating life of the Darlington NGS. DSCs were engineered for a 50-year service life. The actual life of the DSCs could be much longer. The DSCs are continuously monitored and if required, the irradiated nuclear fuel can be retrieved and transferred to a new DSC. OPG s DSC design has been reviewed and accepted by the CNSC for its use as both a storage container and as part of a CNSC-certified transportation package under the Packaging and Transport of Nuclear Substances Regulations. OPG's waste management facilities are licensed for a limited period. Licences issued for OPG's waste management facilities are valid for a 10-year period. At the time of licence renewal, the CNSC examines the operational performance of the facility to determine whether it can continue to operate safely for another licensing term.this situation is expected to continue until a longterm management facility becomes available. CNSC s approach to the safety of irradiated nuclear fuel and radioactive waste management is in accordance with the guidelines provided by IAEA safety guides and practices. Dose to the public from the operation of the Darlington WMF is not distinguishable from the dose to the public from the operation of the Darlington NGSs and is therefore reported as a consolidated dose. Over the past five years ( ), the annual dose potentially received by a member of the public from the Darlington site was msv, which is less than one percent of the annual dose limit of 1 msv [44]. Furthermore, the Darlington Refurbishment and Continued Operations EA considered serious accidents that could result from the improper management of fuel waste, including the drop of a DSC due to an unforeseeable accident during on-site transfer [7]. The results of the assessment indicated that radiation doses to workers and the public from the on-site traffic accident involving a DSC transporter scenario are expected to be well below regulatory limits. Also, radiation doses to non-human biota are expected to be below no-effects levels reported by UNSCEAR. 23

168 June 2015 Environmental Assessment Information Report Long-term Management of Canada s Used Nuclear Fuel A long-term management approach has been proposed to ensure that Canada s used nuclear fuel can be kept safely contained and isolated from the environment without burdening future generations. The proposed long-term management approach is presently undergoing a separate review process which is not linked to this current Darlington NGS licence application.. Further information on the proposed long-term management approach is provided below. The Nuclear Waste Management Organization (NWMO) was established in 2002 under the Nuclear Fuel Waste Act (NFWA). The NWMO, under the NFWA, was mandated to develop collaboratively with Canadians a management approach for the long-term care of Canada s used nuclear fuel that is socially acceptable, technically sound, environmentally responsible and economically feasible. From 2002 to 2005, the NWMO studied various approaches to the longterm management of Canada s spent fuel [46]. In 2005, the NWMO recommended Adaptive Phased Management (APM) for the long term management of fuel. APM includes a technical method based on an end point of centralized containment and isolation of the spent fuel in a deep geological repository in a suitable rock formation. It provides for continuous monitoring of the spent fuel and the potential to retrieve it for an extended time. In June 2007, the Government of Canada selected the APM approach, recommended by the NWMO, for the long-term management of Canada s used nuclear fuel. The NWMO is responsible for implementing this plan. In 2010, NWMO launched its site selection process to identify a willing and informed community to host the repository in a suitable rock formation. Currently, there are 9 communities actively engaged in exploring interest in the project. Implementation of the APM will be regulated at all stages, with the CNSC responsible for regulatory matters pursuant to the NSCA. The NWMO will be required to obtain licences from the CNSC for site preparation, construction, operation, decommissioning and abandonment (release from CNSC licensing) of the repository facilities. CNSC s approach to safety is based upon several factors, including the review of international standards (e.g., IAEA standards and guides) and improvements to regulatory policies and standards (e.g., regulatory policy P-299, Regulatory Fundamentals). In addition, Canada is a signatory of the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management. As such, Canada s strategy for long term management of used nuclear fuel is subject to an international peer review every 3 years. Being a part of the Joint Convention also allows Canada to keep abreast of international best practices. 24

169 June 2015 Environmental Assessment Information Report 4. CNSC INDEPENDENT ENVIRONMENTAL MONITORING PROGRAM The CNSC has implemented its Independent Environmental Monitoring Program (IEMP) to verify that the public and the environment around licensed nuclear facilities are safe. It is separate from, but complementary to, the CNSC s ongoing compliance verification program. The IEMP involves taking samples from public areas around the facilities, and measuring and analyzing the amount of radiological (nuclear) and hazardous substances in those samples. CNSC staff collect the samples and send them to the CNSC s state-of-the-art laboratory for testing and analysis IEMP for Darlington Site The IEMP for the Darlington site consists of measurements of radiological contaminants. A site-specific sampling plan was developed based on OPG s approved environmental monitoring programs, CSA standards and the CNSC s regulatory experience with the site. In 2014, samples were collected in publicly accessible areas outside the perimeter of the Darlington site. CNSC staff sampled the following in the vicinity of the Darlington site: air (from different locations) water (from Lake Ontario) soil (e.g., beach sand and soil) vegetation (e.g., grass and wild plants) local food (e.g., milk, potato, kale, apple, poultry) Samples collected were analyzed by qualified laboratory specialists in CNSC s state-of-the-art laboratory in Ottawa, using appropriate protocols. CNSC staff measured the following: contaminants of potential concern such as tritium (HTO) radioactive particulates such as cesium-137 radioactive iodines such as iodine Results The IEMP results confirm that the public and the environment in the vicinity of the Darlington site are protected from the releases from the facility. The measured radioactivity in all samples was below CNSC referenced levels. The CNSC reference levels are established based on conservative assumptions about the exposure scenario and using CSA standard N [47]. The reference level for a particular radionuclide in a particular medium (e.g., water, air, foodstuff) represents the activity concentration that would result in a dose of 0.1 msv per year. The approach used by CNSC staff to calculate a reference level is similar to Health Canada and World Health Organization s (WHO) approach for drinking water guidelines where 0.1 msv per year is also used. Conservative assumptions that are taken into account when calculating reference levels include the use of upper percentiles of population inhalation and ingestion rates, full-time occupancy 25

170 June 2015 Environmental Assessment Information Report factors at given locations, conservative estimates of time spent outdoors and the use of dose conversion factors that already have safety factors built in. The primary difference in reference levels between different types of food consumed is reflective of the difference in the ingestion/consumption rates of that particular food in a year. Table 6 provides the range of results from the 2014 sampling campaign. The full IEMP results are currently available through a public-friendly dashboard on the CNSC website. Full technical reports are available on request. The IEMP results confirm that the public and the environment around the Darlington NGS facility are safe and that there are no health impacts. These results are consistent with the results submitted by OPG, confirming that the licensee s environmental protection program protects the health and safety of people and the environment. 26

171 June 2015 Environmental Assessment Information Report Table 6: Summary of Darlington site IEMP 2014 results Radionuclide Range of measured Guideline or radioactivity CNSC reference level 1 Water (Bq/L) Cesium-137 < Gross Alpha < Gross Beta Tritium (HTO) 6 < ,000 3 Air (Bq/m 3 ) Cesium-137 < Elemental Tritium 6 <2.0 5,100,000 Iodine-131 < HTO < Soil (Bq/kg dry weight) Cesium-137 < Vegetation (Bq/kg fresh weight 5 ) HTO ,900 Organically Bound Tritium (OBT) ,000 Apples (Bq/kg fresh weight) HTO ,000 OBT <1.5 50,300 Potatoes (Bq/kg fresh weight) HTO ,000 OBT ,000 Kales (Bq/kg fresh weight) HTO ,000 OBT <1.5 45,200 Milk (Bq/kg fresh weight) HTO 3.4 5,560 OBT 1.5 2,260 Meat Poultry (Bq/kg fresh weight) HTO ,000 OBT <1.5 85, The CNSC reference levels are established based on conservative assumptions about the exposure scenario and using CSA Standard N [47]. The reference level for a particular radionuclide in a particular medium (e.g., water, air, foodstuff) represents the activity concentration that would result in a dose of 0.1 msv per year, a dose at which no health impacts are expected. An activity concentration refers to the radioactivity of a quantity of radioactive material (Bq) that is measured in a specific mass or volume of media. 2. The < symbol indicates that a result is below the provided numerical laboratory analytical detection limit. 3. Health Canada Guidelines for Drinking Water Quality 4. Health Canada Guidelines for Drinking Water Quality Screening Level 5. Fresh weight refers to a sample that is on a wet basis, which means it includes both the weight of the solid and the water contained within the media, as opposed to a dry weight which only considers the solid phase of the media. 6. Tritiated water (HTO) is a radioactive form of water where the usual hydrogen atoms in H 2 O are replaced with tritium. Elemental Tritium refers to the radioactive form of hydrogen gas. 27

172 June 2015 Environmental Assessment Information Report 5. CONCLUSION The EA under the NSCA conducted for this licence application concludes that OPG has and will continue to make adequate provision for the protection of the environment and the health of persons. Through ongoing licensing and compliance activities and reviews, CNSC staff continue to verify and ensure that the environment and the health and safety of persons are protected at the Darlington NGS. 28

173 June 2015 Environmental Assessment Information Report ACRONYMS Acronym AECL AL ALARA APM Bq CANDU CEAA CMD CNL CNSC COG CSA DFO DRL DSC EA EC ECI EMS EMP ERA FUMP HLW HTO IAEA IEMP IIP ILW INES Term Atomic Energy of Canada Limited Action Level As Low As Reasonably Achievable Adaptive Phased Management Becquerel Canada Deuterium Uranium Canadian Environmental Assessment Act Commission Member Document Canadian Nuclear Laboratories Canadian Nuclear Safety Commission CANDU Owners Group Canadian Standards Association Department of Fisheries and Oceans Canada Derived Release Limit Dry Storage Container Environmental Assessment Environment Canada Emergency Cooling Injection Environmental Management System Environmental Monitoring Program Environmental Risk Assessment Follow-Up Monitoring Program High-Level Radioactive Waste Tritium International Atomic Energy Agency Independent Environmental Monitoring Program Integrated Implementation Plan Intermediate-Level Radioactive Waste International Nuclear Events Scale 29

174 June 2015 Environmental Assessment Information Report ISR IWST JRP LCH LLW msv NEW NFWA NGS NPP NSCA NWMO OBT OMNRF OPG PRA PROL RD SIO TRF UNSCEAR WHO WMF Integrated Safety Review Injection Water Storage Tank Joint Review Panel Licence Condition Handbook Low-Level Radioactive Waste millisievert Nuclear Energy Worker Nuclear Fuel Waste Act Nuclear Generating Station Nuclear Power Plant Nuclear Safety and Control Act Nuclear Waste Management Organization Organically Bound Tritium Ontario Ministry of Natural Resources and Forestry Ontario Power Generation Inc. Probabilistic Risk Assessment Power Reactor Operating Licence Regulatory Document Safety Improvement Opportunities Tritium Removal Facility United Nations Scientific Committee on the Effects of Atomic Radiation World Health Organization Waste Management Facility 30

175 June 2015 Environmental Assessment Information Report REFERENCES [1] CNSC Regulatory Document, REGDOC-2.9.1: Environmental Protection: Environmental Protection Policies, Programs and Procedures, September 2013, [2] CSA Group, CSA N , Guidelines for Calculating Derived Release Limits for Radioactive Material in Airborne and Liquid Effluents for Normal Operation of Nuclear Facilities, Update No.1, May 2011 [3] CSA Group, CSA N288.4, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills, 2010 [4] CSA Group, CSA N288.5, Effluent Monitoring Program at Class I Nuclear Facilities and Uranium Mines and Mills, 2011 [5] CSA Group, CSA N288.6, Environmental risk assessment at Class I nuclear facilities and uranium mines and mills, 2012 [6] Commission Member Document (CMD) 15-H8, Submission from CNSC staff for Darlington Licence Renewal, August 19, 2015, e-doc: [7] CNSC Environmental Assessment Screening Report, The Refurbishment and Continued Operation of the Darlington Nuclear Generating Station, Municipality of Clarington, Ontario, March 2013, e-doc: [8] CNSC Record of Proceedings, Including Reasons for Decision, Ontario Power Generation - Environmental Screening Regarding the Proposal to Refurbish and Continue to Operate the Darlington Nuclear Generating Station, March 13, 2013, e-doc: [9] OPG Letter, B. Duncan & D. Reiner to F. Rinfret, OPG Submission of the DNGS Environmental Assessment Follow-up Program, October 2013, e-doc: [10] CNSC Regulatory Document, RD-360, Life Extension of Nuclear Power Plants, February 2008, [11] OPG Letter, B. Duncan & D. Reiner to F. Rinfret, Darlington NGS Request for CNSC Acceptance of Integrated Implementation Plan (IIP) Revision 002, April 2015, e-doc: [12] OPG Letter, B. Duncan to M. Leblanc, Darlington NGS Update on Ongoing Environmental Activities Arising from DNGS Refurbishment EA Decision 2013, December 2014, e-doc: [13] OPG Letter, B. Duncan to F. Rinfret, Darlington NGS - Thermal Plume Impacts on Round Whitefish, December 2014, e-doc:

176 June 2015 Environmental Assessment Information Report [14] OPG Letter, B. Duncan to F. Rinfret, Darlington NGS - OPG Submission of the DNGS Injection Water Storage Tank Spill (IWSTl Phase 2 Site Environmental Assessment, February 2015, e-doc: [15] Heath Canada, Canadian Guidelines for the Restriction of Radioactively Contaminated Food and Water Following a Nuclear Emergency, 2003 [16] Health Canada, Canadian Guidelines for Intervention During an Emergency, 2003 [17] ICRP Publication 72, Age-Dependent Doses to Members of the Public from Intake of Radionculides. Part 5 Compilation of Ingestion and Inhalation Dose Coefficients, Ann. InCRP 26 [18] OPG Letter, P. F. Tremblay to T.E. Schaubel & P.A. Webster, 2008 Results of Radiological Environmental Monitoring Programs, April 22, 2008, N-CORR , e-doc: [19] OPG Letter, L. Swami to T.E. Schaubel & P.A. Webster, 2009 Results of Radiological Environmental Monitoring Programs, April 26, 2010, N-CORR , e-doc: [20] OPG Letter, L. Swami to T.E. Schaubel & P.A. Webster, 2010 Results of Radiological Environmental Monitoring Programs, April 21, 2011, N-CORR , e-doc: [21] OPG Letter, L. Swami to M. Santini & P.A. Webster, 2011 Results of Radiological Environmental Monitoring Programs, April 26, 2012, N-CORR , e-doc: [22] OPG Letter, B. Reuber to M. Santini & F. Rinfret, 2012 Results of Radiological Environmental Monitoring Programs, April 23, 2013, N-CORR , e-doc: [23] OPG Letter, W. B. Reuber to M. Santini and F. Rinfret, 2013 Results of Environmental Monitoring Programs, April 25, 2014, e-doc: [24] OPG Letter, B. Reuber to M. Santini & F. Rinfret, 2014 Results of Environmental Monitoring Programs, April 24, 2015, e-doc: [25] Lane, R., Dagher, E., Burtt, J. and P. A. Thompson, Radiation and Incidence of Cancer around Ontario Nuclear Power Plants from 1990 to 2008 (The RADICON Study), J. Env. Prot, 4, , Room/healthstudies/Radiation-Incidence-Cancer-Around-Ontario-NPP.pdf [26] Walter SD, Marrett LD, Taylor SM, King D. (1999). An analysis of the geographic variation in cancer incidence and its determinants in Ontario. Can J Public Health. Mar-Apr; 90(2): [27] Altmayer CA, Hutchison BG, Torrance-Rynard VL, Hurley J, Birch S, Eyles JD. (2003). Geographic disparity in premature mortality in Ontario, Int J Health Geogr. Sep 25; 2(1):7. 32

177 June 2015 Environmental Assessment Information Report [28] Durham Region (2008). Durham Region Nuclear Emergency Evacuation Information: Annex B Durham Region Nuclear Emergency Response Plan [29] Durham Region (2011). Durham Region Nuclear Emergency Response Plan (DRNERP): Part II Durham Region Emergency Master Plan. Retrieved May 17, 2013 from [30] Spix C, Schmiedel S, Kaatsch P, Schulze-Rath R, and Blettner M. (2008). Case-control study on childhood cancer in the vicinity of nuclear power plants in Germany European Journal of Cancer 44(2): [31] Kaatsch P, Spix C, Schulze-Rath R, Schmiedel S, and Blettner M. (2008). Leukemia in young children in the vicinity of German nuclear power plants. International Journal of Cancer 122(4): [32] Bithell JF, Keegan TJ, Kroll ME, Murphy FG and Vincent TJ. (2008). Childhood leukemia near British nuclear installations: Methodological issues and recent results. Radiation Protection Dosimetry 132(2): [33] Spycher BD, Feller M, Zwahlen M, Röösli M, von der Weid NX, Hengartner H, Egger M, Kuehni CE. (2011). Swiss Paediatric Oncology Group; Swiss National Cohort Study Group Childhood cancer and nuclear power plants in Switzerland: a census-based cohort study. Int J Epidemiol. 40(5): [34] Heinävaara S, Toikkanen S, Pasanen K, Verkasalo PK, Kurttio P, Auvinen A. (2010). Cancer incidence in the vicinity of Finnish nuclear power plants: an emphasis on childhood leukemia. Cancer Causes Control. 21(4): [35] Tritium Studies Project Synthesis Report INFO-0800 Revision 1. Published by the Canadian Nuclear Safety Commission (CNSC) Catalogue number INFO-0800 Revision 1, Minister of Public Works and Government Services Canada 2011 Catalogue number CC172-56/2011E- PDF ISBN [36] Zablotska, L. B., Lane R. S. D. and P. A. Thompson, A reanalysis of cancer mortality in Canadian nuclear workers ( ) based on revised exposure and cohort data, 2014, British Journal of Cancer, 110, [37] OPG Submission, Derived Release Limits and Environmental Action Levels for Darlington Nuclear Generating Station, September 2011, NK38-REP R001, e-doc: [38] Canadian Nuclear Safety Commission, Scoping Information Document: Proposal by Ontario Power Generation for the Refurbishment and Continued Operation of the Darlington Nuclear Generating Station in the Municipality of Clarington, Ontario. October 2011, e-doc: [39] Commission Member Document (CMD) 14-M30, Study of Consequences of a Hypothetical Severe Nuclear Accident and Effectiveness of Mitigation Measures, June 19, 2014, e-doc:

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179 ~~ ONTARIOPOifiiER Document GENERATION Number: Usage Classification: Report N K38-REP N/A Sheet Number: N/A l ~ARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Revision: R002 Ontario Power Generation Inc., This document has been produced and distributed for Ontario Power Generation Inc. purposes only. No part of this document may be reproduced, published, converted, or stored in any data retrieval system, or transmitted in any form or by any means (electronic, mechanical, photocopying, recording, or otherwise) without the prior written permission of Ontario Power Generation Inc. Darlington NGS Integrated Implementation Plan (lip) NK38-REP R Prepared by: Section Manager Nuclear Safety Integration Nuclear Refurbishment Prepared by:.ild-ck- Reviewed by: A~ JI,.:b15 Reviewed by: I 2( 20/~ Thomas Lau Manager Nuclear Safety Integration Nuclear Refurbishment /.p Date /4A - ~21;P;ir l,d.fi r tl'v~ ~ Behzad Alavi Date I Reviewed by: Senior Manager Plant Aging Management Director Nuclear Safety Nuclear Refurbishment Date ~ 21-AP&>2o," f<f' eft Lehman Director Station Engineering Darlington NGS Date Approved by: ~ l~ Approved by: ~===-~~------~~F-~~ Dietmar Reiner Senior Vice President Nuclear Projects Date Associated with OPG-PROC-0019, Record and Document Management OPG-TMP-0003-R003 (Microsoft 2007)

180 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R002 2 of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Table of Contents Page List of Tables and Figures... 3 Revision Summary INTRODUCTION CNSC Review and Assessment of the GAR and IIP INTEGRATED IMPLEMENTATION PLAN (IIP) SCOPE IIP SCHEDULE DESCRIPTION OF APPENDICES Appendix A: Open Activities...11 Appendix B: Completed Activities...50 Appendix C: IIP Mapping...61 Appendix D: Integrated Aging Management Program...75 Appendix E: Glossary...77 Appendix F: References...79 OPG-TMP-0003-R003 (Microsoft 2007)

181 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R002 3 of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN List of Tables and Figures Page Tables Table 1: EA Mitigation Measures (Open Activities)...12 Table 2: Follow-up Program Elements (Open Activities)...15 Table 3: CCAs (Open Activities)...21 Table 4: Code Gaps (Open Activities)...31 Table 5: EA (Completed Activities)...50 Table 6: CCAs (R001 Completed Activities)...51 Table 7: CCAs (R002 Completed Activities)...51 Table 8: Code Gaps (R001 Completed Activities)...52 Table 9: Code Gaps (R002 Completed Activities)...57 OPG-TMP-0003-R003 (Microsoft 2007)

182 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R002 4 of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Revision Summary Revision Number Date Comments R Initial Issue R General - Revised IIP to reflect feedback received following CNSC staff initial review [R-6] Section Added Section 1.1 CNSC Review and Assessment of the GAR and IIP Section Added the IIP Criteria used for the CCA and Code Gap IIP Commitments. Section High-level expectation of schedule has been provided. - Life Extension Model has been removed. Major Activities - Major Activities have been removed as they are identified in the respective IIP Commitment tables located in the Appendices. IIP Change Control Process - The IIP Change Control Process has been limited to a high-level description. Specific details will be described in the IIP Change Control Process document. Tables - Removed Roadmap of Items Considered in the Development of the IIP. Appendices - Appendix A identifies the Open IIP Commitments for EA, CCAs and Code Gaps. - Appendix B identifies the IIP Commitments that have been completed for EA, CCAs and Code Gaps. - Appendix C identifies the IIP Item Number mapping between IIP R000 and IIP R Appendix D describes the Integrated Aging Management Program. R General Revised IIP to reflect feedback received from CNSC staff of IIP R001 [R-7]. Section 3.0 Clarified TRF work to be managed by TRF lifecycle planning Section 5.0 Removed as managed systems instruction for Change Control and Close-out of actions has been issued Appendix A Removed items completed since R001 issuance Appendix B Inserted items completed since R001 issuance Appendix C Updated table for completed items OPG-TMP-0003-R003 (Microsoft 2007)

183 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R002 5 of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN 1.0 INTRODUCTION The Darlington Nuclear Generating Station, also referred to here as Darlington, is a four-unit generating station that includes a separately housed Tritium Removal Facility (TRF). The site is located in the Municipality of Clarington, Regional Municipality of Durham, in the Province of Ontario. Darlington has operated successfully since the early 1990s and a program has been implemented to extend the life of the plant for 30 additional years. The justification for the continued operation of Darlington following Life Extension is documented in a Global Assessment [R-1] carried out in accordance with the Canadian Nuclear Safety Commission (CNSC) Regulatory Document RD-360, Life Extension of Nuclear Power Plants [R-2]. The regulatory document, hereafter referred to as RD-360, requires the licensee to demonstrate that continued station operation poses no unreasonable risk to health, safety, security of the public or the environment, and will continue to conform to international obligations. The results from the Global Assessment [R-1] demonstrated that Darlington is a safe and reliable nuclear power plant today. Implementation of the improvements, as documented here, will result in Darlington being an even safer and more reliable source of clean electrical power to the Province of Ontario for another 30 years. Three principal activities were undertaken by OPG to systematically identify the environmental and safety enhancements that will assure ongoing safe operation for 30 additional years: 1. Environmental Assessment (EA) The EA is a comprehensive assessment of the potential impacts of refurbishment and continued operation on the natural environment including public safety and socio-economic considerations. The EA is focused on the impacts beyond the plant boundary. The EA determined that refurbishment and continued operation of Darlington, given the mitigations described, will not have significant adverse environmental impacts. The results of the EA are contained in the Environmental Impact Statement [R-3], the technical support documents, and the CNSC decision as documented in the CNSC s Record of Proceedings [R-4]. 2. Integrated Safety Review (ISR) The ISR is a systematic and comprehensive assessment of the plant design and actual condition, and of the management system used to operate and maintain the nuclear plant. The ISR enabled determination of the reasonable and practical modifications that should be made to the plant design or the management system to further enhance future safe operation. The results of the ISR are documented in a series of reports based on established Safety Factor review topics listed in N- PROC-LE-0005 Nuclear Refurbishment Integrated Safety Review Darlington [R-5]. OPG-TMP-0003-R003 (Microsoft 2007)

184 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R002 6 of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN 3. Global Assessment (GA) The Global Assessment used the results of the EA and ISR and examined them in an integrated manner. It assessed the strengths, opportunities for improvement, and actions to address the opportunities for improvement, in order to provide an overall judgment on the acceptability of the risk arising from continued operation. The GA further assessed the adequacy, and implementation timing of the actions arising from the EA and ISR that are identified to extend the life of the plant. The IIP presents the scope and schedule for the implementation of actions identified through the ISR and the EA. 1.1 CNSC Review and Assessment of the GAR and IIP Canadian Nuclear Safety Commission (CNSC) staff completed their review and assessment OPG s submission of the Global Assessment Report (GAR) and Integrated Implementation Plan (IIP). As documented in the CNSC correspondence letter [R-6], OPG s GAR as submitted was acceptable to CNSC staff as it meets all applicable requirements of RD-360. CNSC staff accepted OPG's lip Revision 001 with implementation of several required specific changes [R-7]. OPG-TMP-0003-R003 (Microsoft 2007)

185 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R002 7 of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN 2.0 INTEGRATED IMPLEMENTATION PLAN (IIP) SCOPE The scope of OPG s Integrated Implementation Plan (IIP) includes: Mitigating measures and follow-up program activities from the Environmental Assessment (EA) Actions from the Integrated Safety Review: o o o Recommendations from Component Condition Assessments (CCA); Actions to close gaps identified through the balance of the Integrated Safety Review (ISR) and CNSC questions; and Actions resulting from the review of updates to modern ISR Codes and Standards and significant operating experience since the submission of the ISR to the end of The Environmental Assessment (EA) The scope of the IIP resulting from the EA includes the mitigation measures, the Safety Improvement Opportunities (SIO s) committed in the EA and the follow-up program elements. The mitigation measures and SIOs address potential environmental effects. The follow-up program elements are actions to confirm that the predictions of environmental effects are accurate post refurbishment, and that the mitigation measures are effective. 2. Components Condition Assessments (CCAs) CCAs were performed on critical components to determine condition, reliability of material and to ensure that required activities are in place to monitor the condition of the components going forward; or that components are repaired or replaced as necessary to ensure good system performance as the plant ages. The Aging and Actual Condition of SSCs Safety Factor Report presented a preliminary list of recommended actions required to allow each unit within the station to reach the end of its current life, as well as actions to be undertaken during and following the refurbishment. Actions to address issues identified in the CCAs are included in the IIP based on the following criteria: Components that are part of the 58 Safety Related Systems identified in the ISR; and Components have high nuclear Safety Significance (Reactor Safety 1 or 2); and OPG-TMP-0003-R003 (Microsoft 2007)

186 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R002 8 of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Components with a condition of less than Good, and the activities to bring them to Good condition are not already part of normal station maintenance; or Components rated with a condition of Good based solely on past performance history and no physical inspections have been done. Inspection activity is required to confirm actual physical condition of component; Actions resulting from the CCA Recovery Project are included in the IIP if they met the criteria outlined above. Any future CCA actions that meet the above criteria will be processed in accordance with the Aging Management Process [R-8]. 3. Code Gaps As part of the ISR, safety improvements were proposed to address gaps with respect to safety requirements identified during the review of modern codes and standards identified in N-PROC-LE-0005 [R-5]. Related gaps were consolidated into ISR Issues for prioritization and resolution. The safety significance of these ISR Issues was assessed in accordance with the Issue Prioritization Process N- INS [R-9]. The code gaps have been consolidated into ISR Issues; ISR Issues with similar resolutions have been consolidated with a single action plan and completion date. TRF actions have been removed from the IIP as they will be managed by the TRF life cycle plan. IIP scope will be monitored to completion and closed out through its own approved processes. Normal component ageing for the remaining station life will be managed in accordance with the Integrated Aging Management (IAM) Program N- PROG-MP-0008 [R-10] and executed as part of normal station practices. The IAM Program ensures that the condition of critical equipment is understood and that activities are in place to ensure the health of these components and systems while the plant ages. Elements of the IAM Program are detailed in Appendix D. OPG-TMP-0003-R003 (Microsoft 2007)

187 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R002 9 of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN 3.0 IIP SCHEDULE The Darlington Life Extension Plan is to have: EA activities implemented in accordance with the EA Screening Report and EA Follow Up Program Report; The majority of unit specific physical work completed prior to restart of the first complete maintenance outage following the Refurbishment Outage for each respective unit; The majority of inspections required to confirm condition completed prior to unit restart from each respective Refurbishment Outage. The timing to execute contingency actions (repairs or replacements resulting from inspections) will be determined by using a graded approach: o o o Inspection results that are favourable will require no further action; Inspections revealing minor degradation will require either enhanced monitoring or will be addressed by normal station practices; Inspections revealing safety significant defects that would prevent unit start-up will be prioritized in alignment with the Technical Operability Evaluation Process N-PROC-MP-0045 [R-11] and corrected as required prior to unit restart of each respective Refurbishment Outage. The majority of safety improvements applicable to the entire station will be implemented prior to the restart from the Unit 2 Refurbishment Outage; Specific year end completion dates have been identified for all actions in the IIP for unitized and non-unitized work, unless otherwise noted. There are cases where the activity will be completed by the restart of a unit outage rather than the year end date. These details have been provided in the Date column of the subsequent tables. OPG-TMP-0003-R003 (Microsoft 2007)

188 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN 4.0 DESCRIPTION OF APPENDICES Appendix A - IIP Commitments Activities identified in Appendix A are open actions which are required for Life Extension. These include: EA Mitigation Program Elements including SIO s (Table 1); EA Follow-Up Monitoring Program Elements (Table 2); Component Condition Assessments (Table 3); Code Gaps (Table 4). Appendix B - Completed Activities Activities identified in Appendix B have been completed since the submission of IIP R000 and R001. These include: EA Activities (Table 5); Component Condition Assessments (Table 6,7); Code Gaps (Table 8, 9). Reference to the associated completion documentation has been provided. Appendix C - IIP Mapping In R001 of the IIP, new IIP Item Numbers were assigned to each activity as multiple line items were consolidated into a single line item. Appendix C identifies the mapping between the IIP Item Number in IIP R000 and IIP R001. The numbering established in R001 of the IIP remains the same in R002 of the IIP. Appendix D Integrated Aging Management Program Appendix D describes the elements of the OPG equipment aging management process. OPG-TMP-0003-R003 (Microsoft 2007)

189 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Appendix A: Open Activities Table 1 is a summary of the activities to address the EA Mitigation Measures. Table 2 is a summary of the activities to address EA Follow-up Program Elements. The following is a brief description of the columns for both tables: 1. The IIP Item Number column lists a unique identifier. This number remains the same as was produced in R001 of the IIP. Appendix C identifies the mapping between the IIP Item Number in IIP R000 and IIP R The Environmental Component column identifies the source reference(s) for the line item. 3. The Mitigation Objective or Monitoring and Follow-up Objective column lists the high level mitigation measure or follow-up program elements. 4. The Action Plan column lists the proposed strategy to meet the objectives of the mitigation measures and follow-up program elements. 5. The Tracking Number column lists the Action Request (AR) number or Darlington Scope Request (DSR) number that internally tracks each item to completion. 6. The Completion Date column identifies the year end date in which the identified actions will be completed. Refurbishment Outage completion dates are linked to the Refurbishment Outage restart dates and not the year end date.

190 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Table 1: EA Mitigation Measures (Open Activities) IIP Item Number IIP-EA 001 Environmental Component (Reference) Aquatic CNSC Screening Report - page 90 Mitigation Objective (In design and Additional Mitigation Measures) Mitigate fish impingement and entrainment losses by means of offsetting. Action Plan Tracking Number Completion Date 1) Evaluate the need for a Fisheries Act authorization and document rationale for decision. Reference: NK38-CORR Authorization under the Fisheries Act for DNGS Complete [R-13] 2014 (also in EIS Table 5.15) 2) Submit application to obtain authorization under section 32 of the Fisheries Act as appropriate. Complete [R-14] 2014 Application will assess the need for long term impingement and entrainment monitoring beyond those required as part of the Follow-up monitoring program. 3) Develop any compensation program and update environmental monitoring program/procedures to include requirements defined by the Fisheries Act authorization which may include impingement and entrainment monitoring, thresholds to trigger review of mitigation options and compensation/offset program. AR# IIP- EA 003 Socio-Economics CNSC Screening Report page 108, 109 and 111 (also in EIS Table 5.15) Traffic and Transportation CNSC Screening Report page 107 (also in EIS Table 5.15) Reduce traffic disruption during peak periods and maintain safe traffic conditions both on-site and off-site during the Refurbishment Phase. 1) Develop a Traffic Management Working Group (TMWG) Terms of Reference between the interested parties (OPG, Ministry of Transportation, Durham region and Clarington) to plan a coordinated program of road improvements to maintain safe and efficient transportation operations in the Local Study Area. Darlington Nuclear Traffic Management Working Group (TMWG), NK38-CORR , provides the Terms of Reference (purpose, mandate, scope of activities, membership, schedule and agenda/minutes) 2) Develop and implement a Travel Demand Management (TDM) program to reduce and control DN site traffic during peak periods and to reduce disruption to the use or enjoyment of community and recreational facilities on or off the DN site. Issue a report documenting the TDM initiatives that were implemented. TDM initiatives will consider shift changes at times other than traditional peak travel periods; shuttle/transit service to DN site, and carpool incentives. Complete [R-15] AR# ) Perform an assessment to confirm effectiveness of traffic management and travel demand management initiatives by periodically assessing levels of service at key intersections and road links during Refurbishment phase (until Horizon 2021 which represents peak Project-related traffic conditions). AR#

191 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP- EA 005 Environmental Component (Reference) Socio-Economics CNSC Screening Report page 110 and 111 (also in EIS Table 5.15) Mitigation Objective (In design and Additional Mitigation Measures) Inform neighbours and the public of the refurbishment project and ongoing activities of the DNGS operations. Action Plan Tracking Number Completion Date 1) Ensure activities to periodically inform the public about the progress of the Project; share information with key stakeholders regarding the timing and magnitude of the onsite labour force; and work in partnership with government and educational institutions through existing liaison mechanisms and programs, are identified in communication plans in accordance with NK38-PLAN Refurbishment Program Communications Plan. Issue annual communication reports documenting the above. AR# to report completed [R-16] Annually from 2014 to 2025 IIP-EA 006 Socio-Economics CNSC Screening Report page 110 (also in EIS Table 5.15) Minimize disruption of recreation facilities and amenities on the DN site which includes maintaining public access to the Waterfront Trail. 2) Communicate information to the public based on level of public interest of station operations, activities, and anticipated effects on environment and the health and safety of persons. Nuclear Public Information and Disclosure, N-STD-AS-0013 defines the on-going public and stakeholder communication program. 1) Establish and maintain agreements with the Municipality of Clarington to ensure safe public access of the Waterfront trail that traverses the DN site. Site Plan Agreement (G14375) item #8 specifies the OPG lands set aside for the Waterfront trail and the Licensing agreement (Licence P502128) for the Waterfront trail. 2) Undertake a Recreational User Survey of DN site recreation facilities for two seasons in one year after the restart of all reactors. AR# to report completed [R-16] Complete [R-17] [R-18] AR# Annually from 2014 to ) Results of the Recreation User Survey will be reviewed as part of the DN Public Affairs program and with the Community Advisory Committee. AR#

192 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-EA 009 Environmental Component (Reference) Accidents & Malfunctions CNSC Screening Report Section Mitigation Objective (In design and Additional Mitigation Measures) Implement the following design modifications as identified in Section in the CNSC Screening Report through the Safety Improvements for the DNGS Refurbishment Project. Credit for these improvements were taken in the EA resulting in RC7 as the representative accident scenario: 1. Containment Filtered Venting System (CFVS) 2. Powerhouse Steam Venting System (PSVS) 3. Third Emergency Power Generator (EPG) 4. Provision of Alternate and Independent Supply of Water to Heat Transport System (Emergency Heat Sink). Implement the following modifications: Action Plan Tracking Number Completion Date 1) A Containment Filtered Venting System (CFVS). The purpose of the CFVS is to provide controlled and filtered emergency venting of containment to prevent overpressurization and assure containment integrity in the unlikely event of a multi-unit Severe Accident. A Severe Accident is a Beyond Design Basis Accident 1 (BDBA) that involves significant core degradation. To enhance the CFVS modification, a Shield Tank Overpressure Protection modification will be implemented. The purpose of this modification is to enhance the relief capacity of the shield tank surrounding each unit s calandria vessel to prevent shield tank catastrophic failure and to limit the containment over pressurization in the unlikely event of a multi unit Severe Accident. 2) Powerhouse Steam Venting System (PSVS) enhancements. These enhancements are related to duplication of the programmable controller logic of the current PSVS to improve the reliability of the PSVS which is an important system to protect plant systems following a steam line break. DSR# IP DSR# IP DSR# SI U0: U3: 2015 U4: U1: U2: 2019 (Refurbishment Outage Restart) U1: U2: U3: U4: ) A third Emergency Power Generator (EPG3). The third EPG is planned to be able to withstand a seismic event which is more demanding than the Design Basis Earthquake for which the existing two EPGs are designed, and to increase emergency power reliability when one EPG is not available. A Design Basis Earthquake is a representation of the combined effects, at the site, of a set of possible earthquakes having a very small probability of being exceeded during the life of the plant. 4) Provide an alternate and independent source of Emergency Water supply to the Heat Transport System by: a. Installing Emergency Mitigation Equipment. b. Installing permanent Fire Water pumps and a permanent line from the Emergency Service Water System to the Heat Transport System and using an existing Emergency Coolant Injection System line for injection to the Heat Transport System.. DSR# SI Complete [R-19] DSR# SI U0: U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) 1 A BDBA is an event with a frequency of occurrence less than 1 in 100,000 reactor years. 2 Activity will be completed prior to U2 Refurbishment breaker-open. 3 Activity will be completed prior to U2 Refurbishment Outage Restart (breaker-closed) and prior to bulkhead installation.

193 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Table 2: Follow-up Program Elements (Open Activities) IIP R001 Item Number IIP EA-010 Environmental Component (Reference) Surface Water CNSC Screening Report page 167 Monitoring and Follow-up Objective Action Plan Tracking Number Completion Date Characterize the conventional chemical (i.e., nonradiological) parameters present in DNGS effluent streams. 1) Develop a sampling plan. Measured parameters will be based on sources of chemicals, metals of construction (e.g. corrosion product transport), and review of Constituents of Potential Concern (COPCs) considered in the EA studies (see Non-Human Health Ecological Risk Assessment TSD (OPG 2011d) and Human Health TSD (OPG 2011e)). The monitoring frequency will be determined considering the range of conditions encountered under normal operations. Proposed sample locations are at the point of discharge (i.e., MISA or ECA control point). Condenser cooling water (CCW) sampling is also proposed as confirmation of the parameters measured in the systems and to compare with ECA limits. Complete [R-20] ) Conduct effluent characterization according to sampling plan. 1 3) Document and report findings. Update the Liquid Effluent Assessment performed during the EA studies considering the results of the effluent characterization. The measured concentrations will be used to identify Constituents of Potential Concern (COPC). Assess the exposure to the COPCs and provide an assessment of environmental risk to receptors. The ERA will be revised according to these new insights. If the ERA identifies new environmental issues or the need to study an environmental issue further, additional site data may be needed to refine exposure calculations, reduce uncertainty and identify risk management or remediation measures if required. These recommendations identified as part of this follow-up program element will be addressed as part of compliance with CSA N288 series standards and incorporated in the site Emergency Management Plan accordingly, and this follow-up monitoring will be complete. AR# AR# Activity will be completed prior to U2 Refurbishment breaker-open.

194 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP EA-011 Environmental Component (Reference) Surface Water CNSC Screening Report page 167 Monitoring and Follow-up Objective Action Plan Tracking Number Completion Date Confirm the effectiveness of mitigation measures to protect stormwater quality in the area subject to refurbishment activities (i.e., Protected Area). 1) Develop a sampling plan. Measured parameters will include MISA parameters as well as other historic relevant parameters based on water quality monitoring. The sample design should be based on the methodologies employed in the DNGS EA to allow comparison with historical studies. Sampling locations will be established during development of the study plan and focus on areas within the Protected Area (e.g., 2010/2011 stormwater control study catchment areas K1, K2, K3, J, L and M). AR# ) Conduct a stormwater control study according to the sampling plan. AR# ) Document and report findings. Include a comparison to previous stormwater sampling results and recommendation for additional monitoring if required. AR# IIP EA-012 Aquatic CNSC Draft Report page 97, 160 and 168 (Also in EIS Table ) Confirm the accuracy of the predictions made in the EA concerning changes in lakewater temperatures in the vicinity of the CCW discharge, and their associated possible effects on survival rates for round whitefish embryos. 1) Obtain and review the results of an in-progress CANDU Owners Group (COG) study examining thermal effects to round whitefish eggs over the two winter seasons (2011/2012 and 2012/2013). 2) Develop a sampling plan. A Thermal Monitoring Protocol Agreement established through consultations with regulatory agencies and other stakeholders will be included in the sampling plan. The Protocol should consider the results of the COG study in establishing: Thermal benchmark(s) for comparison of measured values. Determination of location(s) for ambient water temperature monitoring; and Temperature thresholds that would trigger adaptive management response (e.g., increased thermal monitoring). 3) Implement annual ambient water temperature monitoring. 4) Conduct thermal monitoring during Refurbishment outage. 5) Report monitoring data collected during Refurbishment outage and assess likely effects on the survival of round white fish embryos. If the performance threshold is exceeded, review available mitigation options to determine if additional technically and economically feasible opportunities are available to further reduce the potential for effects. 6) Conduct thermal monitoring after restart of all reactors (i.e. Continued Operation phase). 7) Report monitoring data collected during Continued Operation phase and assess likely effects on the survival of round white fish embryos. If the performance threshold is exceeded, review available mitigation options to determine if additional technically and economically feasible opportunities are available to further reduce the potential for effects. Complete [R-21] AR# AR# AR# AR# AR# AR#

195 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP EA-013 Environmental Component (Reference) Aquatic Monitoring and Follow-up Objective Action Plan Tracking Number Completion Date Benthic Invertebrate Community Study Benthic Invertebrate Community Study CNSC Screening Report pages 168 to 171 (Also in EIS Table and Adaptive Management for Impingement and Entrainment Effects During Continued Operations of DNGS (Discussion Draft)) Determine baseline abundance and species diversity of benthic invertebrates in the vicinity of the DNGS intake. Species presence will be classified to order (or genus if possible) and will be compared to future entrainment study results. These benthic results will also be compared to near shore benthic studies conducted in 2008 in the vicinity of the proposed New Nuclear at Darlington (NND) infill area. Entrainment Monitoring Characterize early life stages of fish and macro invertebrates being entrained by station operation. The sampling should be conducted in a manner sufficient to reflect the diel and seasonal cycles in organism abundance within the capture zone of the intake; Monitor at a level capable of detecting fish Species at Risk and aquatic species of conservation concern that have been identified by provincial or federal agencies. Sampling should target species based on life history characteristics and potential for interaction with station operation; and, Determine the total fish and macro invertebrate losses and associated impact. 1) Develop a sampling plan for Benthic Invertebrate Community Study in the vicinity of DNGS intake. 2) Conduct Benthic Invertebrates Community study. 1 3) Document and report findings including a comparison to the 2008 study in the vicinity of NND. Entrainment Monitoring 1) Develop a sampling plan which includes entrainment sampling methodology. The selected methodology will consider methodologies from other jurisdictions. Sampling plan should include development of performance threshold(s) for impingement and entrainment (i.e. unacceptable levels of impingement and entrainment losses especially in reference to Species at Risk and aquatic species of conservation concern) through consultations with regulatory agencies and other stakeholders. 2) Using the methodology developed from activity 1), conduct entrainment study prior to start of the refurbishment outage. AR# AR# AR# AR# AR# Impingement and Entrainment 3) Document and report findings. AR# Characterize early life stages of fish and macro invertebrates being entrained and fish impinged by station operation. The sampling should be conducted in a manner sufficient to reflect the deil and seasonal cycles in organism abundance within the capture zone of the intake; Monitor at a level capable of detecting fish Species at Risk and aquatic species of conservation concern that have been identified by provincial or federal agencies. Sampling should target species based on life history characteristics and potential for interaction with station operation; and, Determine the total fish and macro invertebrate losses and associated impact. Impingement and Entrainment 1) Prepare sampling plan for impingement and entrainment. 2) Conduct impingement and entrainment monitoring according to the sampling plan. AR# AR# Activity will be completed prior to U2 Refurbishment breaker-open.

196 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number Environmental Component (Reference) Monitoring and Follow-up Objective Action Plan Tracking Number Completion Date 3) Document and report findings. If the performance threshold(s) are exceeded, review available mitigation options to determine if additional technically and economically feasible opportunities are available to further reduce the potential for effects (see Section 3.3). AR# IIP EA-014 Malfunction and Accidents CNSC Screening Report page 169 Update the station PRA to confirm that the assignment of probabilities appropriately represent the SIO changes. This will take place after the station design has been finalized, all the design changes with supporting Safety Analysis and procedural documents (e.g., Emergency Operating Procedures, Abnormal Incident Manual) and the plant modifications are declared Available for Service (AFS) are complete prior to bringing the refurbished units back on-line. The PRA will be updated and reported to the CNSC as per S-294 requirements. 1) Provide the SIO implementation status update prior to the restart of each the refurbished units. 2) Once all of the refurbished units are back on-line, update the PRA to reflect the plant changes in all units. A review of the PRA results will be completed to confirm that the event frequencies predicted in the EA based on conceptual design features are consistent with the installed equipment. AR# ,-10,-11,-12 AR# U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) 2026

197 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP EA-015 Environmental Component (Reference) Effects of the Environment on the Project CNSC Screening Report page 169 Monitoring and Follow-up Objective Action Plan Tracking Number Completion Date Confirm the liquefaction potential of foundation materials in the Protected Area is acceptably low. 1) Carry out a review including the following general steps: Compile and review all available data regarding the fill material in the Protected Area where there are relevant safety-related systems, structures and components on their liquefaction potential. This material is readily available from sources accessed for the EA studies and the ISR. AR# (U2 Refurbishment Outage Restart) For contextual purposes, review the geotechnical conditions relevant to the construction history for DNGS. Based on relevant collected data, undertake an evaluation of the stability of the fill materials with regard for liquefaction potential under seismic and static load conditions. The evaluation criteria will be established based on the objectives, scope and methods adopted for the evaluation program. They will incorporate geotechnical guidance and standards as they are appropriate and applicable. Should sufficient verification not be realized for the prediction of low liquefaction potential, recommendations for further investigation will be provided as appropriate. 2) If required, conduct a liquefaction assessment study based on recommendations of the review in activity 1). AR# (U2 Refurbishment Outage Restart)

198 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Table 3 provides a summary of the activities to address CCAs in support of the ISR. The activities are categorized based on whether they were identified based on input from the Major Components Program [R-22] or from the ISR System Reviews which is documented in the Aging and Actual Condition of SSCs Safety Factor Report [R-23]. The following is a brief description of the columns in the table: 1. The IIP Item Number column lists a unique identifier. This number remains the same as was produced in R001 of the IIP. Appendix C identifies the mapping between the IIP Item Number in IIP R000 and IIP R The CCA column lists a sequential CCA number, if applicable, for the Commodity Group included in a particular system. 3. The System column lists the applicable system. 4. The Description column lists the name of the Commodity Group (e.g. Vault Coolers). This is the generic name for components in a Commodity Group. 5. The Condition column lists the overall condition of components in each Commodity Group, if applicable. The condition is ranked Very Good, Good, Satisfactory, Poor or Very Poor in accordance with Section of N-PROC-MP-0060 [R-8]. Condition Classification Very Good Good Satisfactory Poor Very Poor Criteria a) The component meets all functional design requirements, with no reduction in operating margin and exhibits no apparent degradation, i.e., is in like new condition, and b) The ageing management practices have been optimized to ensure the component remains in a like new condition. a) The component meets all its functional design requirements, with only a slight reduction in operating margins. Some slight ageing degradation is evident, or b) The ageing management practices are adequate but have not been optimized to ensure that the component remains in like new condition. a) The component still meets all its functional design requirements, but operating margins are significantly eroded. This can be attributed to evidence of significant ageing degradation, or b) The ageing management practices are ineffective in only one area and should be reviewed and/or changed. a) The component can only marginally meet its functional design requirements and has lost all its operating margin. Severe aging degradation is evident, or b) The ageing management practices are ineffective in a number of areas and need to be revised. a) The component cannot meet one or more of its functional design requirements The component needs immediate or near term maintenance, repair and/or replacement to restore its condition, or b) The current ageing management practices are completely ineffective and need revision. 6. The Activity Description column identifies the required activities to resolve the issues or recommendations. A detailed assessment of adequacy of these activities to address the identified degradation by the CCAs was performed as part of the Global Assessment. 7. The DSR# column identifies the tracking number originating from the Darlington Scope Request (DSR) Database in accordance with NK38-INS [R-24]. 8. The Date column either identifies the end year or the unit restart date in which the IIP item will be completed. A date for each affected unit is provided, if applicable.

199 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP-CC 001 N/A N/A Shutdown Cooling Pumps Table 3: CCAs (Open Activities) CCA System Description Condition Activity Description DSR# Date N/A Install two Shutdown Cooling (SDC) "Auxiliary" pumps which are physically separate and of diverse design than the existing SDC pumps. TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) IIP-CC 002 N/A Major Components Program Feeders N/A Replace Feeders TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) IIP-CC 003 N/A Major Components Program Fuel Channels N/A Replace Fuel Channels TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) IIP-CC 004 N/A Major Components Program Calandria Tubes N/A Replace Calandria Tubes TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) IIP-CC 005 N/A Major Components Program End Fittings N/A Replace End Fittings TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) IIP-CC 006 N/A Major Components Program Calandria N/A Conduct an internal inspection of the calandria TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) IIP-CC 007 N/A Major Components Program Lattice Tubes N/A Perform visual inspection of all Lattice Tubes for leaks TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart)

200 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP-CC G.05 Boiler Feedwater System, USI# 43000, System #: 0005 CCA System Description Condition Activity Description DSR# Date IIP-CC Class II Power System, USI# 50320, System #: 0011 IIP-CC Class IV Power System, USI# 50340, System #: 0013 IIP-CC Digital Control Computers System, USI# 69000, System #: 0016 IIP-CC Emergency Coolant Injection System, USI# 34320, System #: 0018 Auxiliary Boiler Feed Pumps Good Perform an internal inspection of a selected Auxiliary Boiler Feed Pump. Repair/replace based on inspection results. 1 Distribution Bus Satisfactory Clean and test MCC (three 120/208Vac buses per unit) per NK38-CMP IP U2: U3: U1: U4: (Each Unit Refurbishment Outage Restart) TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) TS U0: 2019 Transformers, 4 kv Poor Complete the tapchanger bypass modification on 0- (10MVA) (silicone) T59 and T60. Computer - DCC Satisfactory Replace the DCC, CP and SEM CPUs. TS U0-U4: 2024 Check Valves > 3" Good Inspect representative sample of check valves (3 of 10 large NVs) and repair as required 5. 2 TS U0: (U2 Refurbishment Outage Restart) IIP-CC Emergency Coolant Injection System, USI# 34320, System #: 0018 IIP-CC Emergency Coolant Injection System, USI# 34320, System #: 0018 Check Valves < 3" Good Inspect representative sample of NVs and repair as required 5. Heat Exchanger (HX) R/S Satisfactory Inspect the inlet and outlet nozzles of HX1 and HX2 for pitting corrosion. TS U3: 2018 U4: 2019 U1: 2020 U2: 2022 (Each Unit Planned Outage Restart) TS U0: (U2 Refurbishment Outage Restart) IIP-CC Emergency Coolant Injection System, USI# 34320, System #: 0018 IIP-CC Emergency Filtered Air Discharge System, USI# 73750, System #: 0019 IIP-CC Emergency Filtered Air Discharge System, USI# 73750, System #: 0019 IIP-CC Emergency Power Generators System, USI# 49200, System #: 0020 Hydraulic Power Unit Satisfactory Conduct a detailed study to evaluate options for potential ECI Hydraulic Control Circuit replacement. TS Moisture element Satisfactory Replace 4 moisture probes and transmitters for TS U0: 2023 EFADS. Rad Monitor computer Satisfactory Replace EFADS computer and associated TS U0: 2023 and peripherals. components. Gas Producer / Power Poor Replace EPG 1 and EPG2 degraded Gas Generator. 3 TS U0: 2019 Turbine Unit 4 If safety significant defects are found as a result of inspections, they will be corrected by the date specified. 5 Sample sizes for inspections are based on similarity of materials of construction, fabrication, procurement, design, installation, operating conditions/environment, system function, location, existing technical information, system and structure design, OPEX and previous failure history

201 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP-CC Emergency Service Water System, USI# 72800, System #: 0022 CCA System Description Condition Activity Description DSR# Date Butterfly and Ball MOV (EQ) Satisfactory Replace valve body on MV29, MV30, MV34, & MV35. TS Replace U0: 2015 IIP-CC Emergency Service Water System, USI# 72800, System #: 0022 Globe and Gate Valve Motor Operated (MV) Satisfactory Overhaul actuator on MV29, MV30, MV34, & MV35 and overhaul PAWCS HX1 ESW Supply Valve MV168, based on inspection results. Inspect/overhaul and/or replace ECIS IWST ESW Supply valve. Replace bellows assembly IWST ESW supply valve (plug, bonnet included in the assembly). Overhaul or replace ESW steam generator injection valves. Overhaul U0: 2022 (U2 Planned Outage Restart) TS U0: 2015 U3: 2018 U4: 2019 U1: 2020 U2: 2022 (Each Unit Planned Outage Restart) IIP-CC HVAC System for Main Control Room & Secondary Control Area, USI# 73910, System # 0032 IIP-CC Main Condensate System, USI# 44000, System #: 0036 IIP-CC Miscellaneous Air Conditioning System, USI# 73940, System #: 0040 Fire Damper Satisfactory Test required fire dampers and replace as necessary. TS TS Drains Cooler/LP Heater Motor Operated Valves (RS) Air Conditioning Unit (RS) Satisfactory Inspect a representative sample of MVs to determine condition of stem, gate, seat and body. Overhaul/replace based on inspection 5. 1 TS TS U0: (U2 Refurbishment Outage Restart) U2: U3: U1: U4: (Each Unit Refurbishment Outage Restart) U3: 2018 U4: 2019 U1: 2020 U2: 2022 (Each Unit Planned Outage Restart) Satisfactory Replace the entire ACU. TS U012/U034/U1-U4: 2022 (U2 Planned Outage Restart) IIP-CC Miscellaneous Air Conditioning System, USI# 73940, System #: 0040 Fire Damper (FDP)- R/S Satisfactory Test required fire dampers and replace as necessary. 2 TS TS U0: (U2 Refurbishment Outage Restart) 4 If safety significant defects are found as a result of inspections, they will be corrected by the date specified. 5 Sample sizes for inspections are based on similarity of materials of construction, fabrication, procurement, design, installation, operating conditions/environment, system function, location, existing technical information, system and structure design, OPEX and previous failure history

202 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP-CC Miscellaneous Air Conditioning System, USI# 73940, System #: 0040 CCA System Description Condition Activity Description DSR# Date IIP-CC Moderator and Auxiliary Systems, USI# 32000, System #: 0042 IIP-CC Moderator and Auxiliary Systems, USI# 32000, System #: 0042 IIP-CC Negative Pressure Containment System, USI# 34200, System #: 0044 IIP-CC Negative Pressure Containment System, USI# 34200, System #: 0044 IIP-CC Powerhouse Ventilation System, USI# 73220, System #: 0050 Damper (DP)-R/S Satisfactory Do a sample inspection of the dampers and determine the scope of replacement. 1 Replace dampers as required 5. 2 Velan Swing Check Valves Satisfactory Overhaul X NV3/4/9/10/23/24/28 with new seat and disk material. Replace X NV112 in all units. Manual Valves Satisfactory Replace the following isolating valves: 1/2/3/ V52 V53 and 1/2/3/ V5, V6, V21, V22, V25, V26, and 1/2/3/ MV1, MV2, MV7, MV8, MV11, MV12, MV31, MV32 Radiation Detector and Monitor Piping (line) PRV VAC DWS TS TS TS TS U2: U3: U1: U4: (Each Unit Refurbishment Outage Restart) U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) Satisfactory Replace activity monitors. TS U012/U034/U1-U4: 2022 (U2 Planned Outage Restart) Good Develop program to address the aging related TS degradation mechanisms identified and perform condition assessment of the exposed piping to water and stagnant conditions. Air Cooling Units - R/S Satisfactory Replace ACU5 to 16, 1,2,3, ACU2 to 10, ACU17 to 22. TS U0: 2022 (U2 Planned Outage Restart) IIP-CC Powerhouse Ventilation System, USI# 73220, System #: 0050 IIP-CC Powerhouse Ventilation System, USI# 73220, System #: 0051 Fire Damper (FDP)- R/S Pneumatic Operator (PO)-R/S U3: 2018 U4: 2019 U1: 2020 U2: 2022 (Each Unit Planned Outage Restart) Satisfactory Test required fire dampers and replace as necessary. TS U012/U034: TS (U2 Refurbishment Outage Restart) Poor Refurbish Power Operators 63 TS U2: 2022 U3: 2025 U1: 2026 U4: 2028 (Each Unit Planned Outage Restart) 5 Sample sizes for inspections are based on similarity of materials of construction, fabrication, procurement, design, installation, operating conditions/environment, system function, location, existing technical information, system and structure design, OPEX and previous failure history 6 The majority (more than 70%) of the Power Operators (POs) will be refurbished prior to 2022 as online work. However, some areas may require an outage so a full unit outage cycle is required to ensure 100% completion of the work. The IIP committed completion date should be viewed as the latest possible completion date. Continuous monitoring of PO failures is done through safety related system tests (functional and stroke tests twice per year), as well as walk downs by the system responsible engineer. It should be noted that there have not been a significant number of PO failures so far that have caused system unavailability.

203 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP-CC PHT and Auxiliaries System, USI# 33100, System #: 0053 CCA System Description Condition Activity Description DSR# Date IIP-CC PHT and Auxiliaries System, USI# 33100, System #: 0053 IIP-CC PHT and Auxiliaries System, USI# 33100, System #: 0053 IIP-CC PHT and Auxiliaries System, USI# 33100, System #: 0053 IIP-CC PHT Pressure and Inventory Control System, USI# 33300, System #: 0054 IIP-CC PHT Pressure and Inventory Control System, USI# 33300, System #: 0054 IIP-CC Radiation Monitors and Samplers System, USI# 67989, System #: 0057 IIP-CC Radiation Monitors and Samplers System, USI# 67989, System #: 0057 IIP-CC Radiation Monitors and Samplers System, USI# 67978, System #: 0057 Main HT Interconnect Motor Operated Valves Main HT Pump Trip Pressure Switches Good Inspect two representative PHT loop isolation / interconnect MOVs to determine condition and provide an inspection and rehab strategy. Satisfactory Replace the cable associated with PHT trip pressure switches and perform any corrective maintenance for switch modules and pressure switches in all units. Main HT Pumps Good Inspect P3 and fix the gasket leaks. Repair gasket leaks on P2. Inspect one Unit 3 pump and repair/replace if required. Main HT Pump Motors & Heaters Dresser Control Valves Bleed Cooler Temperature Control Valves Noble Gas Monitor, Iodine Monitor, Particulate Monitor Tritium Oxide Collectors TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage TS TS Satisfactory Replace all PHT pump motors. TS U2: 2022 U3: 2025 U1: 2026 U4: 2028 Satisfactory Inspect a representative sample of system AOVs to determine condition of valve internals (e.g. CV 3, 4, 11, 13, and 14). Replace or repair based on inspection 5. 1 Satisfactory Inspect a representative sample(s) of 1/2/3/ TCV36/37 and determine the scope of replacement/repair 5. Satisfactory Replace computers and modicons for the stack monitor system. TS U3: 2018 U4: 2019 U1: 2020 U2: 2022 Restart) U2: 2019 U3: 2022 U1: 2024 (Each Unit Refurbishment Outage Restart) (Each Unit Planned Outage Restart) (Each Unit Planned Outage Restart) IP U3: 2018 U4: 2019 U1: 2020 U2: 2022 (Each Unit Planned Outage Restart) TS U012/U034/U0-U4: 2023 Satisfactory Replace Labserco Tritium collectors on all affected TS U012/U034/U0-U4: 2023 stacks. Rate meter Poor Replace Liquid Effluent Monitoring System 7. 2 TS U0: Sample sizes for inspections are based on similarity of materials of construction, fabrication, procurement, design, installation, operating conditions/environment, system function, location, existing technical information, system and structure design, OPEX and previous failure history 7 Poor condition is based on past frequent battery failures along with other maintenance issues including decay of source, electronic component degradation and obsolescence issues. Risk Mitigation Strategy: A bridging strategy to find a suitable replacement for the computer backup battery has been completed. The batteries have been sourced and installed. Maintenance practices to ensure condition of the rate meter does not degrade prior to monitoring system replacement include periodic calibration and prompt repair/replacement if required.

204 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP-CC Reactor Vault and Fuelling Duct Atmosphere Cooling System, USI# 73720, System #: 0060 CCA System Description Condition Activity Description DSR# Date IIP-CC Reactor Vault and Fuelling Duct Atmosphere Cooling System, USI# 73720, System #: 0060 IIP-CC Reactor Vault and Fuelling Duct Atmosphere Cooling System, USI# 73720, System #: 0060 IIP-CC Shutdown Cooling System, USI# 33410, System #: 0067 IIP-CC Shutdown Cooling System, USI# 33410, System #: 0067 IIP-CC Shutdown Cooling System, USI# 33410, System #: 0067 Vault Coolers (RS) Satisfactory Replace coils (like-for-like). TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) Temperature Satisfactory Replace all 16 Temperature Controllers. (4 per unit). TS U1-U4: 2023 Controllers, Vault Coolers (RS) Backpressure Damper, Vault Cooler (RS) Satisfactory Perform an investigation to determine which components are failing and their associated failure modes. TS TS Heat Exchangers Poor Replace heat exchangers 8. 1 TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 Motor Operated Valves Satisfactory -Inspect 5 representative MOVs on U2. Inspect 4 representative valves each in U1, U3 and U4. -Inspect MOV intergate drain lines. -Replace bellows sealed valves, MV28 MV97 in U2. -Disassemble and inspect removed valves to determine path forward for remaining Units. -Provide an inspection and rehab strategy prior to and after inspections are complete in Unit 2. Manual Valves Poor Complete an engineering assessment of manual valves to determine if repacking is required. Repack the SDC manual valves as required 9. 2 TS TS U3: 2018 U4: 2019 U1: 2020 U2: 2022 (Each Unit Planned Outage Restart) U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) 8 Per the current schedule, the HX replacement will start in 2016 and be complete by 2019, based on the assumption that all the work will be executed Online. However, a contingency is in place in case of potential passing isolation of PULSW and PHT isolation valves. Based on the contingency plan, the OPG commitment dates for SDC HX replacement are for U2 2019, U3:2022, U1: 2024, U4: Risk Mitigation Strategy: Response to an SDC HX tube leak is addressed under NK38-OM-09013B , Abnormal Incidents Manual, SDC HX Tube Failure, wherein the leaking HX. is isolated, drained, disassembled, and the leaking and degraded tubes would be plugged or repaired. 9 The valves are scheduled for replacement during the refurbishment outage because that is the only time that the shutdown cooling system can be taken out of service safely. Risk Mitigation Strategy: Because the valves are only required for maintenance they are operated infrequently and as a result the risk of failure is minimized. There are also alternatives available for isolating portions of the SDC system if one of the manual valves fails.

205 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP-CC CCA System Description Condition Activity Description DSR# Date Shutdown System Computer Hardware System, USI# 68240, System #: 0068 IIP-CC Shutdown System Process System, USI# 68200, System #: 0069 IIP-CC Shutdown System Process System, USI# 68200, System #: 0069 IIP-CC Shutdown System Computer Hardware System, USI# 68340, System #: 0070 IIP-CC Shutdown System Process System, USI# 68300, System #: 0071 IIP-CC Shutdown System Process System, USI# 68300, System #: 0071 IIP-CC Standby Generators System, USI# 49100, System #: 0073 IIP-CC Structures - Reactor Building and Fueling Facilities, USI# 21000, System #: 0080 SDS1 GA Computers Satisfactory Design and Replace SDS1 Trip Computer and the Display / Test Computer. Element, Flow Satisfactory Conduct design review to select/modify the flow element prior to refurbishment. S/A Clutch Power Supply Satisfactory Replace SDS1 Flow Elements. Replace Shutoff Rod Clutch Power Supplies on all Units SDS2 GA Computers Satisfactory Design and replace the SDS2 Trip Computer and the Display / Test Computer. Poison Tank Ball Position Level Alarm Satisfactory Replace LISS poison tank ball position level alarm system. Element, Flow Satisfactory Conduct design review to select/modify the flow element prior to refurbishment. Standby Generator Building Reactor Building Structure Satisfactory Satisfactory Replace SDS2 Flow Elements. Perform an inspection for Standby Generator complex. Perform required repairs. Perform required inspections for Reactor Building Structure. TS TS U2: 2022 (Planned Outage Restart) U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) TS U2: 2022 U3: 2025 U1: 2026 U4: 2028 TS TS TS U4: 2019 U1: 2020 U2: 2022 U3: 2025 (Each Unit Planned Outage Restart) U2: 2022 (Planned Outage Restart) U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) (Each Unit Planned Outage Restart) TS U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) TS TS TS U0: 2018 U0: 2022 (U2 Planned Outage Restart) U014: 2018 Perform required repairs. TS U014: 2022 (U2 Planned Outage Restart)

206 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP-CC Structures - Reactor Building and Fueling Facilities, USI# 21000, System #: 0080 CCA System Description Condition Activity Description DSR# Date Reactor Building Internal Structure Satisfactory Perform inspections for the Reactor Building Internal Structures. TS U014: 2018 IIP-CC Structures - Reactor Building and Fueling Facilities, USI# 21000, System #: 0080 IIP-CC Structures - Reactor Building and Fueling Facilities, USI# 21000, System #: 0080 Reactor Auxiliary Bay including structural and architectural elements Good Perform required repairs. Perform inspections for the civil structures located in the Reactor Auxiliary Bay (RAB). Perform required repairs. FFAA - West & East Good Perform required inspections for the civil structures located in Fuelling Facilities Auxiliary Areas (FFAA). TS TS TS TS U014: 2022 (U2 Planned Outage Restart) U014: 2018 U014: 2022 (U2 Planned Outage Restart) U012/U034: 2018 IIP-CC Structures - Reactor Building and Fueling Facilities, USI# 21000, System #: 0080 IIP-CC Structures - Reactor Building and Fueling Facilities, USI# 21000, System #: 0080 Perform required repairs. Irradiated Fuel Area Satisfactory Perform required inspections for irradiated fuel area. Fuel Handling & Service Area Good Perform required repairs. Perform required inspections for fuel handling and service area. TS TS TS TS U012/U034: 2022 (U2 Planned Outage Restart) U014: 2018 U014: 2022 (U2 Planned Outage Restart) U012/U034: 2018 IIP-CC Structures - Powerhouse System, USI# 22000, System #: 0081 IIP-CC Structures - Powerhouse System, USI# 22000, System #: 0081 Turbine Hall & Turbine Auxiliary Bay civil/ structural elements Good Perform required repairs. Perform required inspections for turbine hall and turbine auxiliary bay. Perform required repairs. Central Control Area Good Perform inspection of civil structures located in the central control area. TS TS TS TS U012/U034: 2022 (U2 Planned Outage Restart) U014: 2018 U014: 2022 (U2 Planned Outage Restart) U0: 2018 IIP-CC Circulating Water Systems System, USI# 27100, System #: 0083 Perform required repairs. Pumphouse Good Perform required inspections on Pumphouse Structures. TS TS U0: 2022 (U2 Planned Outage Restart) U0: 2018 IIP-CC Emergency Power System & Emergency Service Water Complex System, USI# 28300, System #: 0084 EPS Buildings Including EPS, EPG, ESW and EPS Fuel Management Good Perform required repairs. Perform required inspections on EPS Buildings, including EPS, EPG, ESW and EPS Fuel Management Structures. Perform required repairs. TS TS TS U0: 2022 (U2 Planned Outage Restart) U0: 2018 U0: 2022 (U2 Planned Outage Restart)

207 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R001 Item Number IIP-CC Fuel Handling Trolley System, USI# 35700, System #: 0206 CCA System Description Condition Activity Description DSR# Date Cable-Power-Harsh- Trolley-I&C Satisfactory Perform a visual inspection and megger testing on cables and connections and send power cable sample for analysis. 1 TS U0: (U2 Refurbishment Outage Restart) Change the power cables as required based on results of inspection. TS U0: 2025 IIP-CC Fuel Handling Trolley System, USI# 35700, System #: 0206 Cable-Signal-Harsh- Trolley-I&C Satisfactory Replace all catenary power cables. Perform a visual inspection and megger testing on the signal cables and connections and send sample for analysis. TS TS U0: 2025 U0: (U2 Refurbishment Outage Restart) Change the signal cables as required based on results of inspection. TS U0: 2025 IIP-CC Fuel Handling Trolley System, USI# 35700, System #: 0206 Catenary Mechanical Satisfactory Replace all catenary signal cables. Perform verification of the chain for length TS TS U0: 2025 U0: (U2 Refurbishment Outage Restart) IIP-CC Fuel Handling Trolley System, USI# 35700, System #: 0206 IIP-CC Fuel Machine Head System, USI# 35210, System #: 0208 IIP-CC Irradiated Fuel Bay System, USI# 34410, System #: 0209 Fuelling Machine Support Frame Catenary Support Mechanical Homing & Locking Good Perform any necessary contingency work. Visually inspect welds for cracks and visually inspect frame and attachment hardware for corrosion. Repair as required. Satisfactory Replace manifolds for fine homing and gap sensing on (Snout) Assembly all fuel machine heads. Heat Exchanger Poor Change gasket and plate material on the heat exchangers. TS TS U0: 2025 U0: (U2 Refurbishment Outage Restart) TS U0: 2025 TS U0/U012/U034: 2025 TS U012/U034: If safety significant defects are found as a result of inspections, they will be corrected by the date specified.

208 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Table 4 provides a summary of the activities to address the Code Gaps resulting from the ISR and CNSC comments. The following is a brief description of the columns in the table: 1. The IIP Item Number column lists a unique identifier. This number remains the same as was produced in R001 of the IIP. Appendix C identifies the mapping between the IIP Item Number in IIP R000 and IIP R The Issue Number and Title column lists the following: a. Issue Number assigned by the ISR Gap Resolution Process N-INS [R-25]. b. Title of the ISR Issue including the PROL (Power Regulator Operating License) and non-prol Code(s) and Standard (s) in which the ISR Issue was discovered. 3. The Issue Description column lists a high level description of the ISR Issue. 4. The Action Plan column includes a description of the required activities to address the ISR Issue. A detailed assessment of adequacy of these activities to address the identified issues at a gap level was performed as part of the Global Assessment. 5. The Tracking # column identifies the DSR tracking number originating from the Darlington Scope Request (DSR) Database in accordance with NK38-INS [R-24] or the OPG internal Action Request (AR) number, or CNSC Action Item (AI) Number. 6. The Date column either identifies the end year or the unit restart date in which the IIP item will be completed. A date for each affected unit is provided, if applicable.

209 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Table 4: Code Gaps (Open Activities) IIP Item Number IIP-OI 001 IIP-OI 002 Issue Number & Title D044 Fire Alarm Systems (CSA N Fire Protection for CANDU Nuclear Power Plants ) D045 Fire Suppression (CSA N Fire Protection for CANDU Nuclear Power Plants ) Issue Description Action Plan Tracking # Date The scope of the Integrated Safety Review (ISR) Issue covers new requirements for fire alarm systems. The outstanding actions are related to transfer of the Fire Alarm system to the Secondary Control Area (SCA), display of all unit alarms in the applicable unit SCA s and some isolation modules were found to be missing from selected stairwells. Also CNSC has challenged the analysis to justify no fire alarm system in the CCW pump houses and Water Treatment plant. The design criteria used for the existing fire suppression and extinguishing systems do not meet some of the modern design standards referenced in CSA-N Design requirements in modern codes are typically grandfathered for existing facilities however they are being re-evaluated as part of the Darlington Refurbishment. Upon completion of analysis it has been determined that there are 2 areas where corrective actions are required for refurbishment. Outdoor transformer protection and the fire loading in Central Services Area (CSA) storage area. 1) Upgrade the station fire alarm system to allow transfer of the fire alarm to the secondary control areas where all applicable alarms will be displayed. 2) Add fault isolation modules where missing from stairwells. 3) The rationale in the analysis will be improved to justify no fire alarm system in the CCW pump houses and Water Treatment plant, or fire alarm systems will be added. Additional Analysis complete and has resulted in the following two corrective actions: 1) Outdoor Transformer Protection To prevent a Main Output Transformer (MOT) fire from damaging the Powerhouse wall or spreading fire into the Unit 0 lunchroom, the existing containment dikes in each unit will be filled with rock to reduce the risk of fire spread. To prevent against a potential Unit Service Transformer or System Service Transformer fire from damaging the Powerhouse wall, the associated containment dikes will be filled with rock to reduce the risk of fire spread. 2) CSA Stores Sprinkler System Commodity Storage To avoid over taxing the existing CSA Stores Sprinkler systems in S-119 and S-219 the plastic storage bins will be removed and replaced with metal wire baskets or steel drawers. IP IP Complete [R-26] Complete [R-27] IP IP U0: 2019 (U2 Refurbishment Outage Restart) U0: 2019 (U2 Refurbishment Outage Restart) 2015 Additional Analysis 2016 U2: 2022 U3: 2025 U1: 2026 U4: 2028 (Each Unit Planned Outage Restart) U2: 2019 (U2 Refurbishment Outage Restart)

210 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 003 Issue Number & Title D046 - Fire Protection Seismic Requirements (CSA N Fire Protection for CANDU Nuclear Power Plants ) Issue Description Action Plan Tracking # Date This ISR Issue addresses the seismic restraint requirements related to fire protection. The risk to the station is low and mitigating actions are not required. The installation of seismic restraints provides an additional level of safety at Darlington during seismic events, however the current configuration is compliant with existing requirements. 1) Complete an additional analysis to determine if seismic restraints are required for fire protection equipment located in the areas specified by this clause. 2) As a result of the additional analysis seismic restraints will be provided for fire extinguishers in the areas specified by this clause. Complete [R-28] IP Modifications: U0: 2019 (U2 Refurbishment Outage Restart) U2: 2022 U3: 2025 U1: 2026 U4: 2028 (Each Unit Planned Outage Restart) IIP-OI 004 IIP-OI 006 D048 Fire Protection Requirements for Storage Tanks (NFCC 2005 National Fire Code of Canada ) D080 Fire Separation (CSA N Fire Protection for CANDU Nuclear Power Plants & NFCC 2005 National Fire Code of Canada ) The scope of this ISR Issue covers requirements for combustible fuel oil tanks, associated piping and secondary containment construction. At Darlington, this applies to the Standby Generator and Emergency Power Supply Generator combustible fuel oil tanks. No documentation or procedural requirements were found for fire separations. Complete an evaluation of the existing SG combustible fuel oil tanks secondary containment dykes to confirm that the dyke's permeability is not deteriorating. Additionally, inspect the Standby Generator and Emergency Power Generator combustible fuel oil tanks secondary containment penetration locations to confirm their integrity is not deteriorating. Correct any deficiencies. Document the existing fire-stops for the following barrier types: Life safety barriers (i.e. exit stairshafts), combustible storage rooms, radioactive storage rooms, Main Control Room Complex, Secondary Control Area rooms, and barriers separating redundant fire safe shutdown systems. In addition, update the applicable station procedures/ standards to ensure documentation of future Fire stops. IP Evaluation: 2016 IP IP Inspection/Repairs: U0: 2019 (U2 Refurbishment Restart) 2016

211 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 008 Issue Number & Title D116 Fire Protection Requirements for Building Materials (CSA N Fire Protection for CANDU Nuclear Power Plants, NFCC 2005 National Fire Code of Canada ) Issue Description Action Plan Tracking # Date No documentation found driving compliance with the new requirements for building materials which establish specific restrictions on combustible contents in building materials, fixtures, impermeable finishes, and epoxy linings. 1) Implement a technical specification for future purchases of carpet, drapes and decorative wall covering materials to ensure that new materials meet the requirements. 2) Revise paint specification to ensure future compliance. Complete [R-29] IP IIP-OI 009 IIP-OI 010 IIP-OI 011 IIP-OI 012 D119 Storage Tank Leak Detection(NFCC 2005 National Fire Code of Canada ) D167 Ventilation Systems Disconnect Switch Testing (NFCC 2005 National Fire Code of Canada ) 17 D170 Fire Safety Plan Requirements (NFCC 2005 National Fire Code of Canada ) D181 Fire Safety Training Requirements (NFCC 2005 National Fire Code of Canada ) No evidence in the design documentation regarding requirements to monitor fuel storage tanks for leakage, to take remedial action to repair leaks, to record all leak testing and to conduct reconciliations of the fuel oil inventory. No documentation found regarding the testing of disconnect switches for mechanical airconditioning and ventilating systems to ensure operation at intervals not greater than 12 months to establish that the system can be shut down in an emergency The DNGS fire safety plan does not include the indoor storage the following indoor storage information: a) product classification, b) storage method including aisle widths for rack storage, c) maximum permitted storage height and area No documentation found outlining requirements for all employees concerned with transfer operations involving transfer of flammable or combustible liquids. Implement predefines and develop procedures to limit the probability that defects in storage tanks, sumps or piping systems or the escape of liquid will go unnoticed. Implement a procedure to ensure the disconnect switches for mechanical air conditioning and ventilating systems are tested at 12 month intervals or implement an alternate compliance. Update the Fire Safety Plan and Pre-Fire Plans to incorporate the missing information related to a) Product classification, b) Storage method including aisle widths for rack storage, c) Maximum permitted storage height and area and signage. Revise the operating procedures and training associated with the transfer of liquid fuel to require that a Fire Watch Qualified staff member is to be present during fuel transfer operations or implement an alternate compliance. IP IP IP IP Code of Record Gap [R-30], the IIP date should be viewed as the latest possible completion date for code of record action. Where it is possible that the resolution of a code of record gap may lead to a modification, the IIP dates include additional time to accommodate this contingency.

212 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 015 IIP-OI 016 IIP-OI 018 Issue Number & Title D225 Fire Protection Water Supply (CSA N Fire Protection for CANDU Nuclear Power Plants & RD- 337 Design of New Nuclear Power Plants ) D227 Fire Hydrant Requirement (CSA N Fire Protection for CANDU Nuclear Power Plants & NFPA Standard for the Installation of Private Service Mains and Their Appurtenances ) D428 Detection of Significant Fire Hazards (CSA N Fire Protection for CANDU Nuclear Power Plants ) Issue Description Action Plan Tracking # Date Non-compliances identified with the requirements related to design requirements for the fire protection water supply, and the interconnection between the Fire Protection water supply and the Emergency Service Water system. Markings on fire hydrants are not addressed in NK38-DM-78100, Fire Protection Water Supply and Distribution System. Perform an assessment of the Fire Protection Water supply loop to evaluate current condition with additional demands and verify that fire protection system demands can still be achieved. In addition, increase the system demands to include an additional 500 USgpm. Complete a modification to provide a new supply of Fire Protection Water separate from the ESW system. Perform flow testing and marking of the hydrants in accordance with NFPA 291 and fit the yard hydrants with a sign to indicate the need for pumping out after usage. Significant Fires need to be quickly detected. 1) Develop a justification for all screen 2 and 3 rooms which do not have automatic detection installed. 2) Install automatic Fire detection in rooms with Major Fire hazard rooms as identified in the FHA table In NK38-REP R001. 3) Install detection in high Fire hazard rooms Rx-109 and Rx-121. IP IP IP IP IP IP Complete [R-31] IP IP Assessment: 2016 Modification: Justification: 2016 Modifications: U0-U4: 2022 (U2 Planned Outage Restart)

213 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 019 IIP-OI 022 IIP-OI 023 IIP-OI 024 Issue Number & Title D429 Fire Separation Corrective Actions(NFCC 2005 National Fire Code of Canada, NBCC 2005 National Building Code of Canada, & CSA N Fire Protection for CANDU Nuclear Power Plants ) D436 Emergency Lighting in airlocks and Transfer Chambers (CSA N Fire Protection for CANDU Nuclear Power Plants ) D442 Fire Endurance of Fire Alarm Cable (CSA N Fire Protection for CANDU Nuclear Power Plants ) 18 D444 Fire Stopping (CSA N Fire Protection for CANDU Nuclear Power Plants ) Issue Description Action Plan Tracking # Date A review of Darlington Nuclear Generating Station against fire separation requirements identified that Door S-213A to the laundry shaft and room R3-241 do not meet the requirements. A Transfer Chamber was found to not be provided with Class II lighting or emergency backup. This issue is related to the endurance of Fire Alarm cables. While the original station cables do not meet the 1 hour requirement additional analysis has shown that the only location where the loss of a Fire Alarm signal is at risk is above the unit instrument air compressors where the unit Fire Alarm system truck cable is located. A material used for fire-stopping (Sikaflex) at the Darlington Nuclear Generating Station does not meet acceptance criteria outlined in Clause of the NBCC for use in a building of noncombustible construction. Replace door S-213A to the laundry shaft in room S- 213 with a listed and labelled fire door having a rating of not less than 45 minutes. Remove the storage from room R3-241, construct a vestibule as a 1 h fire separation so that the storage area does not open directly into the stair or implement an alternate compliance to justify the existing room configuration. Provide emergency lighting in Fuel Handling Transfer Chamber S120. Protect the Fire and Smoke Detection system cabling located above the unit instrument air compressors in R-108. Perform a review of penetration seals larger than a single cable, a single tube, or 13 mm wide construction joint seal, in required fire separations, to confirm that listed fire stopping materials are used. Replace unlisted materials if they have been used. IP IP IP IP IP IP U0: 2019 (U2 Refurbishment Outage Restart) U3: (U3 Planned Outage Restart) U0: 2019 (U2 Refurbishment Outage Restart) IP U2: 2022 U3: 2025 U1: 2026 U4: 2028 (Each Unit Planned Outage Restart) IP Review and replacement: U0: 2019 (U2 Refurbishment Outage Restart) U2: 2022 U3: 2025 U1: 2026 U4: 2028 (Each Unit Planned Outage Restart) 10 Code of Record Gap [R-30], the IIP date should be viewed as the latest possible completion date for code of record action. Where it is possible that the resolution of a code of record gap may lead to a modification, the IIP dates include additional time to accommodate this contingency.

214 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 025 IIP-OI 026 IIP-OI 027 IIP-OI 028 IIP-OI 029 Issue Number & Title D448 Fire Dampers (NBCC 2005 National Building Code of Canada ) D461 Means of Egress (NBCC 2005 National Building Code of Canada ) D467 Vertical Service Shafts (NBCC 2005 National Building Code of Canada ) D469 Inspection Testing and Maintenance Requirements (NFCC 2005 National Fire Code of Canada ) D472 Oil Storage Tank and Piping Requirements(NFCC 2005 National Fire Code of Canada ) Issue Description Action Plan Tracking # Date Some fire separations in the plant require appropriately rated fire dampers to be installed as per Code requirements. The scope of this ISR issue covers egress requirements which were found to not meet the requirements for numbers of exits in S-510 and S-141. This issue addresses concerns with the fire separations for vertical spaces in the Central Services Area. No documentation was found detailing testing requirements for the general oil transfer system piping valves, and there were findings regarding the inspection, testing and maintenance of water-based fire protection systems, in conformance with NFPA 25, Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems. No inspection reports were found for the Emergency Power Generators fuel tank or Turbine Generator lube oil storage tanks that would indicate compliance or operational suitability of the tanks for life extension Install fire dampers in ducts penetrating Service Shafts S-289 and S-290 on the 107.5m and 110.9m elevations of the CSA, in the normally occupied areas. Provide an additional means of egress from room S- 141, preferably at the west end of the room. Also provide a second means of egress from room S-510 or implement an alternate compliance. - Install fire dampers at the duct penetrations of vertical service shafts S-289 and S-290 between the Central Services Area 107.5m and 110.9m elevations in normally occupied areas and seal any penetrations. -Enclose the top of the two laundry shafts in rooms SM-215 and SM-208 by construction that would provide a 1 h fire separation. Resolve Inspection Testing and Maintenance related deficiencies associated with fuel management system valves and safety devices and confirm that the previously identified deficiencies from report NK38-REP "Third Party Review Fixed Fire Protection Systems Inspection Testing and Maintenance Review" are resolved. Complete an assessment of the Emergency Power Generators fuel tanks and Turbine Generator lube oil storage tanks existing conditions to confirm the tanks' suitability for the extended life of the Station. Correct any deficiencies. IP U0: 2019 (U2 Refurbishment Outage Restart) IP Alternate Compliance IP IP Modifications if required U0: 2019 (U2 Refurbishment Outage Restart) U0: 2019 (U2 Refurbishment Outage Restart) IP Assessment: 2016 Repairs: U0: 2019 (U2 Refurbishment Outage Restart) 10 Code of Record Gap [R-30], the IIP date should be viewed as the latest possible completion date for code of record action. Where it is possible that the resolution of a code of record gap may lead to a modification, the IIP dates include additional time to accommodate this contingency.

215 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Issue Number & Number Title IIP-OI 030 D475 Valves Controlling Water Supplies (NFPA Standard for the Installation of Private Service Mains and Their Appurtenances, NFPA Standard for the Installation of Stationary Pumps for Fire Protection ) 20 IIP-OI 031 D476 Underground Pipe (NFPA Standard for the Installation of Private Service Mains and Their Appurtenances ) IIP-OI 033 D482 Monitoring of Fire Pump Alternate Power Source (NFPA Standard for the Installation of Stationary Pumps for Fire Protection ) Issue Description Action Plan Tracking # Date This issue is related to the requirements for valves controlling Fire Protection Water supplies. This issue is related to discrepancies associated the underground piping system for fire protection water supply between the Water Treatment plant and the unit pumphouses. This issue is related to monitoring of the Fire protection Water booster pump power supplies for phase loss. Additionally, no documentation of the acceptance testing procedures was found to verify the pumps were operated for the required minimum of one hour. Complete the following actions related to Valves Controlling Water Supplies: -Test all private fire service main control valves to confirm operability. -Replace the unlisted hose valves downstream of the fire pumps with listed devices that will have an appropriate pressure rating or implement an alternate compliance. -Disconnect the cross connection between ASW and Fire Protection Water on Elevation Conduct an inspection and assess the state of the buried steel pipe between the Water Treatment Plant and the Unit Pumphouses to determine if it is still suitable for life extension purposes. Replace pipes if necessary. Switch the Fire Pump Controller to its alternate position monthly in order to monitor the Fire Protection Water booster pump odd and even power supplies for phase loss on a bi-monthly basis. Also test run the Fire Protection Water booster pumps for a duration of 1 hour to meet a pump acceptance testing requirement. IP IP Tests: 2016 Modifications/Repairs: U0: 2019 (U2 Refurbishment Outage Restart) U2: 2022 U3: 2025 U1: 2026 U4: 2028 (Each Unit Planned Outage Restart) IP Inspection & Assessment: Modifications: Between U1 and U2 CCW pipes: Between U3 and U4 CCW pipes: IP Code of Record Gap [R-30], the IIP date should be viewed as the latest possible completion date for code of record action. Where it is possible that the resolution of a code of record gap may lead to a modification, the IIP dates include additional time to accommodate this contingency.

216 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 034 IIP-OI 035 IIP-OI 036 Issue Number & Title D260 Human Factors - Annunciation Improvements (NUREG 0700 Human-System Interface Design Review Guidelines & IAEA NS-R-1 Safety of Nuclear Power Plants: Design ) D027 - Severe Accident and Beyond Design Basis Accident (BDBA) Analysis/ SAMG (IAEA NS-G-1.2 Safety Assessment and Verification For Nuclear Power Plants ) D068 - Severe Accident and Beyond Design Basis Accident (BDBA) Design/ SAMG (IAEA NS-R-1 Safety of Nuclear Power Plants: Design & CNSC RD-337 Design of New Nuclear Power Plants ) Issue Description Action Plan Tracking # Date An assessment was performed on the humanmachine interface for the Emergency Coolant Injection system and the Annunciation system. Two areas for improvement were identified: 1. Improve annunciation conditioning capability to reduce the number of nuisance alarms in the annunciation system to minimize operator distraction. 2. Improve the control scheme for the annunciation acknowledge function. A systematic analysis of BDBA and Severe Accidents is required and Severe Accident Management Guidelines must be fully implemented. The scope of this ISR issue covers the design requirements of the plant with respect to its capability to safely respond to Beyond Design Basis Accidents (BDBA) and Severe Accidents, and that will reduce any impact to the plant, during and after the accident. Although the clauses specify aspects of the design of a nuclear power plant, all of these Integrated Safety Review (ISR) gaps were declared because a Severe Accident Management Guidelines (SAMG) program has not been fully implemented at Darlington. OPG has already completed the work committed in D260 to reduce nuisance alarms. Nuisance alarms associated with shutdown, start-up, and turbine trip have been reduced by 85% and current levels are acceptable to operations and human factors engineering. This meets the intent of the first area for improvement identified in D260. The second area for improvement in D260 is in the control scheme for acknowledging annunciations in the control room. The current state is acceptable however some improvements will be made to further reduce the potential for error in acknowledging annunciations. -Implement the Safety Improvement Opportunities (SIOs) resulting from the Environmental Assessment. -Complete the Reg Doc Compliance Activities. -Complete the remaining SAMG activities which involve enhancements to the suite of guidelines. -Implement the Safety Improvement Opportunities (SIOs) resulting from the Environmental Assessment. -Complete the remaining SAMG activities which involve enhancements to the suite of guidelines. -Address equipment and instrument survivability under Severe Accident conditions. -Install Passive Autocatalytic Re-combiners (PARS) in all 4 Units at Darlington. IP U1: 2020 U2: 2022 U3: 2025 U4: 2028 (Each Unit Planned Outage Restart) SIO s: Refer to IIP-EA 009 AI 2014-OPG AR ,05,09 SIO s: Refer to IIP-EA 009 AR ,05,09 Complete [R-32] Complete [R-33] SIO s: Refer to IIP-EA 009 Reg Doc 2.4.1: 2024 SAMG: 2015 SIO s: Refer to IIP-EA 009 SAMG: 2015 Instrument Survivability PARS: 2015

217 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 037 IIP-OI 038 Issue Number & Title D143 - Severe Accident and Beyond Design Basis Accident (BDBA) Program/ SAMG (CNSC G-306 Severe Accident Management Programs for Nuclear Reactors ) D300 Inspection Requirements for Safety-Related Structures (CSA N Requirements for safety-related structures for CANDU nuclear power plants & RD- 337 Design of New Nuclear Power Plants ) Issue Description Action Plan Tracking # Date The scope of this Integrated Safety Review (ISR) Issue includes the requirements for Severe Accident Management Guidelines (SAMG) and their implementation at Darlington. There is a need to conduct regular in-service examinations of safety-related structures for evidence of degradation. The structures covered include: -Those that support, house or protect nuclear safety systems,-components of structures required for the safe operation or reactor shutdown, and -Facilities for storage of irradiated fuel and other radioactive waste material. -Implement the Safety Improvement Opportunities (SIOs) resulting from the Environmental Assessment -Complete the remaining SAMG activities which involve enhancements to the suite of guidelines. -Address equipment and instrument survivability under Severe Accident conditions. Prepare and implement inspection programs for the following Safety Related Structures (SRS): - Reactor Building Structures - Reactor Building Internal Structures - Central Services Area Civil Structures - Central Control Area Civil Structures - Turbine Supporting Structures - Pumphouse Structures - Intake Pipes, Ducts & Encasements Structures - Emergency Power Supply and Emergency Service Water Complex - Turbine Hall and Turbine Auxiliary Bay - Central Services Area Buildings consisting of Workshop and Laydown Area and Service Auxiliary Bay - Reactor Auxiliary Bay Civil Structures - Fuelling Facilities Auxiliary Areas Civil Structures - Irradiated Fuel Area - Fuel Handling and Services Area - Forebay Intake System Structures - Emergency Coolant Injection Tanks - Standby Generator Buildings Perform repairs as required. SIO s: Refer to IIP-EA 009 AR ,05,09 Complete [R-32] TS through TS , TS , TS , TS , TS , TS , TS TS TS TS & TS SIO s: Refer to IIP-EA 009 SAMG: 2015 Instrument Survivability: 2015 Inspections & Repairs (U2 Refurbishment Outage Restart) 214 If safety significant defects are found as a result of inspections, they will be corrected by the date specified.

218 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 039 IIP-OI 040 Issue Number & Title D328 - Post Accident Monitoring - Configuration Management (CSA N , Requirements for Monitoring and Display of Nuclear power Plant Safety Functions in the Event of an Accident ) D345 - Consolidated Seismically Qualified Equipment List (CSA-N , "General Requirements for Seismic Design and Qualification of CANDU Nuclear Power Plants" & NK38-REP R001, "Darlington NGS Integrated Safety Review Equipment Qualification Safety Factor Report") Issue Description Action Plan Tracking # Date Less than adequate configuration management of the Post-Accident Monitoring (PAM) system exists. This has resulted in the design and design documents not adequately identifying the appropriate post accident information displays. OPG does not have a single consolidated list that includes all the seismically qualified Systems, Structures and Components for Darlington Nuclear Generating Station. It is the responsibility of the owner/licensee to submit this list for acceptance by the regulatory authority. However, there is no evidence that OPG has created and submitted the list. Revise the Post-Accident Monitoring (PAM) system Design Description [NK38-DD R002], Operational Safety Requirements [NK38-OSR R02] and operating documentation [NK38-OM-09013A R005] to be consistent with the Design Basis Document [NK38-REP R003]. If required, initiate a Design Modification to modify to the appropriate PAM indicators in the MCR and USCA panels as required to comply with NK38- REP Technical Basis Document for Environmental Qualification of Post-Accident Monitoring. Develop a Consolidated Seismically Qualified Equipment List for Darlington Nuclear Generating Station. IP A/R

219 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 041 IIP-OI 042 Issue Number & Title D301 - Potential Impacts from Channel Defueling (NK38-REP , "Review of Licensing Issues for DNGS Integrated Safety Review ) N/A Heat Transport Liquid Relief Valve water hammer Issue Description Action Plan Tracking # Date The closed Station Specific Action Item Darlington NGS - Units 1 and 4, Feeder Vibration During Flow Defueling was assessed as relevant and applicable to Refurbishment. This Action Item (AI) is concerned with the various potential impacts on the reactor of employing "flow defueling". The AI was closed and OPG has subsequently defueled a varying number of channels in other outages. For Refurbishment, the entire reactor will be defueled. As such, this issue may impact Refurbishment and is applicable and relevant to Refurbishment. The Global Assessment performed a review of the licensing issues addressed in the Integrated Safety Review (NK38-REP Appendix H). The path forward on the Heat Transport Liquid Relief Valve (HT LRV) water hammer issue resulted in a design change. - Perform necessary nuclear safety analyses and develop a defueling plan to ensure reactor defueling is performed in a manner that ensures adequate fuel cooling at all times, taking into account relevant operating experience (OPEX). -Perform assessments to determine the defueling conditions under which pressure tube fracture (e.g. due to DHC, hydride overload, fatigue cracking) is not a concern. -Perform thermal hydraulic analysis to demonstrate flow evolution in channels during defueling, placement of Flow Restricting Outlet Bundles, and the number of dummy bundles required. -Perform required nuclear safety assessments to examine impact of defueling on feeder vibration, fuel channel vibration, and fuel bundle vibration. -Perform required nuclear safety analysis to determine neutron flux monitoring requirements and expected detector response as defueling proceeds. Replace the Primary Heat Transport Liquid Relief Valves (LRVs) to limit the risk of water hammer loading. Retain sections of removed piping for a metallurgical assessment following replacement of the Liquid Relief Valves (LRVs) in the first refurbished unit. Complete the metallurgical assessment and report results to CNSC. SI A/R IP AI Replacement: U2: 2019 U3: 2022 U1: 2024 U4: 2025 (Each Unit Refurbishment Outage Restart) Assessment: 2019

220 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 043 Issue Number & Title D028 - Systematic Analysis of Anticipated Operational Occurrences (AOO s) D030 - Identification and Classification of Events per CNSC RD-310 D332 - Reactor Control System Requirements for Anticipated Operation Occurrences (AOOs) D346 - Environmental Qualification of Equipment for Beyond Design Basis Accident (BDBA) Analysis D399 - Acceptance Criteria for Anticipated Operational Occurrences (AOO s) D400 - Deterministic Safety Analysis Uncertainties D424 - Anticipated Operational Occurrences (AOOs) Issue Description Action Plan Tracking # Date Comply with the new requirements of CNSC Reg Doc Complete the Reg Doc compliance activities which includes: 1) Carrying out a comprehensive review of Event Identification and Classification 2) Performing AOO analysis 3) Performing DBA analysis 4) Associated documentation updates 5) Developing analysis rules, coordinating with other COG members, and interactions on technical matters with the CNSC AI 2014-OPG

221 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Issue Number & Number Title IIP-OI 044 D416 - N285.4 Periodic Inspection Program (PIP) Governance References N not N UPD2 D420 - New Erosion and Corrosion Inspection Requirements in N UPD2 not Reflected in Current PIP Governance, D421 - Extended Life Inspection Schedules in N UPD2 are not Reflected in PIP Governance D422 - Assessment of Prior Operating Non-Conforming State is required when Dispositioning Inspection Results D423 - Governance does not Ensure that Qualifications of Examination Personnel are Included Within Inspection Reports (CSA N285.4 Periodic Inspection for CANDU Power Plants ) IIP-OI 046 D426 - Source Term Analysis Not Complete for BDBEs (IAEA-SSG Deterministic Safety Analysis for Nuclear Power Plants ) Issue Description Action Plan Tracking # Date Perform compliance activities to meet CSA N285.4 including appropriate assessments and PIP updates. Assess Emergency Response Projection (ERP). When the Darlington licence is updated to include the 2014 edition of CSA N285.4, update the Darlington Periodic Inspection Plans (PIPs) for Piping and Components, Fuel Channels, Feeders and Steam Generators as necessary to address the requirements of N Assess the Emergency Response Program (ERP) for potential enhancements to address multi-unit BDBE (Beyond Design Basis Events) scenarios. A/R A/R

222 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 049 IIP-OI 050 IIP-OI 051 Issue Number & Title D356 - Compliance with ASME BPVC, Section III NF (CSA N285.0 General Requirements for Pressure-Retaining Systems and Components in Nuclear Power Plants D370 - Qualification of Inspection Procedures and Demonstration of their Effectiveness (CSA N285.4 Periodic Inspection of CANDU Nuclear Power Plant Components") D344 - Self-Vented Pressure Regulating Valves (CSA N290.5, Requirements for Electrical Power and Instrument Air Systems of CANDU Nuclear Power Plants ) Issue Description Action Plan Tracking # Date The jurisdictional boundary between ASME III and the building structure defined for Darlington NGS does not meet the current requirements of ASME Section III. Periodic inspection procedures for volumetric inspections of pressure tubes are to be documented and proven capable of yielding results to a sensitivity that is appropriate for the system or components being inspected. All inspection procedures used in periodic inspections need to be qualified. Inspection procedures applied to pressure tube inspections are to be qualified by the CANDU Inspection Qualification Bureau (CIQB). Self-vented pressure regulating valves are required to be used to supply air to components with design pressures lower than the air system design pressure. Evidence that Darlington NGS is compliant with this requirement is not readily available. When the DNGS licence is updated to include the 2014 edition of CSA N285.4, update the DNGS Periodic Inspection Plans (PIPs) for Piping and Components to address the requirements of N Complete initial Inspection Qualification process for applicable Darlington Major Components per CSA N285.4 (clauses 12, 13, and 14) requirements. Verify that the equipment design pressures for Pressure Regulating Valves (PRV s) that are not selfvented are not less than the design pressure of the air supply system or the equipment is otherwise provided with overpressure protection. A/R A/R A/R

223 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 053 Issue Number & Title D397 - Time Limited Aging Analysis for Civil Structures and Components (NK38-REP R001, "Darlington NGS Integrated Safety Review - Ageing and Actual Condition of Systems Structures and Components Safety Factor Report") IIP-OI 054 D398 - Transient/Fatigue Monitoring Program (NK38-REP R001, "Darlington NGS Integrated Safety Review - Ageing and Actual Condition of Systems Structures and Components Safety Factor Report") IIP-OI 055 D425 No Best Estimate Analysis of Operational Events (IAEA-SSG Deterministic Safety Analysis for Nuclear Power Plants ) Issue Description Action Plan Tracking # Date The acceptance criterion for fitness for service is based on Time Limited Aging Analysis (TLAA) which was generally established from the original safety analysis. The acceptance criterion for TLAA of the Safety Related SSCs for a nuclear station which undergoes refurbishment should be re-evaluated and re-established to demonstrate their continued validity that aging effects will be effectively managed. While there is little evidence of fatigue induced degradation of Systems, Structures and Components (SSCs) during current life, fatigue is a time dependent mechanism and a fatigue monitoring program could be a valuable tool for problem characterization and the implementation of mitigation strategies during post refurbishment operation. There was no evidence found that the best estimate approach is used for analysis of operational events. An assessment of TLAAs for Darlington has been performed and it identified the following actions to be completed. 1. Inspect external concrete components for depth of concrete carbonation and develop corrective actions to mitigate degradation if required. 2. Review the design calculations for the reactor building, vacuum structure and steam turbine and auxiliary structure to determine if concrete creep and shrinkage loads were based on an assumed service life for these structures (e.g. 30 years) and if that assumption remains valid. Perform further analysis if required. 3. The civil structure inspection program at Darlington inspects for concrete degradation due to Alkali Aggregate Reactivity (AAR) and none has been observed at Darlington to date. These inspections will continue through the extended life of Darlington. In addition, the documentation from the construction of Darlington will be reviewed to determine how AAR was addressed in the selection of aggregates to provide further confirmation that AAR degradation will not occur at some point in the future. Develop, and implement a Transient/Fatigue Monitoring Program at Darlington. Revise OPG Governing document N-MAN , Nuclear Safety Analysis to require the use of best estimate approach or a similarly conservative approach for analysis of operational events. IP IP U2: 2019 U3: 2022 U1: 2024 U4: 2025 A/R Inspection: (U2 Refurbishment Outage Restart) Review & Analysis: If safety significant defects are found as a result of inspections, they will be corrected by the date specified.

224 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 056 IIP-OI 058 IIP-OI 059 Issue Number & Title D498 - Airflow from Zone 3 to Zone 2 Does not Meet Design Requirements(NS- G-1.13 Radiation Protection Aspects of Design for Nuclear Power Plants ) D502 - Foundation Steel Piling Condition Assessment for Life Extension (National Building Code of Canada (2005)) D504 Electrical Equipment and Wiring (CSA N Fire Protection for CANDU Nuclear Power Plants ) Issue Description Action Plan Tracking # Date The as-built condition of the Powerhouse Ventilation System does not meet the following requirement: The airflow in the ventilation system should be such that the pressure in a region of lower airborne contamination is higher than the pressure in a region of potentially higher contamination. Thus the airflow in the ventilation system should be directed from regions of lower airborne contamination to regions of higher contamination and air should be extracted from the latter. The airflow should be such as to minimize the re-suspension of contamination. CNSC staff requested OPG to provide comprehensive site-specific assessment that can provide thorough information on the potential for pile corrosion at the Darlington site. Based on the available evidence, there is no immediate risk to the buried steel piles on the Darlington site. In addition, periodic civil structural inspections will identify the early warnings signs should there be any significant pile corrosion. As a result the safety risks associated with this IIP item are very low and no additional mitigating actions are necessary. Changes to the 2009 edition of the CSA C22.1 may impact protection from fire. Repair and return to service Units 1 and 3 supply fans and non-contaminated exhaust fans. Once returned to service in all units, conduct smoke tests to confirm inter-zonal airflow direction at the Zone 2/3 boundaries in all units. Evaluate options available to better characterise the corrosion of buried steel foundation piles, using conservative assumptions, to ensure that they can continue to fulfill their function for extended life. Options may include further analysis, testing, or inspections. 1) Perform a code refresh between the Canadian Electrical Code (CEC) Part Edition [R-34] and the 2009 edition [R-35]. 2) The code refresh concluded that there are no significant code changes that impact protection from fire. One minor modification is required: Replace the water tight conduit seals with explosion proof seals on the Heat Transport Hydrogen Addition system, units 1 to FT6. IP A/R Complete [R-36] IP Code Refresh: 2015 Modifications: U2: 2022 U3: 2025 U1: 2026 U4: 2028 (Each Unit Planned Outage Restart)

225 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 060 Issue Number & Title D517 Electrical Protections and Requirements for Fire Pump Systems (NFPA Standard for the Installation of Stationary Pumps for Fire Protection ) Issue Description Action Plan Tracking # Date This issue is related to the requirements for electrical protection of Fire Pump systems. As per the code requirement, ground fault interruption should not be installed in any fire pump control or power circuit. The existing installation includes a ground fault interruption on the Fire Protection Water booster pump. Also it could not be confirmed based on the documentation if the fire pump motor terminal boxes are a listed means of connection. Modify the Fire Protection Water booster pump electrical installation to eliminate ground fault interruption and ensure the electrical connections at the fire pump motor terminal boxes are a listed means of connection. IP U0-U4: 2023 IIP-OI 061 IIP-OI 062 D521 Fire Safety Plan for Storage of Group A Plastics, Rubbers, Aerosols and Dangerous Goods (NFCC 2010 National Fire Code of Canada ) D522 Tank Storage of Combustible Liquids (NFCC 2010 National Fire Code of Canada ) This issue is low risk, mitigating actions are not required since the pumps are tested monthly, have redundant power supplies and in the unlikely event that the fire booster pump in one unit is unavailable, a fire booster pump in an adjacent unit can be used. The DNGS Fire Safety Plan, NK38-PLAN R006, does not document the location or quantities of storage of Group A plastics, rubber products, Level 2 or 3 aerosols, or dangerous goods. These issues are related to the requirements for Fuel Oil storage tanks and the associated piping. Update the Fire Safety Plan and the Pre-Fire Plans to the NFCC 2010 requirements to ensure that they are aligned and detail the location and quantity of all stored substances as required. -Initiate predefines for continuous and periodic inservice monitoring of the SG and the EPG tanks and implement a Fuel Oil reconciliation process, in accordance with the requirements of the 2010 NFCC. - Revise N-PROC-MA-0088, Buried Piping Program Requirements, to use a graded approach for the replacement of single-walled piping with double walled material in instances of leakage, rather than repair or accept as is. - Prepare an alternate compliance to justify the graded approach for the replacement of single-walled piping with double walled material in instances of leakage. A/R A/R , 04,

226 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 063 Issue Number & Title D523 Piping System Requirements (NFCC 2010 National Fire Code of Canada ) IIP-OI 064 D565- Implementation of Severe Accident Management Guidelines (SAMG) Validation and Refinement (CNSC Regulatory Document REGDOC-2.3.2, Accident Management: Severe Accident Management Programs for Nuclear Reactors ) IIP-OI 066 D607 - Severe Accident and Beyond Design Basis Accident (BDBA) Design Severe Accident Management Guidelines (SAMG) (CSA N290.3 Requirements for the Containment System of Nuclear Power Plants ) IIP-OI 069 D612 - Containment Boundary Report Open Items (CSA N Requirements for the Containment System of Nuclear Power Plants ) Issue Description Action Plan Tracking # Date These issues are related to the requirement to replace single wall fuel oil piping with double wall piping if degraded buried piping is found. The implementation of Severe Accident Management Guidelines (SAMG) at Darlington is ongoing. CSA N290.3 requirements for new build are a Containment Filtered Venting System to protect containment integrity, Shield Tank Overpressure Protection to promote In-Vessel Retention of corium to prevent Core Concrete Interaction, and Severe Accident Management Guides to monitor hydrogen. The following open Design Guide (DG-7) exceptions were found in the Containment Boundary Report: Powerhouse Service Air System V234 listed as Containment Boundary (CB) on the flow sheets. D20 Leakage Collection System containment boundary for L82-D2 is not being met. Revise N-PROC-MA-0088, Buried Piping Program Requirements, to use a graded approach for the replacement of single-walled piping with double walled material in instances of leakage, rather than repair or accept as is. - Prepare an alternate compliance to justify the graded approach for the replacement of single-walled piping with double walled material in instances of leakage. There is already a project in progress to complete SAMG at Darlington. The majority of the work has been completed, guidelines are in place and staff have been trained and exercises are conducted using SAMG. The remaining work involves enhancements to the suite of guidelines and for IFB and multi-units guidelines. -Implement the Safety Improvement Opportunities (SIOs) resulting from the Environmental Assessment. -Complete the remaining SAMG activities which involve enhancements to the suite of guidelines. -Install Post Autocatalytic Re-combiners (PARS) in all 4 Units at Darlington. Retrieve and review NK38-CORR {123889} and NK38-CORR {123891} to determine whether the requirements of Clause and Annex A.2 Figure A.1, respectively of CSA have been met. Determine if a design guide exception is required and if so, prepare the design guide exception. A/R , 04 AR ,05,09 SIO s: Refer to IIP-EA 009 AR ,05,09 Complete [R-33] A/R , SIO s: Refer to IIP IIIP-EA 009 SAMG:

227 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 071 IIP-OI 072 Issue Number & Title D618 - Soil Liquefaction Potential (N289.3 Design Procedures for Seismic Qualification of CANDU Nuclear Power Plants") D619 - Control of Combustible Liquids (CSA N Fire Protection for CANDU Nuclear Power Plants ) Issue Description Action Plan Tracking # Date No evidence was found that the identification and evaluation of the potential for soil liquefaction at Darlington site was completed. Combustible liquids must be controlled where uncontrolled leakage could jeopardize FSSA systems. Review the available information to verify that the liquefaction potential for fill materials in the Protected Area related to safety related systems and structures is low. Otherwise, complete a liquefaction assessment study. Install 25ft squared dykes around all 4 Emergency Service Water (ESW) pumps to contain a potential spill/fire of the 135L of oil contained in each ESW pump motor to the pump motor of origin. A/R IP U0: 2019 (U2 Refurbishment Outage Restart)

228 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Appendix B: Completed Activities Table 5: EA (Completed Activities) IIP Item Number Environmental Component (Reference) 0002 Atmospheric, Geology, Hydrology, Surface Water, Terrestrial CNSC Screening Report page 79, 80, 83, 84, 85, 100, 101, 102, 104, 105, 110 and 111. Mitigation Objective (In design and Additional Mitigation Measures) Demonstrate that implementation of good industry management practices are effective in minimizing air, soil and water quality effects on humans and biota. Action Plan 1) Incorporate applicable Good Industry Management Practices as suggested in the EA and include consideration for enhancing wildlife crossings where feasible, in the Nuclear Projects Environmental Requirements Guideline, N-GUID Issue document for contractors to develop and implement project-specific Environmental Protection Plans. 2) Establish environmental oversight and monitoring requirements for Nuclear Projects. Environmental oversight and monitoring specified in Darlington Refurbishment Environmental Program Management Plan, NK38-NR-PLAN Sh. 004 Section 2.5. Completion Reference [R-37] [R-38] (also in EIS Table 5.15) 3) Incorporate consideration of Good Industry Management Practices in all projects which may have an environmental impact. The Project Charter Template (N-TMP R005), which defines the need for a project, was revised to include the Environmental Impact Worksheet (N-FORM-10422). After the project has been approved a Project Management Plan is developed (PMP-TMP R002) which references N-GUID Nuclear Projects Environmental Requirements Guideline in Section 1.5 [R-39] [R-40] [R-37] 0004 Land Use CNSC Screening Report page 106 (also in EIS Table 5.15) 0007 Physical and Cultural Heritage CNSC Screening Report, page 112 Monitor and consult municipalities on land use policies and future developments proposed in the vicinity of DN site with focus on sensitive land uses (e.g. hospitals, schools) which may result in incompatible uses and effects on implementation of the emergency plans. Protect and avoid the potential impact on the Van Camp cemetery which has archaeological and cultural heritage resource interest. Update emergency management governance to include a statement that Real Estate Services (RES) is the Primary OPG Department responsible for monitoring of land use activities and policies in proximity to DNGS. The wording of the update will include the fact that EP supports this activity when required, including providing information on risk of incompatible uses with respect to implementation of nuclear emergency plans. OPG Guide Excavation, Concrete Drilling, and Anchoring Process, N-GUID , section provides the approximate location of the Van Camp cemetery and actions to be taken to protect the cemetery should it be encountered. The Guide is referenced in OPG Procedure Identification of Buried or Embedded Services, OPG- PROC-0138 and Engineering Design Standard Excavation and Backfill Practices, N-STC [R-41] [R-42] [R-43] [R-44] Paul Nadeau 0008 Malfunctions and Accidents CNSC Screening Report, page 123, 124, 126, 127, 145 and 146 Maintain emergency response procedures to protect the health and safety of people and the environment. OPG has the following emergency response procedures to protect the health and safety of people and the environment. Consolidated Nuclear Emergency Plan, N-PROG-RA-0001 and Abnormal Waterborne Tritium Emission Response, N-PROC-OP [R-45] [R-46] OPG-TMP-0003-R003 (Microsoft 2007)

229 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Table 6: CCAs (R001 Completed Activities) IIP R000 Item Number CCA System Description Condition Activity Description Completion Reference G.31 Powerhouse Ventilation System, USI# 73220, System #: 0050 HVAC Fan(F)-Non R/S Satisfactory Replace remaining non-contaminated fans found with low speed blades. Table 7: CCAs (R002 Completed Activities) [R-47] IIP R001 Item Number IIP-CC Digital Control Computers System, USI# 69000, System #: 0016 CCA System Description Condition Activity Description Completion Reference IIP-CC Emergency Coolant Injection System, USI# 34320, System #: 0018 IIP-CC Moisture Separator Reheater System, USI# 41800, System #: 0043 IIP-CC PHT Pressure and Inventory Control System, USI# 33300, System #: 0054 IIP-CC Shutdown System Process System, USI# 68300, System #: 0071 IIP-CC Structures - Reactor Building and Fueling Facilities, USI# 21000, System #: 0080 IIP-CC Structures - Powerhouse System, USI# 22000, System #: 0081 IIP-CC Structures - Powerhouse System, USI# 22000, System #: 0081 Interprocess Communication & Transfer of Control ECI Water Storage Tank Satisfactory Assess I/O subsystems WIBA terminal blocks. Replace terminal blocks based on assessment. [R-48] Satisfactory Inspect civil structure of ECI Storage tank and repair as required. [R-49] Motorized Valves Satisfactory Perform internal inspection for a representative sample of [R-50] system MOVs. Pressurizer Satisfactory Extend inspection of the pressurizer to all units as required. [R-51] LISS Injection & Mixing Tanks Central Service Area - Nuclear Central Service Area - Conventional Part Steam Turbine Supporting Structures Good Good Good Satisfactory Perform video/visual inspection on TK4 during outage conditions to provide baseline inspections for the LISS tanks. Perform inspections on the civil structures located in Central Service Area-Nuclear. Perform repairs based on inspection results. Perform required inspections for Central Service Area (CSA) buildings consisting of Workshop and Laydown Area (WLA) and Service Auxiliary Bay (SAB). Perform repairs based on inspection results. Perform inspections on the Turbine Supporting Structures. Perform repairs based on inspection results. (Excludes trombik supports) [R-52] [R-53] [R-54] [R-55] OPG-TMP-0003-R003 (Microsoft 2007)

230 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R000 Item Number Table 8: Code Gaps (R001 Completed Activities) Issue Number & Title Issue Description Action Plan Completion Reference 0149 D081 Radioactive Material Storage (CSA N Fire Protection for CANDU Nuclear Power Plants ) D251 Fire Protection Requirements for Air-Cleaning Units (ASME N Nuclear Power Plant Air-Cleaning Units and Components ) 0279 D445 - Combustible Insulation (NBCC 2005 National Building Code of Canada ) D446 - Combustible Material In Ducts (NBCC 2005 National Building Code of Canada ) 0283 D452 Spatial Separation and Exposed Building Face (NBCC 2005 National Building Code of Canada ) D464 Signage Requirements (NBCC 2005 National Building Code of Canada, NFCC 2005 National Fire Code of Canada ) 0292 D468 - Pipe Insulation Requirements (NBCC 2005 National Building Code of Canada ) 0295 D469 - Inspection, Testing and Maintenance Requirements (NFCC 2005 National Fire Code of Canada ) The scope of this issue covers the requirements for the storage of radioactive materials. This Issue covers fire protection requirements for air cleaning systems listed in ASME N There is no evidence in Darlington Nuclear Generating Station documentation as to whether or not the requirements are being met. Documentation could not be found to confirm that if foamed plastic insulation was present in vertical service shafts, or if it was properly protected. Insufficient evidence was found to confirm if combustible coverings and linings on vibration isolation connectors and ducts are interrupted at fire separations. Documentation could not be found to confirm that foamed plastic insulation is not used in exterior walls of the buildings within the scope of the review, and if it is, that the wall assembly meets the requirement for protection on the exterior side. There are no signs posted in the Powerhouse on elevation 100 in exit stair indicating that that level is the level of exit discharge, and the Cafeteria in Unit 0 is an assembly occupancy and the occupant load exceeds 60 persons, but no documentation was found indicating the occupant load sign is posted. Insufficient evidence was found to confirm if pipes reach 120 C, and if they do, if insulation meets the ASTM C 411 "Hot-Surface Performance of High-Temperature Thermal Insulation". Testing of emergency power systems is carried out on the battery banks, but it has not been confirmed whether the Standby Generators are adequately tested to the CAN/CSA- C282 standard. Implement a radioactive material storage evaluation and approval process to ensure that the intended level of safety is not compromised in the event of changes in the location, nature and/or loading of radioactive materials related to the analyzed conditions under the FHA. Analyze charcoal filter hazards to determine appropriate protection measures. Investigate vertical service shafts S-289 and S-290 to determine if foamed plastic insulation exists in the spaces. If so, initiate a modification to either remove or protect it by the appropriate thermal barrier. Confirm the type of duct linings and coverings. If combustible, confirm that the criteria of Sentences (2), (4) and (5) below are satisfied. Initiate a modification to remove any foamed plastic insulation found. Evaluate others for continued use based on their properties. Confirm the type of insulation used in the metal panel exterior walls. If the insulation is foamed plastic, confirm that the panels comply with the testing criteria indicated in clause b). If the panels do not conform to clause b), complete an evaluation of the potential fire impact. Provide appropriate signs at the exit discharge level of exit stairs that do not terminate and discharge to the exterior at El. 100, but continue on to lower elevations. Post appropriate signage as required by Clause of NFCC 2005 in the Cafeteria. Update the existing Preventative Maintenance Identification (PMID) or create a new one for the SG for inspection and testing as per the requirements of CAN/CSA-C282, Emergency Electrical Power Supply for Buildings. [R-56] [R-57] [R-58] [R-59] [R-60] [R-61] [R-62] [R-63] OPG-TMP-0003-R003 (Microsoft 2007)

231 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R000 Item Number Issue Number & Title Issue Description Action Plan Completion Reference D472 - Oil Storage Tank and Piping Requirements (NFCC 2005 National Fire Code of Canada ) D473 Documentation (NFPA Standard for the Installation of Private Service Mains and Their Appurtenances ) D477 - Size of Bypass(NFPA Standard for the Installation of Stationary Pumps for Fire Protection ) 0320 D484 - Magnetic Locks (NBCC 2005 National Building Code of Canada ) D247 - In-service Testing of Air Treatment Systems (ASME N510 - Testing of Nuclear Air Treatment Systems ) 0463 D027 - Severe Accident and Beyond Design Basis Accident (BDBA) Analysis/ Severe Accident Management Guidelines (SAMG) (IAEA NS-G-1.2 Safety Assessment and Verification for Nuclear Power Plants ) This Integrated Safety Review (ISR) issue covers the requirements of oil storage tanks and their associated piping as per the fire protection codes and standards. The requirements such as tank construction and ventilation, piping installation, foundations and supports, shut-off valves, locations and clearances, maximum quantities of stored materials and manual fire protection provided. Hose Houses have been deleted as per PCP However, Drawing NK38-F5H R019 still shows a hose house symbol adjacent to Hy-10. The bypass is 4 which does not meet the requirement of the discharge pipe being a minimum 5" in size. Documentation on the operation of the electromagnetic locking devices could not be found. Routine practices are not followed for tests which would determine; filter housing leakage, filter bypass leakage, degradation of filter media following inadvertent exposure degradation agents (solvents, paints, or other organic fumes or water intrusion). The safety analysis should aim to quantify a plant safety margin and demonstrate that a degree of defence is provided for this class of accidents. Complete an assessment of the EPG and Lube Oil tanks existing tank conditions to confirm the tanks' suitability for the extended life of the Station. Correct any deficiencies. Revise documentation to eliminate the hose house references from NK38-F5H and the design manual NK38-DM as the Hose Houses have been previously removed in the field as approved by PCP Perform a hydraulic analysis to compare the friction losses in the 4 inch diameter bypass to the required 5 inch diameter pipe to demonstrate that the 4 inch pipe is sufficient. Review the operation of the electromagnetic locking devices with all main control room staff to confirm that they are comfortable with their operation and the risks involved should the locks not comply with the requirements of NBCC Clause (4). Adopt CSA N , "Performance Testing of Nuclear Air Cleaning Systems at Nuclear Facilities" which was issued in April Review CSA N as part of the ISR Code Refresh process and resolve any gaps. The SAMG Guides make use of insights from the Level 2 analysis to guide the emergency response on-site to prevent/control the progression of severe accidents and limit releases of radioactive material. It has been issued and the validation is in progress. Several SAM exercise drills have already been performed. Off-site emergency response is managed by the provincial emergency response organization. The Level 2 analysis demonstrates that there is an acceptable risk associated with all severe accident scenarios. No further action is required. [R-64] [R-65] [R-66] [R-67] [R-68] [R-69] OPG-TMP-0003-R003 (Microsoft 2007)

232 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R000 Item Number Issue Number & Title Issue Description Action Plan Completion Reference D337 No Governance Reference for Zone Definitions (Province of Ontario Nuclear Emergency Plan (PNEP)) D338 - No Governance to Maintain 5 MDUs (Province of Ontario Nuclear Emergency Plan (PNEP)) 0490 D339 - Radiological Event Monitoring Support for Non- OPG Events (Province of Ontario Nuclear Emergency Plan (PNEP)) 0491 D115 - Fire Protection Requirements for Laboratories (NFCC 2005 National Fire Code of Canada ) 0495 D460 Fuel Supply Shut Off Valves (NBCC 2005 National Building Code of Canada ) 0496 D482 Monitoring of Fire Pump Alternate Power Source (NFPA Standard for the Installation of Stationary Pumps for Fire Protection ) 0502 D266 - Lack of ALARA & Radiation Protection Training for Plant Design Staff (NK38-REP Darlington NGS-A Integrated Safety Review Plant Design Safety Factor ) There is no suitable governance reference for Zone Definitions, Zone Radii, Zone Response Sectors, Primary Zone Response Sector Pattern, Primary Zone Response Sector Demarcation, Secondary Sub Zones, Actual Zones and Response Sectors, Restricted and Buffer Zones, delineated by Field monitoring, DNGS Contiguous Zone definition, DNGS Primary Zone definition, DNGS Secondary Zone definition and DNGS Primary Zone Response Sectors. There is no governance reference to demonstrate that OPG will continue to retain and maintain the 5 MDUs as required by the PNERP. PNERP requires OPG to provide a radiation monitoring service to the Emergency Management Ontario (EMO) Environmental Radiation Monitoring Group for a non-opg radiological event. Available documentation could not verify compliance with the requirements for ignition sources and combustible material control in a laboratory, including the requirements for high temperature limit switches for heating equipment, and restrictions when an ignition source is used in conjunction with flammable and combustible liquids. An emergency fuel shut off valve for engines or turbines used for an emergency electric power supply must be provided and have a sign. The power to the monitoring loop is drawn from only two of the three phases with no evidence that a signal would be initiated on loss of control power. Also, no documentation has been found indicating the phase loss signal is monitored for each of the feeds The current program provides no specific training course or Computer Based Training (CBT) to ensure staff applies As Low As Reasonably Achievable (ALARA) to radiation protection within the design process. Revise OPG Program, N-PROG-RA-0001 R010, Consolidated Nuclear Emergency Plan and/or N-STD-RA-0004, Emergency Off-Site Radiological Monitoring Process for Airborne Releases of Radioactive Materials to reference Zone Definitions, Zone Radii, Response Sector Boundaries, Desirable Pattern of Response Sectors, Secondary Sub Zones, Actual Zones and Response Sectors, Restricted and Buffer Zones, delineated by Field monitoring, DNGS Contiguous Zone definition, DNGS Primary Zone definition, DNGS Secondary Zone definition and DNGS Primary Zone Response Sectors. Revise N-PROG-RA-0001, Consolidated Nuclear Emergency Plan (CNEP) to comply with the requirements of Ontario Provincial Nuclear Emergency Response Plan (PNERP), 2009 Clause with regard to radiation monitoring and decontamination units (MDUs). Prepare and issue a Letter of Understanding to EMO that will confirm and define OPG s responsibility to provide radiological event monitoring support for a non OPG event. Evaluate the use of the heaters to confirm whether they will be used in unattended applications, and whether overheating of the heater could cause a fire or explosion. If so, equip the heater with an audible alarm or some other type of alarm notification that would alert personnel to the fault. Add the required signs or revise Pre-Fire Plans. Review the existing MCC current tap relay should be reviewed to confirm that it is fail safe. If it is not, install an alternative circuit separate from the MCC circuit. Review and confirm both the primary and alternate power sources. Complete the following activities: - The creation of the CAL - The implementation of the CAL [R-70] [R-71] [R-72] [R-73] [R-74] [R-75] [R-76] OPG-TMP-0003-R003 (Microsoft 2007)

233 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R000 Item Number Issue Number & Title Issue Description Action Plan Completion Reference 0503 D303 - Extension of the Containment Envelope Requirements (CNSC R-7 Requirements for Containment Systems for CANDU Nuclear Power Plants", DG Nuclear Safety Design Guide - Darlington NGS Extensions of the Containment Envelope") 0504 D304 - Change to Extension of the Containment Envelope (CNSC R-7 Requirements for Containment Systems for CANDU Nuclear Power Plants", DG "Nuclear Safety Design Guide - Darlington NGS Extensions of the Containment Envelope" 0505 D321 - Threaded Connections (CSA N285.2 Requirements for Class 1 C, 2C and 3C Pressure-Retaining Components and Supports in CANDU Nuclear Power Plants") 0508 D355 - Library Functions (N , "Quality Assurance of Analytical, Scientific, and Design Computer Programs for Nuclear Power Plants") 0511 D412 - Predicted Failure mode of Anchorage Systems (CSA N287.3 "Design Requirements for Concrete Containment Structures for CANDU Nuclear Power Plants") 0512 D413 - Concrete Cover for Reinforcement (CSA N287.3 "Design Requirements for Concrete Containment Structures for CANDU Nuclear Power Plants") CNSC staff has requested that OPG provide evidence that the calculation and analysis was completed to support the statement as presented in the Design Guide Exception that "For large, fluid filled structures such as the Shield tank extension, the internal design pressure is not indicative of its capacity to withstand the external pressure resulting from Loss of Containment Accident (LOCA) (48 kpa(g). Such a structure can withstand external pressures significantly higher than the limiting internal pressures. The Shield tank assembly has been analyzed for a containment positive pressure test of 111 kpa(g) and the stresses are well within the acceptable limit." CNSC have requested OPG to provide the reference document to support the following statement made in the Design Guide Exception: "The maximum pressure (in Line 12) following an accident would be 98 psia (static 85 psia pressure rinse in the vacuum structure of about 13 psia). This small incremental pressure rise from the normal operating pressure is unlikely to affect the integrity of the piping, as it is still well below the piping design pressure." Threaded connections to Fuelling Machine Class 1 vessel walls do not meet all of the requirements of Clause 9.5 of CSA N The applicable OPG governing document, N-PROC-MP-0095, does not include the requirement that the design description include library functions. There is a lack of documentation requiring anchorage systems to be designed to exhibit ductile behaviour in safety related structures. There is a lack of accounting for the design requirements for actual concrete cover of containment structures in relation to actual environment conditions (humidity, temperature, chemicals, etc.). Either retrieve the required documents from CANDUEnergy or recreate the documents / analysis required to close the gap. Either retrieve the required documentation or recreate the documents / analysis required to close the gap. Perform additional analysis of threaded connections in Fuelling Machine Extension Tube and Drive Housing. Verify that reinforcement of the threaded connections meets the requirements of Paragraph NB-3300 of the ASME Boiler and Pressure Vessel Code, or that the stresses at the threaded connections meet the requirements of ASME Section III Subsection NB. Revise Table 2 Graded Application for Design and Development Tasks of N-PROC-MP-0095 to require that library functions are included in the design description. Incorporate this requirement into N-PROC-MP-0095 at the first opportunity to revise this governing document. Perform calculations and/or finite element limit load analysis for selected anchorage/support configurations using actual material properties for the anchorage system to demonstrate that the predicted failure mode is a ductile failure. Undertake an assessment on actual concrete cover of safetyrelated structures in relation to actual environment conditions (humidity, temperature, chemicals, etc.). [R-77] [R-78] [R-79] [R-80] [R-81] [R-82] OPG-TMP-0003-R003 (Microsoft 2007)

234 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP R000 Item Number Issue Number & Title Issue Description Action Plan Completion Reference 0515 D500 - Adequacy of the N289.3-M81 Code Review Report (CSA-N289.3 Design Procedures for Seismic Qualification of CANDU Nuclear Power Plants ) 0517 N/A Life Extension Activities resulting from CCA Adequacy Review and CCA Recovery Project 0518 N/A- Improve the Aging Management Process documentation There is a lack of a listing of systems and structures that were considered in the N289.3-M81 code review report. Review the results of the Component Condition Assessment (CCA) Adequacy Review and CCA Recovery Project for potential actions required for life extension. The Global Assessment identified a recommendation to improve the Aging Management Process documented in N-PROC-MP to better address consideration for life extension. Clearly identify the systems and structures including SCI/USI in the code refresh review for the 2010 edition CSA N Also describe the methodology that was used to identify the systems and structures that are within the scope. When assessing compliance against the clauses in CSA N , demonstrate compliance for all of the systems and structures within the scope of the review. Update the Integrated Implementation Plan (IIP) with the results of the CCA Adequacy Review and CCA Recovery Project. Modify the Aging Management Program governance to address life extension. [R-83] The following line items have been added to Appendix A of the IIP R001: IIP-CC 008 IIP-CC 009 IIP-CC 016 IIP-CC 017 IIP-CC 023 IIP-CC 038 IIP-CC 040 IIP-CC 043 IIP-CC 051 IIP-CC 075 IIP-CC 076 IIP-CC 077 [R-8] OPG-TMP-0003-R003 (Microsoft 2007)

235 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Table 9: Code Gaps (R002 Completed Activities) IIP Item Number IIP-OI 005 IIP-OI 007 IIP-OI 013 IIP-OI 014 IIP-OI 017 Issue Number & Title Issue Description Action Plan Completion Reference D059 Lightning Protection The scope of this ISR Issue covers the protection of all Complete a review of the current lightning protection at the [R-84] (CSA N Fire Protection for structures and equipment from lightning. This includes Station to determine if it is compliant with NFPA CANDU Nuclear Power Plants ) buildings, above ground tanks, stacks construction cranes, Install upgrades where required to achieve compliance with D115 Fire Protection Requirements for Laboratories (Powerhouse) 23 (NFCC 2005 National Fire Code of Canada ) D182 Thermal Insulating Materials (CSA N Fire Protection for CANDU Nuclear Power Plants ) D184 Fire Protection Program Audit (CSA N Fire Protection for CANDU Nuclear Power Plants ) D297 Fire Protection Air Filter Media Requirements (CSA N Fire Protection for CANDU Nuclear Power Plants ) and meteorological towers. Documentation could not be located to demonstrate compliance with requirements for cleaning, inspection and maintenance of electrical equipment, mechanical systems, piping, valves, automatic and manual control and safety devices, and ventilation systems within laboratories. Existing documentation does not provide requirements for protection, inspection and replacement of thermal insulating materials to prevent them from becoming fire hazards. The following review elements are not covered in the current scope of the Performance Improvement and Nuclear Oversight (PINO) annual fire protection audits: -Fire protection procedure for inclusion of industry OPEX and evolving industry standards; -A sample of plant modifications to ensure compliance with National Building Code of Canada (NBCC) and National Fire Code of Canada (NFCC), as well as to ensure that the impact on the Fire Safe Shutdown Analysis (FSSA) has been evaluated; -At least one emergency response team drill; The system Design Manual does not confirm that the originally installed pre-filter meets the combustibility requirements of Class 1, per CAN/ULC-S111or that the HEPA filters meet the combustibility requirements of ANSI/UL-586. NFPA Implement Inspection Testing and Maintenance requirements for the mechanical, electrical and control systems in the Chemical laboratories. Revise procedures to ensure compliance with the requirements for protection, inspection and replacement of thermal insulating materials to prevent them from becoming fire hazards. Review Nuclear Oversight audit scope for 2012, 2013, 2014 pertaining to CSA N compliance elements documented in gap D184. If gaps related to audit scope per D184 are identified, re-scope future audit plans per N-PROC-RA-0048 to ensure appropriate elements are audited once every 3 years to close D184 gap and to adhere to CSA N requirements. Ensure replacement pre-filters used in the main Powerhouse and supporting out buildings comply with the Class 1 requirements in accordance with CAN/ULC-S111, where available. Also ensure replacement HEPA filters used in the main powerhouse and supporting out buildings comply with the combustibility requirements in accordance with ANSI/UL-586. Implement applicable station procedures regarding the air handling systems and the HEPA filters to drive compliance with this clause. [R-85] 5 [R-86] 5 [R-87] [R-88] 5 Code of Record Gap [R-30] OPG-TMP-0003-R003 (Microsoft 2007)

236 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number Issue Number & Title Issue Description Action Plan Completion Reference IIP-OI 020 D116, D226, D430, D431, D439, D441, D445, D466, D503 Resolution of issues tied to the CCR, FHA and FSSA (CSA N Fire Protection for CANDU Nuclear Power Plants, CSA N Fire Protection for Nuclear Power Plants NBCC 2005 National Building Code of Canada, NK38-REP , Fire Protection Specialists Review of the Fire Protection Issues Identified through the Darlington Integrated Safety Review ) Scope of these ISR issues covers issues tied to analysis of code compliance review requirements for facilities licensed for operation prior to the publication of CAN/CSA N293-07, and analysis of potential fire hazards and the impacts and consequences of such fires on the safety objectives of the Station. Review the agreement on the Code Compliance Review (CCR), FHA and FSSA reached between the station and CNSC and determine if the actions when implemented will close these issues. If not, utilize data extracted from the FHA and FSSA to document an assessment on how the FHA and FSSA goals for the station can be met without additional modifications or develop and implement an action plan to close the gaps. [R-89] IIP-OI 021 IIP-OI 032 IIP-OI 045 IIP-OI 047 IIP-OI 048 D432 Canadian Electrical Code Review for Changes Impacting Fire Protection (CSA N Fire Protection for CANDU Nuclear Power Plants ) D479 Fire Pump Disconnecting Means (NFPA Standard for the Installation of Stationary Pumps for Fire Protection ) D013 - Long Term Control of Hydrogen in Containment (IAEA NS-R-1 Safety of Nuclear Power Plants: Design & CNSC RD- 337 Design of New Nuclear Power Plants ) D141 Fire Protection Requirements for Indoor Fuel Oil Systems (NFCC 2005 National Fire Code of Canada ) D011 - Changes to In-Service Examination and Testing Requirements for Concrete Containment Structures (RD-337, Design of New Nuclear Power Plants ) There is a lack of gap analysis between the 2006 Canadian Electrical Code [R-34] and the edition of the Code at the time of station design and construction. For any major changes implement upgrades. This issue is related to the requirements for fire pump controller disconnection means, signage and seals or locks There is a need for systems to control the fission products, hydrogen, oxygen, and other substances that could be released into containment. No documentation found indicating compliance with the requirement for signs indicating the location of valves used for operation of fire protection equipment and manual emergency shut-off valves to be posted in conspicuous locations. Darlington is not fully compliant with the requirement to provide a list of requirements for design to facilitate inspection of civil structures. Review the changes between the CEC Part 1 code of record and the 2006 Edition to verify there are no major code changes that impact protection from fire. If required, implement any modifications. Add the required seals or locks and the prescribed signage to the Fire Protection booster pumps power supply as described in the NFPA Install Passive Autocatalytic Re-combiners (PARS) in all 4 Units at Darlington which will provide an additional capability to reduce hydrogen concentration. Install signs in conspicuous locations indicating the location of valves used for the operation of fire protection equipment and manual emergency shut-off of fuel oil. Create a high level document for leakage rate testing and update the Periodic Inspection Programs for Concrete Containment Structures. [R-90] [R-91] 524 [R-33] [R-92] [R-93] 5 Code of Record Gap [R-30] OPG-TMP-0003-R003 (Microsoft 2007)

237 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 052 IIP-OI 057 IIP-OI 065 IIP-OI 067 IIP-OI 068 IIP-OI 070 Issue Number & Title Issue Description Action Plan Completion Reference D352- Time History Compatibility Documented evidence in the form of a calculation to show Verify that the time histories used in seismic analyses of safetyrelated [R-94] with the Design Ground Response that the generated time history correctly represents the System, Structure and Components (SSCs) comply with Spectrum (N289.3 Design design ground response spectrum within the prescribed the original and recent versions of N Procedures for Seismic requirements have not been provided. Qualification of CANDU Nuclear Power Plants") D617 - Seismic Time History Requirements (CSA N289.3 "Design Procedures for Seismic Qualification of Nuclear Power Plants") D501 - Aging and Actual Conditions of SSCs SFR - CNSC Type II Inspection of CCAs (NK38-REP R01, "Ageing and Actual Condition of Systems, Structures and Components (SSC) Safety Factor Report ) D606 - Darlington's Non-compliance with Hygrometer Probe Requirements(CSA N287.7 Inservice Examination and Testing Requirements for Concrete Containment Structures for CANDU Nuclear Power Plants D610 - Long Term Control of Hydrogen In Containment (CSA N290.3 Requirements for the Containment System of Nuclear Power Plants ) D611 - Coatings and Coverings Within Containment System (CSA N290.3 Requirements for the Containment System of Nuclear Power Plants ) D616 - Equipment Qualification for Beyond Design Basis Accidents (BDBAs) (CSA N290.0, General Requirements for Safety Systems of Nuclear Power Plants ) There are quality issues with the Component Condition Assessments (CCAs) as identified in self-assessment D and the preliminary findings of the CNSC Staff Type II Plant Condition Assessment Compliance Inspection. Darlington is not compliant with the dewpoint requirements initially stated in the 2008 version of the standard. There is a lack of Post Autocatalytic Re-combiners (PARs) for long term hydrogen control. There is no evidence to confirm that post-accident conditions inside containment were considered when choosing the coating for civil structures and steel lined reactor structures. The interaction of some coatings in containment with the post-accident environment has the potential to produce hydrogen. There is a lack of completed qualification assessments for instrumentation and equipment required following a Beyond Design Basis Accident (BDBA). Address all of the findings from the CNSC Type II Inspection report. Outstanding activities include: - N-PROC-MP-0060 Roll Out - N-PROC-MA-0077 Update - Effectiveness Review Evaluate options and if required procure higher accuracy probes that will meet the dewpoint requirements or request a concession letter to the CNSC to use existing hygrometers. Install Passive Autocatalytic Re-combiners (PARS) in all 4 Units at Darlington which will provide an additional capability to reduce hydrogen concentration. Install Passive Autocatalytic Re-combiners (PARS) in all 4 Units at Darlington which will provide an additional capability to reduce hydrogen concentration. Complete the instrumentation and equipment qualification assessments for Beyond Design Basis Accidents (BDBAs) (related to external initiating events) as part of the Fukushima follow-up work. [R-95] [R-96] [R-33] [R-33] [R-32] OPG-TMP-0003-R003 (Microsoft 2007)

238 Report Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Document Number: Usage Classification: NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 IIP Item Number IIP-OI 073 Issue Number & Title Issue Description Action Plan Completion Reference D620 - Section 5 of the CSA The code refresh report for CSA N did not include Perform a review of Section 5 of CSA N If any gaps [R-97] N Code Refresh a review of Section 5 of the code. Section 5 is titled New are identified as a result of the review they will be resolved in (CSA N Seismic nuclear power plants and on-site nuclear facilities and accordance with N-INS , Nuclear Refurbishment instrumentation requirements for although it would not normally be applicable to an existing Gap Resolution Process Darlington. nuclear power plants and nuclear station, it is a requirement for the review of modern codes facilities") and standards for the Darlington Integrated Safety Review. OPG-TMP-0003-R003 (Microsoft 2007)

239 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Appendix C: IIP Mapping IIP R000 Item Number IIP R001 Item Number EA IIP Items Status 0001 IIP-EA 001 Open Appendix A 0002 IIP-EA 002 Complete Appendix B 0003 IIP-EA 003 Open Appendix A 0004 IIP-EA 004 Complete Appendix B 0005 IIP-EA 005 Open Appendix A 0006 IIP-EA 006 Open Appendix A 0007 IIP-EA 007 Complete Appendix B 0008 IIP-EA 008 Complete Appendix B 0009 IIP-EA 009 Open Appendix A 0010 IIP-EA 010 Open Appendix A 0011 IIP-EA 011 Open Appendix A 0012 IIP-EA 012 Open Appendix A 0013 IIP-EA 013 Open Appendix A 0014 IIP-EA 014 Open Appendix A 0015 IIP-EA 015 Open Appendix A IIP Appendix or Reference OPG-TMP-0003-R003 (Microsoft 2007)

240 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number CCA IIP Items Status IIP Appendix or Reference 0016 IIP-CC 001 Open Appendix A 0017 IIP-CC 002 Open Appendix A 0018 IIP-CC 003 Open Appendix A 0019 IIP-CC 004 Open Appendix A 0020 IIP-CC 005 Open Appendix A 0021 IIP-CC 006 Open Appendix A 0022 IIP-CC 007 Open Appendix A 0023 N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR IIP-CC 010 Open Appendix A 0029 IIP-CC 011 Open Appendix A 0030 IIP-CC 012 Complete Appendix B 0031 IIP-CC 013 Complete Appendix B 0032 IIP-CC 014 Open Appendix A 0033 N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR IIP-CC 015 Open Appendix A 0036 N/A Asset Preservation NK38-CORR IIP-CC 018 Open Appendix A 0038 N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR IIP-CC 019 Open Appendix A 0043 IIP-CC 020 Open Appendix A 0044 N/A Asset Preservation NK38-CORR IIP-CC 021 Open Appendix A 0046 IIP-CC 022 Open Appendix A 0047 N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR IIP-CC 024 Open Appendix A 0051 N/A Asset Preservation NK38-CORR IIP-CC 025 Open Appendix A 0053 IIP-CC 026 Open Appendix A 0054 IIP-CC 027 Open Appendix A 0055 N/A Asset Preservation NK38-CORR IIP-CC 028 Open Appendix A 0057 IIP-CC 029 Open Appendix A OPG-TMP-0003-R003 (Microsoft 2007)

241 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status IIP Appendix or Reference 0058 IIP-CC 030 Complete Appendix B 0059 IIP-CC 031 Open Appendix A 0060 IIP-CC 032 Open Appendix A 0061 IIP-CC 033 Open Appendix A 0062 IIP-CC 034 Open Appendix A Complete Appendix B 0064 IIP-CC 035 Open Appendix A 0065 IIP-CC 036 Open Appendix A 0066 IIP-CC 037 Open Appendix A 0067 IIP-CC 038 Complete Appendix B 0068 IIP-CC 041 Open Appendix A 0069 N/A Asset Preservation NK38-CORR IIP-CC 0423 Open Appendix A 0071 IIP-CC 044 Open Appendix A 0072 IIP-CC 045 Open Appendix A 0073 N/A Asset Preservation NK38-CORR IIP-CC 046 Open Appendix A 0075 IIP-CC 047 Open Appendix A 0076 IIP-CC 048 Open Appendix A 0077 N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR IIP-CC 049 Open Appendix A 0081 IIP-CC 050 Open Appendix A 0082 N/A Asset Preservation NK38-CORR IIP-CC 052 Open Appendix A 0084 IIP-CC 052 Open Appendix A 0085 IIP-CC 052 Open Appendix A 0086 IIP-CC 052 Open Appendix A 0087 IIP-CC 052 Open Appendix A 0088 IIP-CC 053 Open Appendix A 0089 N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR IIP-CC 054 Open Appendix A 0092 IIP-CC 055 Open Appendix A 0093 IIP-CC 055 Open Appendix A 0094 IIP-CC 055 Open Appendix A 0095 IIP-CC 055 Open Appendix A 0096 IIP-CC 055 Open Appendix A 0097 IIP-CC 055 Open Appendix A 0098 N/A Asset Preservation NK38-CORR IIP-CC 056 Open Appendix A 0100 IIP-CC 057 Open Appendix A 0101 N/A Asset Preservation NK38-CORR OPG-TMP-0003-R003 (Microsoft 2007)

242 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status IIP Appendix or Reference 0102 IIP-CC 058 Complete Appendix B 0103 N/A Asset Preservation NK38-CORR IIP-CC 059 Open Appendix A 0105 N/A Asset Preservation NK38-CORR IIP-CC 060 Open Appendix A 0107 IIP-CC 061 Open Appendix A 0108 IIP-CC 062 Open Appendix A 0109 IIP-CC 063 Open Appendix A 0110 IIP-CC 064 Open Appendix A 0111 IIP-CC 065 Open Appendix A 0112 IIP-CC 066 Complete Appendix B 0113 IIP-CC 067 Open Appendix A 0114 IIP-CC 068 Complete Appendix B 0115 IIP-CC 069 Open Appendix A 0116 IIP-CC 070 Complete Appendix B 0117 IIP-CC 071 Open Appendix A 0118 IIP-CC 072 Open Appendix A 0119 IIP-CC 073 Open Appendix A 0120 IIP-CC 074 Open Appendix A 0121 N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR IIP-CC 078 Open Appendix A New Item IIP-CC 008 Open Appendix A New Item IIP-CC 009 Open Appendix A New Item IIP-CC 016 Open Appendix A New Item IIP-CC 017 Open Appendix A New Item IIP-CC 023 Open Appendix A New Item IIP-CC 039 Open Appendix A New Item IIP-CC 040 Open Appendix A New Item IIP-CC 042 Open Appendix A New Item IIP-CC 051 Open Appendix A New Item IIP-CC 075 Open Appendix A New Item IIP-CC 076 Open Appendix A New Item IIP-CC 077 Open Appendix A OPG-TMP-0003-R003 (Microsoft 2007)

243 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Code Gaps IIP Items Status IIP Appendix or Reference 0127 IIP-OI 001 Open Appendix A 0128 IIP-OI 001 Open Appendix A 0129 IIP-OI 001 Open Appendix A 0130 IIP-OI 001 Open Appendix A 0131 IIP-OI 001 Open Appendix A 0132 IIP-OI 002 Open Appendix A 0133 IIP-OI 002 Open Appendix A 0134 IIP-OI 002 Open Appendix A 0135 IIP-OI 002 Open Appendix A 0136 IIP-OI 002 Open Appendix A 0137 IIP-OI 002 Open Appendix A 0138 IIP-OI 002 Open Appendix A 0139 IIP-OI 002 Open Appendix A 0140 IIP-OI 002 Open Appendix A 0141 IIP-OI 003 Open Appendix A 0142 IIP-OI 003 Open Appendix A 0143 N/A Asset Preservation NK38-CORR IIP-OI 004 Open Appendix A 0145 IIP-OI 005 Complete Appendix B 0146 IIP-OI 005 Complete Appendix B 0147 IIP-OI 006 Open Appendix A 0148 IIP-OI 006 Open Appendix A 0149 N/A Complete Appendix B 0150 IIP-OI 007 Complete Appendix B 0151 IIP-OI 007 Complete Appendix B 0152 IIP-OI 007 Complete Appendix B 0153 IIP-OI 008 Open Appendix A 0154 IIP-OI 008 Open Appendix A 0155 IIP-OI 009 Open Appendix A 0156 IIP-OI 009 Open Appendix A 0157 IIP-OI 009 Open Appendix A 0158 IIP-OI 010 Open Appendix A 0159 IIP-OI 011 Open Appendix A 0160 IIP-OI 012 Open Appendix A 0161 IIP-OI 013 Complete Appendix B 0162 IIP-OI 013 Complete Appendix B 0163 IIP-OI 013 Complete Appendix B 0164 IIP-OI 014 Complete Appendix B 0165 N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR OPG-TMP-0003-R003 (Microsoft 2007)

244 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status IIP Appendix or Reference 0169 IIP-OI 015 Open Appendix A 0170 IIP-OI 015 Open Appendix A 0171 IIP-OI 015 Open Appendix A 0172 IIP-OI 015 Open Appendix A 0173 N/A Asset Preservation NK38-CORR N/A Asset Preservation NK38-CORR IIP-OI 016 Open Appendix A 0176 IIP-OI 016 Open Appendix A 0177 N/A Asset Preservation NK38-CORR Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B 0184 IIP-OI 017 Complete Appendix B 0185 IIP-OI 017 Complete Appendix B 0186 IIP-OI 018 Open Appendix A 0187 IIP-OI 018 Open Appendix A 0188 IIP-OI 019 Open Appendix A 0189 IIP-OI 019 Open Appendix A 0190 IIP-OI 019 Open Appendix A 0191 IIP-OI 019 Open Appendix A 0192 IIP-OI 019 Open Appendix A 0193 IIP-OI 019 Open Appendix A 0194 IIP-OI 020 Complete Appendix B 0195 IIP-OI 020 Complete Appendix B 0196 IIP-OI 020 Complete Appendix B 0197 IIP-OI 020 Complete Appendix B 0198 IIP-OI 020 Complete Appendix B 0199 IIP-OI 020 Complete Appendix B 0200 IIP-OI 020 Complete Appendix B 0201 IIP-OI 020 Complete Appendix B 0202 IIP-OI 020 Complete Appendix B 0203 IIP-OI 020 Complete Appendix B 0204 IIP-OI 020 Complete Appendix B 0205 IIP-OI 020 Complete Appendix B 0206 IIP-OI 020 Complete Appendix B 0207 IIP-OI 020 Complete Appendix B 0208 IIP-OI 020 Complete Appendix B 0209 IIP-OI 020 Complete Appendix B 0210 IIP-OI 020 Complete Appendix B 0211 IIP-OI 020 Complete Appendix B 0212 IIP-OI 020 Complete Appendix B OPG-TMP-0003-R003 (Microsoft 2007)

245 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status 0213 IIP-OI 020 Complete Appendix B 0214 IIP-OI 020 Complete Appendix B 0215 IIP-OI 020 Complete Appendix B 0216 IIP-OI 020 Complete Appendix B 0217 IIP-OI 020 Complete Appendix B 0218 IIP-OI 020 Complete Appendix B 0219 IIP-OI 020 Complete Appendix B 0220 IIP-OI 020 Complete Appendix B 0221 IIP-OI 020 Complete Appendix B 0222 IIP-OI 020 Complete Appendix B 0223 IIP-OI 020 Complete Appendix B 0224 IIP-OI 020 Complete Appendix B 0225 IIP-OI 020 Complete Appendix B 0226 IIP-OI 020 Complete Appendix B 0227 IIP-OI 020 Complete Appendix B 0228 IIP-OI 020 Complete Appendix B 0229 IIP-OI 020 Complete Appendix B 0230 IIP-OI 020 Complete Appendix B 0231 IIP-OI 020 Complete Appendix B 0232 IIP-OI 020 Complete Appendix B 0233 IIP-OI 020 Complete Appendix B 0234 IIP-OI 020 Complete Appendix B 0235 IIP-OI 020 Complete Appendix B 0236 IIP-OI 020 Complete Appendix B 0237 IIP-OI 020 Complete Appendix B 0238 IIP-OI 020 Complete Appendix B 0239 IIP-OI 020 Complete Appendix B 0240 IIP-OI 020 Complete Appendix B 0241 IIP-OI 020 Complete Appendix B 0242 IIP-OI 020 Complete Appendix B 0243 IIP-OI 020 Complete Appendix B 0244 IIP-OI 020 Complete Appendix B 0245 IIP-OI 020 Complete Appendix B 0246 IIP-OI 020 Complete Appendix B 0247 IIP-OI 020 Complete Appendix B 0248 IIP-OI 020 Complete Appendix B 0249 IIP-OI 020 Complete Appendix B 0250 IIP-OI 020 Complete Appendix B 0251 IIP-OI 020 Complete Appendix B 0252 IIP-OI 020 Complete Appendix B 0253 IIP-OI 020 Complete Appendix B 0254 IIP-OI 020 Complete Appendix B 0255 IIP-OI 020 Complete Appendix B 0256 IIP-OI 020 Complete Appendix B IIP Appendix or Reference OPG-TMP-0003-R003 (Microsoft 2007)

246 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status IIP Appendix or Reference 0257 IIP-OI 020 Complete Appendix B 0258 IIP-OI 020 Complete Appendix B 0259 IIP-OI 020 Complete Appendix B 0260 IIP-OI 020 Complete Appendix B 0261 IIP-OI 020 Complete Appendix B 0262 IIP-OI 020 Complete Appendix B 0263 IIP-OI 020 Complete Appendix B 0264 IIP-OI 020 Complete Appendix B 0265 IIP-OI 020 Complete Appendix B 0266 IIP-OI 021 Complete Appendix B 0267 IIP-OI 021 Complete Appendix B 0268 IIP-OI 022 Open Appendix A 0269 IIP-OI 020 Complete Appendix B 0270 IIP-OI 020 Complete Appendix B 0271 IIP-OI 020 Complete Appendix B 0272 IIP-OI 020 Complete Appendix B 0273 IIP-OI 020 Complete Appendix B 0274 IIP-OI 023 Open Appendix A 0275 IIP-OI 023 Open Appendix A 0276 IIP-OI 023 Open Appendix A 0277 IIP-OI 024 Open Appendix A 0278 IIP-OI 020 Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B 0282 IIP-OI 025 Open Appendix A Complete Appendix B 0284 N/A Asset Preservation NK38-CORR IIP-OI 026 Open Appendix A 0286 IIP-OI 026 Open Appendix A Complete Appendix B Complete Appendix B 0289 IIP-OI 020 Open Appendix A 0290 IIP-OI 020 Open Appendix A 0291 IIP-OI 027 Open Appendix A Complete Appendix B 0293 IIP-OI 028 Open Appendix A 0294 IIP-OI 028 Open Appendix A Complete Appendix B 0296 IIP-OI 029 Open Appendix A Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B OPG-TMP-0003-R003 (Microsoft 2007)

247 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status Complete Appendix B 0302 IIP-OI 030 Open Appendix A 0303 IIP-OI 030 Open Appendix A 0304 IIP-OI 030 Open Appendix A 0305 IIP-OI 030 Open Appendix A 0306 IIP-OI 031 Open Appendix A 0307 IIP-OI 031 Open Appendix A 0308 IIP-OI 031 Open Appendix A 0309 IIP-OI 031 Open Appendix A 0310 IIP-OI 031 Open Appendix A Complete Appendix B Complete Appendix B 0313 IIP-OI 032 Complete Appendix B 0314 IIP-OI 032 Complete Appendix B 0315 IIP-OI 033 Open Appendix A 0316 IIP-OI 033 Open Appendix A 0317 IIP-OI 033 Open Appendix A 0318 IIP-OI 033 Open Appendix A 0319 IIP-OI 033 Open Appendix A Complete Appendix B 0321 IIP-OI 034 Open Appendix A 0322 IIP-OI 034 Open Appendix A 0323 IIP-OI 034 Open Appendix A 0324 IIP-OI 034 Open Appendix A 0325 IIP-OI 034 Open Appendix A 0326 IIP-OI 034 Open Appendix A 0327 IIP-OI 034 Open Appendix A 0328 IIP-OI 034 Open Appendix A 0329 IIP-OI 034 Open Appendix A 0330 IIP-OI 034 Open Appendix A 0331 IIP-OI 034 Open Appendix A 0332 IIP-OI 034 Open Appendix A 0333 IIP-OI 034 Open Appendix A 0334 IIP-OI 035 Open Appendix A 0335 IIP-OI 035 Open Appendix A 0336 IIP-OI 035 Open Appendix A 0337 IIP-OI 036 Open Appendix A 0338 IIP-OI 036 Open Appendix A 0339 IIP-OI 036 Open Appendix A 0340 IIP-OI 036 Open Appendix A 0341 IIP-OI 036 Open Appendix A 0342 IIP-OI 036 Open Appendix A 0343 IIP-OI 036 Open Appendix A 0344 IIP-OI 036 Open Appendix A IIP Appendix or Reference OPG-TMP-0003-R003 (Microsoft 2007)

248 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status 0345 IIP-OI 036 Open Appendix A 0346 IIP-OI 036 Open Appendix A 0347 IIP-OI 036 Open Appendix A 0348 IIP-OI 036 Open Appendix A 0349 IIP-OI 036 Open Appendix A 0350 IIP-OI 037 Open Appendix A 0351 IIP-OI 037 Open Appendix A Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B 0362 IIP-OI 038 Open Appendix A 0363 IIP-OI 038 Open Appendix A 0364 IIP-OI 038 Open Appendix A 0365 IIP-OI 038 Open Appendix A 0366 IIP-OI 038 Open Appendix A 0367 IIP-OI 038 Open Appendix A 0368 IIP-OI 039 Open Appendix A 0369 IIP-OI 039 Open Appendix A 0370 IIP-OI 039 Open Appendix A 0371 IIP-OI 040 Open Appendix A 0372 IIP-OI 040 Open Appendix A 0373 IIP-OI 041 Open Appendix A 0374 IIP-OI 041 Open Appendix A 0375 IIP-OI 042 Open Appendix A 0376 IIP-OI 035 Open Appendix A 0377 IIP-OI 035 Open Appendix A 0378 IIP-OI 043 Open Appendix A 0379 IIP-OI 043 Open Appendix A 0380 IIP-OI 043 Open Appendix A 0381 IIP-OI 043 Open Appendix A 0382 IIP-OI 043 Open Appendix A 0383 IIP-OI 043 Open Appendix A 0384 IIP-OI 043 Open Appendix A 0385 IIP-OI 043 Open Appendix A 0386 IIP-OI 043 Open Appendix A 0387 IIP-OI 043 Open Appendix A 0388 IIP-OI 043 Open Appendix A IIP Appendix or Reference OPG-TMP-0003-R003 (Microsoft 2007)

249 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status 0389 IIP-OI 043 Open Appendix A 0390 IIP-OI 043 Open Appendix A 0391 IIP-OI 043 Open Appendix A 0392 IIP-OI 043 Open Appendix A 0393 IIP-OI 043 Open Appendix A 0394 IIP-OI 043 Open Appendix A 0395 IIP-OI 043 Open Appendix A 0396 IIP-OI 043 Open Appendix A 0397 IIP-OI 043 Open Appendix A 0398 IIP-OI 043 Open Appendix A 0399 IIP-OI 043 Open Appendix A 0400 IIP-OI 043 Open Appendix A 0401 IIP-OI 043 Open Appendix A 0402 IIP-OI 043 Open Appendix A 0403 IIP-OI 043 Open Appendix A 0404 IIP-OI 043 Open Appendix A 0405 IIP-OI 043 Open Appendix A 0406 IIP-OI 043 Open Appendix A 0407 IIP-OI 043 Open Appendix A 0408 IIP-OI 043 Open Appendix A 0409 IIP-OI 043 Open Appendix A 0410 IIP-OI 043 Open Appendix A 0411 IIP-OI 043 Open Appendix A 0412 IIP-OI 043 Open Appendix A 0413 IIP-OI 043 Open Appendix A 0414 IIP-OI 043 Open Appendix A 0415 IIP-OI 043 Open Appendix A 0416 IIP-OI 043 Open Appendix A 0417 IIP-OI 043 Open Appendix A 0418 IIP-OI 043 Open Appendix A 0419 IIP-OI 043 Open Appendix A 0420 IIP-OI 043 Open Appendix A 0421 IIP-OI 044 Open Appendix A 0422 IIP-OI 044 Open Appendix A 0423 IIP-OI 044 Open Appendix A 0424 IIP-OI 044 Open Appendix A 0425 IIP-OI 044 Open Appendix A 0426 IIP-OI 044 Open Appendix A 0427 IIP-OI 044 Open Appendix A 0428 IIP-OI 044 Open Appendix A 0429 IIP-OI 044 Open Appendix A 0430 IIP-OI 044 Open Appendix A 0431 IIP-OI 044 Open Appendix A 0432 IIP-OI 044 Open Appendix A IIP Appendix or Reference OPG-TMP-0003-R003 (Microsoft 2007)

250 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status 0433 IIP-OI 044 Open Appendix A 0434 IIP-OI 044 Open Appendix A 0435 IIP-OI 044 Open Appendix A 0436 IIP-OI 044 Open Appendix A 0437 IIP-OI 044 Open Appendix A 0438 IIP-OI 044 Open Appendix A 0439 IIP-OI 044 Open Appendix A 0440 IIP-OI 044 Open Appendix A 0441 IIP-OI 044 Open Appendix A 0442 IIP-OI 044 Open Appendix A 0443 IIP-OI 044 Open Appendix A 0444 IIP-OI 044 Open Appendix A 0445 IIP-OI 044 Open Appendix A 0446 IIP-OI 044 Open Appendix A 0447 IIP-OI 044 Open Appendix A 0448 IIP-OI 044 Open Appendix A 0449 IIP-OI 044 Open Appendix A 0450 IIP-OI 044 Open Appendix A 0451 IIP-OI 044 Open Appendix A 0452 IIP-OI 044 Open Appendix A 0453 IIP-OI 044 Open Appendix A 0454 IIP-OI 044 Open Appendix A 0455 IIP-OI 044 Open Appendix A 0456 IIP-OI 044 Open Appendix A 0457 IIP-OI 044 Open Appendix A 0458 IIP-OI 044 Open Appendix A 0459 IIP-OI 045 Complete Appendix B 0460 IIP-OI 045 Complete Appendix B 0461 IIP-OI 045 Complete Appendix B 0462 IIP-OI 045 Complete Appendix B Complete Appendix B 0464 IIP-OI 036 Open Appendix A 0465 IIP-OI 036 Open Appendix A 0466 IIP-OI 036 Open Appendix A 0467 IIP-OI 036 Open Appendix A 0468 IIP-OI 036 Open Appendix A 0469 IIP-OI 036 Open Appendix A 0470 IIP-OI 036 Open Appendix A 0471 IIP-OI 036 Open Appendix A 0472 IIP-OI 037 Open Appendix A 0473 IIP-OI 037 Open Appendix A 0474 IIP-OI 037 Open Appendix A 0475 IIP-OI 037 Open Appendix A 0476 IIP-OI 046 Open Appendix A IIP Appendix or Reference OPG-TMP-0003-R003 (Microsoft 2007)

251 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B 0492 IIP-OI 009 Open Appendix A 0493 IIP-OI 009 Open Appendix A 0494 IIP-OI 047 Complete Appendix B Complete Appendix B Complete Appendix B 0497 IIP-OI 048 Complete Appendix B 0498 IIP-OI 049 Open Appendix A 0499 IIP-OI 050 Open Appendix A 0500 IIP-OI 050 Open Appendix A 0501 IIP-OI 050 Open Appendix A Complete Appendix B Complete Appendix B Complete Appendix B Complete Appendix B 0506 IIP-OI 051 Open Appendix A 0507 IIP-OI 052 Complete Appendix B Complete Appendix B 0509 IIP-OI 053 Open Appendix A 0510 IIP-OI 054 Open Appendix A Complete Appendix B Complete Appendix B 0513 IIP-OI 055 Open Appendix A 0514 IIP-OI 056 Open Appendix A Complete Appendix B 0516 IIP-OI 057 Complete Appendix B Complete Appendix B Complete Appendix B New Item IIP-OI 058 Open Appendix A New Item IIP-OI 059 Open Appendix A IIP Appendix or Reference OPG-TMP-0003-R003 (Microsoft 2007)

252 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN IIP R000 Item Number IIP R001 Item Number Status New Item IIP-OI 060 Open Appendix A New Item IIP-OI 061 Open Appendix A New Item IIP-OI 062 Open Appendix A New Item IIP-OI 063 Open Appendix A New Item IIP-OI 064 Open Appendix A New Item IIP-OI 065 Complete Appendix B New Item IIP-OI 066 Open Appendix A New Item IIP-OI 067 Complete Appendix B New Item IIP-OI 068 Complete Appendix B New Item IIP-OI 069 Open Appendix A New Item IIP-OI 070 Complete Appendix B New Item IIP-OI 071 Open Appendix A New Item IIP-OI 072 Open Appendix A New Item IIP-OI 073 Complete Appendix B IIP Appendix or Reference OPG-TMP-0003-R003 (Microsoft 2007)

253 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Appendix D: Integrated Aging Management Program Aging management practices at Darlington Nuclear Generating Station (NGS) are managed through the implementation of an integrated set of managed systems and programs. These programs ensure that aging of critical equipment is managed such that the operation of Darlington NGS remains within the licensing basis and allows for station operational goals to be met. The Integrated Aging Management (IAM) Program ensures that the condition of critical equipment is understood and that activities are in place to ensure the health of these components and systems while the plant ages. The IAM program was developed on the basis of IAEA NS-G-2.12 which is in alignment with CNSC Reg Doc and there are 4 elements which ensure success of the IAM program. Element 1: Program Direction OPG has developed an IAM Program on the basis of IAEA NS-G-2.12 which is in alignment with CNSC Reg Doc The program integrates aging management functions that reside in a number of implementing work groups such as equipment reliability, safety analysis, maintenance, supply chain and work management. Element 2: Equipment Reliability OPG has implemented an extensive Equipment Reliability program in place for several years based on nuclear industry best practices. The Equipment Reliability Program applies a programmatic approach to the following elements: Scoping & Identification of Components, Performance Monitoring, Corrective Action, Continuing Equipment Reliability Improvement, Long-Term Planning & Life Cycle Management and Preventive Maintenance (PM) Implementation. For components applicable to the IIP safety goals, Scoping & Identification of Components is based on the 58 Safety Related Systems identified in the ISR. Components whose failure results in a full or partial impairment of a System Important to Safety (SIS) are considered critical components and they receive high priority in maintenance, inspection, monitoring and replacement activities. All other components are prioritized based on other parameters which support the nuclear power plant s generation goals. Performance Monitoring is evaluated through the monitoring of system and component performance and a comparison to the overall performance goals. The objective is to look for trends in overall performance and put action plans in place to address any issues to maintain or improve performance. These action plans are documented and prioritized in system health reports which are communicated to station stakeholders to support the improvement of the systems performance. Should a failure or degradation be discovered through Performance Monitoring activities, appropriate Corrective Actions are taken to ensure the system or component performs to its intended safety function. OPG-TMP-0003-R003 (Microsoft 2007)

254 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Continuing Equipment Reliability Improvements occur through continuous reviews of PM activities, industry OPEX, inspection and maintenance activities of components where frequencies and scope of activities are optimized to ensure high component reliability. Long Term Planning & Life Cycle Management is an ongoing process to create a longterm strategy which integrates long-term plans with the overall station business plan. These strategies prioritize improvement activities based on station need. These strategies are incorporated into the business plan and the appropriate system or component health reports. Most recently, Component Condition Assessments were completed which identified and evaluated degradation mechanisms to determine the extent of degradation, and identify long range asset preservation activities such as replacements of components that are required to address aging and reliability. The objective of the Preventive Maintenance program is to prevent or minimize equipment breakdown and to maintain equipment in a satisfactory condition for normal or emergency use. The output results in the identification of the optimal level of PM tasks necessary to achieve a balance between equipment performance and effective resources used. This involves the specification, scheduling and execution of timebased maintenance on systems and components to ensure continued reliable operation. Condition-based and predictive based activities are also included in the integrated approach used at OPG. Element 3: Parts Availability Supply chain personnel work with station organizations to maintain inventories of equipment and components that support plant reliability and nuclear safety. A spare parts process is in place which defines the criteria for identifying a component as a critical spare and to develop a strategy to mitigate obsolescence issues and lengthy lead times. Element 4: Work Management OPG s Work Management processes are based on Nuclear Industry best practices. Specific Work Management processes are in place for the work completed during a unit outage, a Refurbishment outage, or on-power. The work management processes specify how work is prioritized based on nuclear safety implications, regulatory requirements, preservation of special safety systems or systems important to safety, and threats to electrical generation. OPG-TMP-0003-R003 (Microsoft 2007)

255 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Appendix E: Glossary Asset Preservation activities are activities required to ensure long term preservation of equipment to achieve the greatest financial return and service life. Component Condition Assessment (CCA) provides: 1. An assessment of the current condition of the safety system components 2. An assessment of component life, given the status of the current programs for inspection and maintenance 3. Recommendation of actions required for the components to reach the target extended plant life. Component Condition Assessment (CCA) Recommendations are recommendations that fall into one of the following four broad implementation activity categories: 1. Improving the condition of components through replacement, refurbishment or repair. 2. Determining the condition of components through inspection or testing, followed by remedial actions if the components are found to be aged. 3. Improving the aging management practices to mitigate the effects of future aging through an adjustment to the Preventative Maintenance Program. 4. Addressing obsolescence. Contingency Actions are repair or replace activities resulting from inspections. Environmental Assessment (EA) is an assessment carried out under the Canadian Environmental Assessment Act to identify whether a specific project is likely to cause significant environmental effects. Final ISR Report is the document that summarizes the results and major findings of all the Safety Factors, the ISR Aggregate Review and the disposition of all gaps that were identified. Global Assessment provides an overall risk judgement on the acceptability of continued plant operation based on the significant ISR results and the EA mitigation measures and follow-up program elements, including plant strengths. The Global Assessment takes into account the safety improvements to address the issues identified in the EA and the ISR and the safety improvements resulting from identified opportunities to reduce the overall plant risk. The Global Assessment also incorporates the results of the Defense-in-Depth assessment. Global Assessment Report (GAR) summarizes the results of the Global Assessment by providing a high level summary of the ISR and EA and an overall judgement on Nuclear Safety. Integrated Implementation Plan (IIP) is the integrated result of the EA and ISR, identifying all necessary safety improvements, proposed plant modifications, safety OPG-TMP-0003-R003 (Microsoft 2007)

256 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN upgrades, compensatory measures and improvements to operation and management programs that will apply to the project and to long term operation. Integrated Safety Review (ISR) is a comprehensive assessment of an existing nuclear generating station in order to determine: 1. Extent to which the plant conforms to modern high-level safety goals and requirements. 2. Extent to which Licensing Basis remains valid. 3. Adequacy and effectiveness of arrangements that are in place to maintain plant safety for long-term operation. 4. Safety improvements to address gaps with respect to modern safety requirements identified during the assessment. ISR Gap is a clause for which a safety requirement in a code or standard is not met or for which the intent of the clause is not met depending on the type of code or standard. ISR Gaps exist for: 1. PROL Codes and Standards - the review finds that the safety requirement of a clause has not been met. 2. Non-PROL Codes and Standards the review finds that it does not meet either the safety requirement or the intent of a clause (or set of clauses). 3. Review Task - the assessment of the Review Task finds that it does not meet either the safety requirement or the intent of the Review Task. ISR Issue is a compilation of ISR Gaps with similar scope. The categorization, prioritization and resolution of an ISR Issue shall encompass all the included ISR Gaps. Life Extension is a set of activities for extending the safe operating life of a nuclear power plant beyond its design life. It involves the replacement or refurbishment of major components (e.g. pressure tubes) or substantial modifications to the plant, or both. Reactor Safety 1 (RS1) is an Operational Safety Requirement (OSR) system that is also a System Important to Safety (SIS) whose failure results in a Total Loss of Redundancy (TLR) or System Unavailability impairment condition. Reactor Safety 2 (RS2) is an OSR system that is also a SIS whose failure results in a Partial Loss of Redundancy (PLR) impairment condition, or is an OSR system that is also a non-sis system whose failure results in a Total Loss of Redundancy or System Unavailability impairment condition. Safety Improvements are changes to processes or plant to address the issues identified in the EA, the ISR, and the safety improvements resulting from identified opportunities to reduce the overall plant risk. Safety Related Systems are those systems, components and structures which, by virtue of their failure to perform in accordance with the design intent, would have the potential to impact on the radiological safety of the public or plant personnel from operation of the NPP. OPG-TMP-0003-R003 (Microsoft 2007)

257 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN Appendix F: References [R-1] NK38-REP R000, Darlington NGS Global Assessment Report, [R-2] RD-360, Life Extension of Nuclear Power Plants, February [R-3] [R-4] NK38-REP R000, "Environmental Impact Statement Darlington Nuclear Generation Station Refurbishment and Continued Operation", December 1, NK38-CORR , Louise Levert to Mr. Dietmar Reiner, Record of Proceedings Environmental Assessment on the Refurbishment and Continued Operation of the Darlington Nuclear Generating Station, March 14, 2013, E-DOC: [R-5] N-PROC-LE-0005 R003, Nuclear Refurbishment Integrated Safety Review Darlington, April [R-6] [R-7] NK38-CORR , F. Rinfret to Mr. Dietmar Reiner, Request for CNSC Acceptance of the Darlington NGS Global Assessment Report (GAR) and Integrated Implementation Plan (IIP), April 17, NK38-CORR , F. Rinfret to Mr. Dietmar Reiner, Darlington NGS: Request for CNSC Acceptance of Integrated Implementation Plan (IIP) Revision 001, December 22, [R-8] N-PROC-MP-0060 R005A, Aging Management Process, November [R-9] N-INS R002, Nuclear Refurbishment Issue Prioritization Process Darlington, December [R-10] N-PROG-MP-0008 R005, Integrated Aging Management, May, [R-11] N-PROC-MP-0045 R007, Technical Operability Evaluation, January [R-12] NK38-CORR , Dietmar Reiner and Brian Duncan to F. Rinfret, Darlington NGS A Integrated Implementation Plan (IIP) Change Control Process Principles, November [R-13] OPG Action Request Closure Notes, November [R-14] OPG Action Request Closure Notes, October [R-15] NK38-CORR , Darlington Nuclear Traffic Management Working Group (TMWG), August [R-16] NK38-REP , Darlington Refurbishment 2014 Communications Report, December 29, [R-17] G14375, Site Agreement Plan between the Corporation of the Municipality of Clarington and Ontario Power Generation, March 29, [R-18] P502128, Waterfront Trail Licence. [R-19] NK38-REP IIP-EA 009 Task Completion Installing Emergency Mitigation Equipment, April 2015 OPG-TMP-0003-R003 (Microsoft 2007)

258 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN [R-20] NK38-PLAN R000, Darlington Nuclear Refurbishment and Continued Operation Environmental Assessment Follow-Up Program Effluent Characterization Sampling Plan, October [R-21] NK38-REP , IIP-EA 012 Task Completion Thermal Effects of Whitefish eggs, April 2015 [R-22] N-PROG-MA-0025 R002, Major Components, March [R-23] NK38-REP R001, "Darlington NGS Integrated Safety Review Ageing And Actual Condition of System, Structures and Components Safety Factor Report, October 14, [R-24] NK38-INS R006, Darlington Refurbishment Program Scope Review Instruction, October [R-25] N-INS R002, Nuclear Refurbishment Gap Resolution Process Darlington, December [R-26] NK38-REP R000, IIP-OI 001 Task Completion Fire Alarm Systems CCW Pumphouse and WTP, April 2015 [R-27] NK38-REP , IIP-OI 002 Task Completion - Fire Suppression Additional Analysis, April 2015 [R-28] NK38-REP R000, IIP-OI 003 Task Completion Fire Protection Seismic Requirements, April 2015 [R-29] NK38-REP R000, IIP-OI Task Completion Fire Protection Requirements for Building Materials, April 2015 [R-30] NK38-CORR B. Duncan to F. Rinfret Darlington Ngs - Update On The Action Plan For The Resolution Of The Fire Protection Code-of-record Gaps, March 27, [R-31] NK38-REP R000, IIP-OI 018 Task Completion Detection of Significant Fire Hazards, April 2015 [R-32] NK38-REP , Completion of IIP task related to Instrument Survivability (IIP-OI 036, IIP-OI 037, IIP-OI 070), April [R-33] NK38-CORR , Completion of IIP Tasks Related to Installation of Passive Autocatalytic Re-combiners (PARS) (IIP-OI 045, IIP-OI 067, IIP-OI 068, IIP-OI 036, IIP-OI 066), February 20, [R-34] CSA C , Canadian Electrical Code, Part I, Canadian Standards Association [R-35] CSA C , Canadian Electrical Code, Part I, Canadian Standards Association [R-36] NK38-REP R000, IIP-OI 059 Task Completion Electrical Equipment and Wiring, April [R-37] N-GUID R002, Nuclear Projects Environmental Requirements Guideline, November OPG-TMP-0003-R003 (Microsoft 2007)

259 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN [R-38] NK38-NR-PLAN Sh R000, Darlington Refurbishment Environmental Program Management Plan, February [R-39] N-FORM R007, Environmental Impact Worksheet, December [R-40] PMP-TMP R002, Project Management Plan Template. [R-41] OPG Action Request Closure Notes, June [R-42] N-GUID R001, Excavation, Concrete Drilling, and Anchoring Process, November [R-43] OPG-PROC-0138 R000, Identification of Buried or Embedded Services, September [R-44] N-STC R001, Excavation and Backfill Practices, N-STC , December [R-45] N-PROG-RA-0001 R013, Consolidated Nuclear Emergency Plan, N-PROG- RA-0001, March [R-46] N-PROC-OP-0038 R007, Abnormal Waterborne Tritium Emission Response, July [R-47] NK38-CORR , Completion of IIP Item 63 (CCA 2547), September [R-48] NK38-REP , IIP-CC 012 Item Completion WIBA Terminal Blocks, April 2015 [R-49] NK38-CORR , Completion of lip Item IIP-CC 013 (CCA 1441) -Inspection of Injection Water Storage Tank, April 2015 [R-50] NK38-REP , IIP-CC 030 Task Completion Internal Inspection of MSR System MOVs, April 2015 [R-51] NK38-CORR , Completion of lip Item 67 (CCA153) -Inspection of the Heat Transport Pressurizer, April 2015 [R-52] NK38-CORR , Completion of lip Item 102 (CCA2964) - Inspection of LlSS Mixing and Injection Tank, April 2015 [R-53] NK38-CORR , Completion of IlP Item 112 (CCA83) Inspection of CSA Nuclear Structures, April 2015 [R-54] NK38-CORR , Completion of lip Item 114 (CCA85) -Inspection of CSA Building Structures, April 2015 [R-55] NK38-CORR , Completion of lip Item IIP-CC-070 (CCA87) - Inspection of Turbine Supporting Structures, April 2015 [R-56] NK38-REP R002, Nuclear Refurbishment Issue Resolution Form Darlington Issue #D081 - Radioactive Material Storage, October OPG-TMP-0003-R003 (Microsoft 2007)

260 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN [R-57] NK38-REP R002, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D251 Fire Protection Requirements for Air- Cleaning Units, April [R-58] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D445 Combustible Insulation, April [R-59] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D446 Combustible Material in Ducts, April [R-60] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D452 Spatial Separation and Exposed Building Face, April [R-61] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D464 Signage Requirements, April [R-62] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D468 Pipe Insulation Requirements, April [R-63] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D469 Inspection, Testing and maintenance Requirements, April [R-64] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D472 Oil Storage Tank and Piping Requirements, April [R-65] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D473 Documentation, October [R-66] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D477 Size of Bypass, April [R-67] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D484 - Magnetic Locks, March [R-68] NK38-REP R002, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D247 - In-Service Testing of Air Treatment Systems, April [R-69] NK38-REP R003, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D027 - Severe Accident and Beyond Design Basis Accident (BDBA) Analysis/ SAMG, November [R-70] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D337 No Governance Reference for Zone Definitions, April [R-71] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D338 No Governance to Maintain 5 MDU s, April [R-72] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D339 Radiological Event Monitoring Support for Non-OPG Events, April OPG-TMP-0003-R003 (Microsoft 2007)

261 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN [R-73] NK38-REP R002, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D115 Fire Protection Requirements for Laboratories, April [R-74] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D460 Fuel Supply Shut Off Valves, April [R-75] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D482 Monitoring of Fire Pump Alternate Power Source, April [R-76] NK38-REP R002, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D266 Lack of ALARA & radiation protection training for plant design staff, March [R-77] NK38-REP R002, Nuclear Refurbishment Issue Resolution Form - Darlington Issue # D303 - Extension Of The Containment Envelope Requirements, February [R-78] NK38-REP R002, Nuclear Refurbishment Issue Resolution Form - Darlington Issue # D304 - Change To Extension Of The Containment Envelope, April [R-79] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form - Darlington Issue# D321 - Threaded Connections, March [R-80] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D355 Library Functions, March [R-81] NK38-REP R002, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D412 Predicted Failure mode of Anchorage Systems, February [R-82] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form Darlington Issue # D413 Concrete Cover for Reinforcement, February [R-83] NK38-REP R001, Nuclear Refurbishment Issue Resolution Form - Darlington Issue # D500 Adequacy of the N289.3-M81 Code Review Report, April [R-84] NK38-REP , IIP-OI 005 Line Item Completion Fire Protection Lightning, April 2015 [R-85] NK38-REP , IIP-OI 007 Line Item Completion Fire Protection Laboratories, April 2015 [R-86] NK38-CORR , Completion of IIP-OI 013 (Thermal Insulating Materials CSA N Fire Protection for CANDU Nuclear Power Plants ), February 2015 [R-87] NK38-CORR , Completion of IIP-OI 014 Fire Protection Program Audit, April 2015 OPG-TMP-0003-R003 (Microsoft 2007)

262 Document Number: Usage Classification: Report NK38-REP N/A Sheet Number: Revision Number: Page: N/A R of 84 Title: DARLINGTON NGS INTEGRATED IMPLEMENTATION PLAN [R-88] NK38-CORR , Completion of IIP-OI 017 (Fire Protection Air Filter Media Requirements), February 2015 [R-89] NK38-REP , IIP-OI 020 Line Item Completion Issues Associated with CCR, FHA, FSSA, April 2015 [R-90] NK38-REP , IIP-OI 021 Line Item Completion Electrical Code Impacts to Fire Protection, April 2015 [R-91] NK38-CORR , Completion of IIP-OI 032 (Fire Pump Disconnecting Means), February 2015 [R-92] NK38-CORR , Completion of IIP-OI 047 Fire Protection Requirements for Indoor Fuel Oil Systems, April 2015 [R-93] NK38-REP , IIP-OI 048 Item Completion Concrete Containment Structures, April 2015 [R-94] NK38-REP , IIP-OI 052 Line Item Completion Seismic Time Histories, April 2015 [R-95] NK38-CORR , Completion of IIP-OI 057 (CNSC Plant Condition Assessment Type II Inspection), February 2015 [R-96] NK38-REP , IIP-OI 065 Line Item Completion Hygrometer Probe Requirements, April 2015 [R-97] NK38-CORR , Completion of IIP-OI 073 (Section 5 of the CSA N Code Refresh), February OPG-TMP-0003-R003 (Microsoft 2007)

263 15-H8 Unprotected PART TWO Part Two provides all available information pertaining directly to the licence, including: 1. Proposed changes to the licence and the Licence Conditions Handbook (LCH); 2. The proposed licence; 3. The proposed LCH; and 4. The current licence. e-doc (Word) July 2015 e-doc (PDF)

264 15-H8 Unprotected Proposed Changes to the Licence and the Licence Conditions Handbook Background In 2013 the Darlington NGS PROL (PROL) was renewed for a period of 22 months, in lieu of the normal 5-year period, to allow OPG sufficient time to complete the necessary studies for the proposed refurbishment outages. At the request of OPG, to allow additional time to provide more comprehensive documentation, reflect new CNSC expectations relative to probabilistic safety assessment and facilitate public engagement for this relicensing process, the PROL was subsequently renewed by the Commission until December 31, Over the last few years, the PROL and LCH have been subject to continuous improvements with enhanced regulatory oversight as a result of experience gained. Power Reactor Operating Licence As further described in section 5.11 of this CMD, CNSC staff are recommending a licence period of 10 years (January 1, 2016 to December 31, 2025) for the Darlington NGS PROL. CNSC staff s recommendation for proposing a 10-year licence period is based on: The publication of CNSC regulatory document REGDOC-2.3.3, Periodic Safety Reviews which supersedes CNSC regulatory document RD-360, Life Extension of Nuclear Power Plants. REGDOC builds upon the ISR process outlined in RD-360 and includes a requirement for a safety review to be completed every 10 years throughout the lifetime of the NPP. OPG has already performed an integrated safety review (ISR) in accordance with RD-360 which is considered acceptable as a first PSR. CNSC staff have recommended transitioning to operating licences for NPPs that are valid for 10 years, as compared to the current five year licence periods, and a PSR done every 10 years to coincide with licence renewals. The proposed Darlington NGS PROL was based on a generic PROL template with standardized licence conditions (LC) covering all SCAs, including nuclear-facility specific LCs which are clearly identifiable in the licence. Recently, the format of the PROL has slightly changed whereby the numbering now conforms to the numbering conventions used by the CNSC for SCAs and REGDOCs. Furthermore, a significant change being proposed by CNSC staff is to remove the majority of the direct references to CNSC regulatory documents and CSA standards from the PROL and include them as compliance verification criteria (CVC) in the LCH. This change is made possible by the requirement for licensees to operate in accordance with the licensing basis (LC G.1). e-doc (Word) July 2015 e-doc (PDF)

265 15-H8 Unprotected The proposed PROL contains the following new LCs: LC # Proposed LC Rationale 3.4 The licensee shall prepare and conduct a periodic safety review in support of its subsequent power reactor operating licence application The licensee shall implement a return to service plan for refurbishment The licensee shall implement the Integrated Implementation Plan The licensee shall obtain the approval of the Commission, or consent of a person authorized by the Commission, prior to the removal of established regulatory hold points. This new LC reflects the addition of PSR to the Canadian regulatory framework and to align the conduct of the PSR to coincide with OPG s next licence application. Return to service involves returning the reactor back to commercial operation, postrefurbishment. This LC requires OPG to implement a return to service plan for refurbishment activities. The IIP contains the OPG commitments to be carried out during life extension activities, including refurbishment. This LC requires OPG to carry out the commitments identified in the IIP and to provide updates to the CNSC. CNSC staff have identified four (4) regulatory hold points for return to service for each unit undergoing refurbishment. This LC requires OPG to seek written CNSC approval before releasing these hold points. In addition to the new LCs outlined above, LC 5.3 was expanded to include equipment qualification which is a broader requirement indicating that equipment must be capable of performing their designed function given possible operating conditions. It also formalizes the requirements for seismic qualification in the LC. Minor modifications were made to several other LCs to further streamline and simplify the PROL. The current PROL and proposed PROL for Darlington are attached to this CMD. e-doc (Word) July 2015 e-doc (PDF)

266 15-H8 Unprotected Licence Conditions Handbook The draft LCH describes compliance verification criteria (CVC) on how the licensee is expected to meet the licence conditions in the PROL. The Commission considers the LCH in its decision to renew the licence and maintains regulatory oversight by receiving annual updates of major LCH changes through the annual NPP report. Since 2012, proposed changes to the LCH include the new LCs as described above and several other minor changes and updates. Similar to the Bruce licence renewal in 2015 (CMD 15-H2,) CNSC staff are proposing to move most of the direct references of CNSC regulatory documents and CSA standards from the PROL to the LCH. The exceptions are RD-204 and REDGOC which are described below: Sections 9(2) and 9(3) of the Class I Nuclear Facilities Regulations explicitly state that the requirements for qualifications, training, examinations and requalification tests supporting the certification of personnel are to be specified in the licence. As a result, RD-204 (the regulatory document that specifies these requirements) must be referenced in the PROL; and Section 29(3) and (31(2) of the General Nuclear Safety and Control Regulations (GNSCR) explicitly state that reporting requirements that are identified directly in the licence supersede the reporting requirements in GNSCR section 29(1), 29(2) and 31(1). As a result, REGDOC (the regulatory document that specifies reporting requirements) must be referenced in the PROL. This approach allows for better alignment between the licensing SCA structure and the regulatory documents, CSA standards and OPG s management system. Regulatory documents clarify regulatory requirements but are not facility focused. CSA standards are written to be applicable to multiple engineering disciplines (for example: fire safety, fire design and emergency preparedness), but are not written for a single licence condition and are thus difficult to interpret in a strictly legal manner. Moving the regulatory documents and CSA standards to the LCH allows for clarification of how regulatory documents and CSA standards fit into the SCA structure; for example, the LCH contains multiple cross-references between licence conditions that add clarity and consistency of interpretation. This approach is not a relaxation of CNSC's regulatory oversight; instead, it will further simplify the PROL, increase regulatory clarity and stability, and allow the regulatory focus to be on matters of true regulatory interest. PROL non-compliances will be focused on safety significant programmatic failures. e-doc (Word) July 2015 e-doc (PDF)

267 15-H8 Unprotected The current PROL already contains many requirements by citing CNSC regulatory documents, CSA standards and codes; however, CNSC staff propose that the LCH include many of these same requirements, as well as the following documents which will enhance the regulatory requirements: No Document Identifier Current 1. Class I Regulations CNSC Regulatory Documents Proposed Title Implementation Date REGDOC Personnel Training Gap analysis and implementation plan to be provided by March G-306 REGDOC Accident Management January 1, RD-360 REGDOC Periodic Safety Reviews January 1, S-210 RD/GD-210 Maintenance Programs January 1, RD-334 REGDOC Aging Management July 15, S-296 REGDOC Environmental Protection January 1, RD-353, G-225 REGDOC Nuclear Emergency Preparedness December 31, S-298 REGDOC Nuclear Response Force January 1, Nuclear Security Regulations REGDOC Site Access Security January 1, 2016 e-doc (Word) July 2015 e-doc (PDF)

268 15-H8 Unprotected No. Document Identifier Current Proposed CSA Standards Title Implementation Date 1. N N Management System January 1, N General Requirements for January 1, Class I Regulations N Safety Systems Safety-related Structures January 1, N Seismic, Design and Qualification 5. N N (Annex N only) Pressure-retaining Systems and Components 6. N N Periodic Inspection of Components January 1, 2016 January 1, 2016 July 1, N Environmental Monitoring January 1, S-296 N Effluent Monitoring January 1, N Environmental Risk Assessment 10. N N Management of Low and Intermediate Level Waste December 1, 2016 January 1, N N Fire Protection January 1, 2016 The draft LCH for Darlington is attached to this CMD. e-doc (Word) July 2015 e-doc (PDF)

269 PDF Ref.: e-doc # Word Ref.: e-doc # File / Dossier: 2.01 NUCLEAR POWER REACTOR OPERATING LICENCE DARLINGTON NUCLEAR GENERATING STATION I) LICENCE NUMBER: PROL 13.00/2025 II) LICENSEE: Pursuant to section 24 of the Nuclear Safety and Control Act this licence is issued to: Ontario Power Generation Inc 700 University Avenue Toronto, Ontario M5G 1X6 III) LICENCE PERIOD: This licence is valid from January 1, 2016 to December 31, 2025, unless suspended, amended, revoked or replaced. IV) LICENSED ACTIVITIES: This licence authorizes the licensee to: (i) (ii) (iii) (iv) operate the Darlington Nuclear Generating Station which includes the Darlington Tritium Removal Facility housed within the Heavy Water Management Building (hereinafter the nuclear facility ) at a site located in the Municipality of Clarington, in the Regional Municipality of Durham, in the Province of Ontario; possess, transfer, use, package, manage and store the nuclear substances that are required for, associated with, or arise from the activities described in (i); possess and use prescribed equipment and prescribed information that are required for, associated with, or arise from the activities described in (i); possess, transfer, process, package, manage and store the nuclear substances associated with the operation of the Darlington Tritium Removal Facility; V) EXPLANATORY NOTES: (i) (ii) Nothing in this licence shall be construed to authorize non-compliance with any other applicable legal obligation or restriction. Unless otherwise provided for in this licence, words and expressions used in this licence have the same meaning as in the Nuclear Safety and Control Act and associated Regulations.

270 Page 2 of 4 Nuclear Power Reactor Operating Licence PROL 13.00/2025 (iii) The Darlington NGS Licence Conditions Handbook (LCH) provides compliance verification criteria including the Canadian standards and regulatory documents used to verify compliance with the conditions in the licence. The LCH also provides information regarding delegation of authority, applicable versions of documents and non-mandatory recommendations and guidance on how to achieve compliance. VI) CONDITIONS: G. General G.1 The licensee shall conduct the activities described in Part IV of this licence in accordance with the licensing basis, defined as: (i) the regulatory requirements set out in the applicable laws and regulations (ii) the conditions and safety and control measures described in the facility's or activity's licence and the documents directly referenced in that licence (iii) the safety and control measures described in the licence application and the documents needed to support that licence application; unless otherwise approved in writing by the Canadian Nuclear Safety Commission (CNSC, hereinafter the Commission ). G.2 The licensee shall give written notification of changes to the facility or its operation, including deviation from design, operating conditions, policies, programs and methods referred to in the licensing basis. G.3 The licensee shall control the use and occupation of any land within the exclusion zone. G.4 The licensee shall provide, at the nuclear facility and at no expense to the Commission, suitable office space for employees of the Commission who customarily carry out their functions on the premises of that nuclear facility (onsite Commission staff). G.5 The licensee shall maintain a financial guarantee for decommissioning that is acceptable to the Commission. G.6 The licensee shall implement and maintain a public information and disclosure program. 1. Management System 1.1 The licensee shall implement and maintain a management system. 2. Human Performance Management 2.1 The licensee shall implement and maintain a human performance program. 2.2 The licensee shall implement and maintain the minimum shift complement and control room staffing for the nuclear facility. 2.3 The licensee shall implement and maintain training programs for workers. The certification process and supporting examinations and tests shall be conducted in accordance with CNSC regulatory document RD-204 CERTIFICATION OF PERSONS WORKING AT NUCLEAR POWER PLANTS. Persons appointed to the following positions require certification: (i) (ii) (iii) Responsible Health Physicist; Shift Manager; Control Room Shift Supervisor;

271 Page 3 of 4 Nuclear Power Reactor Operating Licence PROL 13.00/2025 (iv) (v) Authorized Nuclear Operator; and Unit 0 Control Room Operator. 3. Operating Performance 3.1 The licensee shall implement and maintain an operations program, which includes a set of operating limits. 3.2 The licensee shall not restart a reactor after a serious process failure without the prior written approval of the Commission, or prior written consent of a person authorized by the Commission. 3.3 The licensee shall notify and report in accordance with CNSC regulatory document REGDOC REPORTING REQUIREMENTS: NUCLEAR POWER PLANTS. 3.4 The licensee shall prepare and conduct a periodic safety review in support of its subsequent power reactor operating licence application. 4. Safety Analysis 4.1 The licensee shall implement and maintain a safety analysis program. 5. Physical Design 5.1 The licensee shall implement and maintain a design program. 5.2 The licensee shall implement and maintain a pressure boundary program and have in place a formal agreement with an Authorized Inspection Agency. 5.3 The licensee shall implement and maintain an equipment and structure qualification program. 6. Fitness for Service 6.1 The licensee shall implement and maintain a fitness for service program. 7. Radiation Protection 7.1 The licensee shall implement and maintain a radiation protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within seven days. 8. Conventional Health and Safety 8.1 The licensee shall implement and maintain a conventional health and safety program. 9. Environmental Protection 9.1 The licensee shall implement and maintain an environmental protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within seven days. 10. Emergency Management and Fire Protection 10.1 The licensee shall implement and maintain an emergency preparedness program The licensee shall implement and maintain a fire protection program.

272 Page 4 of 4 Nuclear Power Reactor Operating Licence PROL 13.00/ Waste Management 11.1 The licensee shall implement and maintain a waste management program The licensee shall implement and maintain a decommissioning strategy. 12. Security 12.1 The licensee shall implement and maintain a security program. 13. Safeguards and Non-Proliferation 13.1 The licensee shall implement and maintain a safeguards program. 14. Packaging and Transport 14.1 The licensee shall implement and maintain a packaging and transport program. 15. Nuclear Facility-Specific 15.1 The licensee shall implement and maintain an operations program for the Tritium Removal Facility, which includes a set of operating limits The licensee shall implement a return to service plan for refurbishment The licensee shall implement the Integrated Implementation Plan The licensee shall obtain the approval of the Commission, or consent of a person authorized by the Commission, prior to the removal of established regulatory hold points. SIGNED at OTTAWA (scanned version e-doc #######) Michael Binder President CANADIAN NUCLEAR SAFETY COMMISSION

273 Licence Conditions Handbook Effective Date: January 1, 2016 (LCH-DNGS-R000) Darlington Nuclear Generating Station Nuclear Power Reactor Operating Licence PROL 13.00/2025 (Effective: January 1, 2016) SIGNED at OTTAWA on the xx th MMM, Original signed by B. Howden (scanned version e-doc #######) Barclay D. Howden Director General, Directorate of Power Reactor Regulation CANADIAN NUCLEAR SAFETY COMMISSION e-doc Page 1 of 142

274 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Revision History: Effective Date Revision # LCH e-doc # Section(s) Changed Description of the Changes DCR List e-doc # January 1, 2016 R000 Word e-doc (PDF embedded) First Issue Word e-doc (PDF embedded) e-doc Page 2 of 142

275 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 TABLE OF CONTENTS PART I INTRODUCTION...5 PART II FACILITY SPECIFIC...6 A. GENERAL...6 G.1 Licensing Basis for the Licensed Activities...6 G.2 Notification of Changes...9 G.3 Land Use and Occupation...12 G.4 Office for CNSC On-Site Inspectors...14 G.5 Financial Guarantees...15 G.6 Public Information and Disclosure SCA MANAGEMENT SYSTEM Management System Requirements SCA HUMAN PERFORMANCE MANAGEMENT Human Performance Program Minimum Shift Complement Training, Certification and Examination Program SCA OPERATING PERFORMANCE Operations Program Approval to restart after a serious process failure Reporting Requirements Periodic Safety Review SCA SAFETY ANALYSIS Safety Analysis Program SCA PHYSICAL DESIGN Design Program Pressure Boundary Program Equipment and Structure Qualification Program SCA FITNESS FOR SERVICE Fitness for Service Programs SCA RADIATION PROTECTION Radiation Protection Program and Action Levels SCA CONVENTIONAL HEALTH AND SAFETY Conventional Health and Safety Program...77 e-doc Page 3 of 142

276 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA ENVIRONMENTAL PROTECTION Environmental Protection Program SCA EMERGENCY MANAGEMENT AND FIRE PROTECTION Emergency Preparedness Program Fire Protection Program SCA WASTE MANAGEMENT Waste Management Program Program for Planning the Decommissioning of the nuclear facility SCA SECURITY Nuclear Security Program SCA SAFEGUARDS AND NON-PROLIFERATION Safeguards Program SCA PACKAGING AND TRANSPORT Packaging and Transport Program NUCLEAR FACILITY-SPECIFIC Tritium Removal Facility Operations Refurbishment - Return to Service Integrated Implementation Plan Regulatory Hold Points for Return to Service and Continued Operations APPENDIX A Administrative Processes APPENDIX B Glossary of Terms APPENDIX C List of All Version-Controlled Documents APPENDIX D List of Licensee Documents Requiring Written Notification APPENDIX E List of Documents used as Guidance or Criteria APPENDIX F Approvals pursuant to a PROL LC granted by the Commission APPENDIX G Consents pursuant to a PROL LC APPENDIX H Resolution of Inconsistencies e-doc Page 4 of 142

277 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 PART I INTRODUCTION The general purpose of the Licence Conditions Handbook (LCH) is to identify and clarify the regulatory requirements and other relevant parts of the licensing basis for each licence condition. This will help ensure that the licensee maintains facility operation in accordance with the licensing basis for the facility and the intent of the nuclear power reactor operating licence (PROL). The LCH is not intended to introduce new requirements but simply to elaborate upon the requirements in the licensing basis. The LCH should be read in conjunction with the licence. The LCH provides compliance verification criteria (CVC) that the staff of the Canadian Nuclear Safety Commission (CNSC) uses to verify compliance with each licence condition. These regulatory criteria are written in mandatory language. The CVC also contain operational limits and information regarding delegation of authority and applicable versions of documents referenced in the licence. Furthermore, the LCH provides nonmandatory recommendations and guidance on enhancing the effectiveness of the safety and control measures. Direct references to most Canadian standards and CNSC regulatory documents have been removed from the associated PROL as a last step in the CNSC licence reform for operating licences for nuclear power reactors. The licensee is required to meet the requirements of any standard or regulatory document that is explicitly mentioned in the CVC sections of this LCH, as they were referenced in the licence applications or supplemental updates and; therefore, form part of the licensing basis of the nuclear facility. However, the standards and regulatory documents referenced in the Recommendations and Guidance section should be considered by the licensee as a means to meet or exceed requirements. Where the LCH refers to licensee submissions to CNSC staff or requests for consent of CNSC staff, if the proposed action or request would lead to operation outside the licensing basis, licence condition G.1 applies. For these submissions and requests, the prevailing communications protocol shall be followed, unless stated otherwise in the CVC for the applicable licence condition. Current versions of the written notification (WN) documents cited in this LCH are tracked in the document OPG Darlington NGS PROL Written Notification Documents in LCH (e-doc ). This spreadsheet is controlled by Darlington Regulatory Program Division (DRPD). This document is available upon request from DRPD. This LCH includes appendices A to E which contain administrative information, a glossary of terms and lists of LCH-related documents. Appendices F through H provide tables of approvals and consents granted to the licensee. For more information on the role, purpose and content of the LCH, refer to information document Purpose and Description of the Licence Conditions Handbook for the Darlington NGS (e-doc ). e-doc Page 5 of 142

278 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 PART II FACILITY SPECIFIC A. GENERAL G.1 Licensing Basis for the Licensed Activities Licence Condition G.1: The licensee shall conduct the activities described in Part IV of this licence in accordance with the licensing basis, defined as: (i) (ii) (iii) the regulatory requirements set out in the applicable laws and regulations the conditions and safety and control measures described in the facility's or activity's licence and the documents directly referenced in that licence the safety and control measures described in the licence application and the documents needed to support that licence application; unless otherwise approved in writing by the Canadian Nuclear safety Commission (CNSC, hereinafter the Commission ). Preamble: The licensing basis is discussed in CNSC document INFO The licensing basis sets the boundary conditions for acceptable performance at a regulated facility or activity, thus establishing the basis for the CNSC compliance program with respect to that regulated facility or activity. This LCH aligns specific parts of the licensing basis with each LC. For those LCs that require the licensee to implement and maintain a particular program, the licensing basis includes the licensee document(s) that describe the program. This could be a single document, or multiple documents, depending on the licensee s document structure. Compliance Verification Criteria: Part (i) of the licensing basis, lists the applicable laws and regulations that are set out in several federal statutes and agreements, including the following: Nuclear Safety and Control Act; Canadian Environmental Assessment Act; Canadian Environment Protection Act; Nuclear Liability Act; Transportation of Dangerous Goods Act; Radiation Emitting Devices Act; Access to Information Act; and Canada/IAEA Safeguards Agreement. Part (iii) of the licensing basis consists of the safety and control measures described in the licence application and the documents needed to support that licence application. The safety and control GENERAL Licence Conditions e-doc Page 6 of 142

279 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 measures include important aspects of that documentation, as well as important aspects of analysis, design, operation, etc. They may be found in high-level, programmatic licensee documents but might also be found in lower-level, supporting licensee documentation. Part (iii) of the licensing basis also includes safety and control measures in the CNSC regulatory documents, CSA standards, and other standards and references that are cited in the application or in the licensee s supporting documentation. Those support documents could cite other documents that also contain safety and control measures (i.e., there may be safety and control measures in nested references in the application). LC G.1 requires the licensee to conform to, and/or implement, all the safety and control measures. Note, however, that not all details in referenced documents are necessarily considered to be safety and control measures. Details that are not directly relevant to safety and control measures for facilities or activities authorized by the licence are excluded from the licensing basis. Details that are relevant to a different safety and control area (i.e., not the one associated with the main document), are only part of the licensing basis to the extent they are consistent with the main requirements for both safety and control areas. Informative or guidance sections in referenced documents are not considered to be part of the licensing basis. The licensing basis is established by the Commission at the time the licence is issued. Per LC 1.1, operation during the licence period that is not in accordance with the licensing basis is only allowed based on the written approval of the Commission. Similarly, only the Commission can change the licensing basis during the licence period; and this would also be expected to be recorded in writing. Where the licensing basis refers to specific configurations, methods, solutions, designs etc., and the licensee is free to propose alternate approaches that differ from those in the CVC as long as they remain in accordance with the licensing basis for the facility. This LC is not intended to unduly inhibit the ongoing management and operation of the facility or the licensee s ability to adapt to changing circumstances and continuously improve. This LC does not explicitly prohibit changes (such as in management or operation) with a neutral or positive impact on safety. Changes shall be in accordance with the licensing basis and shall be made in accordance with the licensee s management system (see LC 1.1). Changes to licensee documents may require written notification to the CNSC, even if they are in accordance with the licensing basis; see LC G.2. For unapproved operation that is not in accordance with the licensing basis, the licensee shall take action as soon as practicable to return to a state consistent with the licensing basis, taking into account the risk significance of the situation. In the event of any conflict or inconsistency between two elements of the licensing basis, the licensee shall direct the conflict or inconsistency to CNSC staff for resolution. Any such conflict or inconsistency identified would be discussed between the licensee and CNSC staff; the outcome of such discussions will be documented to ensure a common understanding. In case of a conflict between Canadian Standards Association (CSA) standards, CNSC will consult with the CSA before reaching a conclusion on the resolution. Resolutions made pursuant to this LC are recorded in Appendix H of the LCH. This appendix lists the subject of the conflict or inconsistency and will give the reference to the electronic record GENERAL Licence Conditions e-doc Page 7 of 142

280 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 (e-doc XXXXXXX) documenting the resolution as well as the licensee s identifying correspondence number. Any resolution made will be formally communicated to all other power reactor licensees as appropriate, ensuring consistency of CNSC regulatory oversight amongst all nuclear facilities in Canada. The appropriate changes will be reflected in the CVC of the affected LC and compliance to the resolution will therefore be subject to verification. The licensee s safety and control measures are described in the following documentation provided at the time of the licence application, or in support of thereafter: Date Document Title Document # E-Doc # December 13, 2013 May 1, 2014 January 30, 2015 Darlington NGS - Application for Renewal of Darlington Nuclear Generating Station Power Reactor Operating Licence 13.00/2014 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 Darlington NGS- Additional information in Support of Application for Renewal of Darlington s Power Reactor Operating Licence (PROL) 13.01/2015 NK38-CORR NK38-CORR NK38-CORR Recommendations and Guidance: When the licensee becomes aware that a proposed change or activity might be outside the licensing basis, it should first seek direction from CNSC staff regarding the potential acceptability of this change or activity. The licensee should take into account that certain types of proposed changes might require significant lead times before CNSC staff can make recommendations and/or the Commission can properly consider them. Examples of these types of changes are discussed under various licence conditions in this LCH. GENERAL Licence Conditions e-doc Page 8 of 142

281 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 G.2 Notification of Changes Licence Condition G.2: The licensee shall give written notification of changes to the facility or its operation, including deviation from design, operating conditions, policies, programs and methods referred to in the licensing basis. Preamble: The licensing basis sets the boundary conditions for acceptable performance at a regulated facility or activity and thus establishes the basis for the CNSC s compliance program in respect of that regulated facility or activity. Licensees are required to operate nuclear facilities in accordance with the licensing basis; however, as changes to the documents included or referenced in the licence application are to be expected during the licensing period, licensees are expected to assess changes for impact on the licensing basis. Any changes to the licensing basis require evaluation to determine impact as related to the provision for the protection of the environment, the health and safety of persons and the maintenance of national security and measures required to implement international obligations to which Canada has agreed. In general, it is expected that changes for which the licensee shall notify the CNSC will be captured as changes to specific licensee documents. This LCH identifies licensee documents that require written notification of changes to the CNSC. They are primarily selected from the set of documents supporting the application and which describe the licensee s safety and control measures (part (iii) of the licensing basis, as defined in LC G.1). In identifying the WN documents for each LC, CNSC staff select licensee documents that provide reasonable assurance that adequate safety and control measures are in place to satisfy the LC. See LC G.1 for additional discussion of the licensing basis. Tables under each LC in the LCH identify the documents (if any) requiring WN of change. Appendix A.4 describes some of the general criteria that CNSC staff will use to assess changes to documents subject to the WN requirement. WN documents are subdivided into ones that require prior WN of changes and those that require written notification only (i.e. where a change can be implemented prior to the WN being provided). CNSC staff will track the version history of all WN documents cited in the LCH with the exception of security-related documents. A spreadsheet list controlled by the DRPD entitled OPG - Darlington NGS PROL Written Notification Documents in LCH (e-doc ) has been created for this purpose. Compliance Verification Criteria: The licensee shall, as a minimum, provide WN to the CNSC of changes to the specific licensee documents identified in this LCH under the most relevant LC. The changes for which CNSC requires WN consist, primarily, of those captured as changes to specific licensee documents. Licensee documents that require written notification of change are identified in this LCH under the most relevant LC. These documents represent the minimum subset of documents. For any change that is not captured as a change to a document listed in the LCH, if it negatively impacts GENERAL Licence Conditions e-doc Page 9 of 142

282 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 designs, operating conditions, policies, programs, methods, or other elements that are integral to the licensing basis, the licensee shall provide WN of the change. WN is defined as a physical or electronic communication from a person authorized to act on behalf of the licensee to a CNSC delegated authority or a CNSC staff member acting on behalf of a CNSC delegated authority. WN documents are subdivided into ones that require prior WN of changes and those that require written notification only. For the former type, the licensee shall submit the WN to the CNSC prior to implementing the change. Typically, the requirement is to submit the proposed changes 30 days prior to planned implementation; however the licensee shall allow sufficient time for the CNSC to review the change proportionate to its complexity and the importance of the safety and control measures being affected. For the latter type, the licensee need only submit the WN at the time of implementing the change. All WNs shall include a summary description of the change, the rationale for the change, and a summary explanation of how the licensee has concluded that the changed document remains in accordance with the licensing basis. A copy of the revised WN document shall accompany the notification. Changes to the licensing basis that are not clearly in the safe direction require further assessment of impact to determine if prior Commission approval is required in accordance with LC G.1. Additional considerations for changes to facility operation or operating limits, conditions or procedures are discussed under LC 3.1 and those for facility design or equipment are discussed under LC 5.2. In the event of a discrepancy between the tables in any section of this LCH that contain numbers and limits drawn from licensee documents (e.g., minimum shift complement, action levels, derived releases limits and environmental action levels) and the licensee documentation upon which they are based, the licensee documentation shall be considered the authoritative source, provided that their change control process was followed. Since these limits are considered safety and control measures, any change to them in the licensee documents listed in the WN tables will be reviewed by CNSC staff to confirm they remain within the licensing basis, using the criteria in Appendix A.4 and any other applicable criteria. Should a change to a WN document listed in this LCH also require submission for approval/acceptance per a standard referenced in the PROL, the licensee shall submit that document for approval/acceptance to comply with the governing standard and the associated LC. Submission of a proposed WN document for approval, in accordance with a LC does not alleviate the licensee from also providing the WN of the revised (approved) document. OPG shall follow its process N-PROG-AS-0006 Records and Document Control, for any changes related to a document listed in Appendix D. The following documents require written notification of change: Document Title Document # Prior Notification? Records and Document Control N-PROG-AS-0006 No GENERAL Licence Conditions e-doc Page 10 of 142

283 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Adequate insurance is a safety and control measure that is necessary for compliance with the Nuclear Liability Act. The licensee shall notify the CNSC of changes to the insurance policy. This WN is specified under LC G.2 because insurance is a safety and control measure that does not fit under any other LC. Recommendations and Guidance: For proposed changes that would not be in accordance with the licensing basis, the Recommendations and Guidance for LC G.1 apply. GENERAL Licence Conditions e-doc Page 11 of 142

284 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 G.3 Land Use and Occupation Licence Condition G.3: The licensee shall control the use and occupation of any land within the exclusion zone. Preamble: The General Nuclear Safety and Control Regulations require that a licence application contain a description of the nuclear facility. The siting guide used at the time of design of all Canadian NPPs (AECB-1059, e-doc ) stipulated an exclusion zone that extended at least 914 metres (3000 feet) from the exterior of any reactor building. Compliance Verification Criteria: The licensee shall ensure that the use and occupancy of land within the exclusion zone does not compromise the safety and control measures in the licensing basis. Specifically, the licensee shall consider emergency preparedness and ALARA with respect to land use within the exclusion zone. This applies to land the licensee occupies as well as to land occupied by others. The licensee shall not permit a permanent dwelling to be built within the exclusion zone. Permanent dwelling refers to housing that is meant to be fixed. The licensee may erect, for a short time without prior notification, a temporary dwelling (e.g., a trailer). The licensee shall notify the CNSC of changes to the use and occupation of any land within the exclusion zone. The notice shall be submitted prior to the change, with lead time in proportion to the expected impact of the change on the licensee s safety and control measures. The following documents require written notification of change: Document Title Document # Prior Notification? Darlington NGS-A Plant Survey June 7, 1999 Darlington NGS Safety Report: Part 1 Plant/Site Description Ontario Hydro layout drawing, Rev. 9, November 1981 Ontario Hydro layout drawing, Rev. 4, March 1982 LO4254 DZS NK38-SR NK38-DOH NK38-DOH Yes No No No GENERAL Licence Conditions e-doc Page 12 of 142

285 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 LO4254 DZS , The Darlington NGS-A Plant Survey, NK38-DOH Ontario Hydro layout drawing, Rev. 9 and NK38-DOH , Ontario Hydro layout drawing, Rev. 4, describe the exclusion zone, identifying the parcels of land that are not owned by OPG and provide information on land use. These documents shall be revised to reflect any transfer of land within the exclusion zone to non-licensee ownership. The Plant Survey also appears in the Darlington NGS Safety Report, Part 1 Plant/Site Description, NK38-SR , which provides added details on the plant and site description. Recommendations and Guidance: Not applicable to this LC. GENERAL Licence Conditions e-doc Page 13 of 142

286 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 G.4 Office for CNSC On-Site Inspectors Licence Condition G.4: The licensee shall provide, at the nuclear facility and at no expense to the Commission, suitable office space for employees of the Commission who customarily carry out their functions on the premises of that nuclear facility (on-site Commission staff). Preamble: CNSC staff require suitable office space and equipment at the nuclear facility in order to satisfactorily carry out its regulatory activities. Compliance Verification Criteria: Any changes of accommodation or equipment shall be made based on discussion, and subsequent agreement, between the CNSC and the licensee. Suitable office space is office space that is separated from the remainder of the building in which it is located by walls or other suitable structures. Recommendations and Guidance: Not applicable to this LC. GENERAL Licence Conditions e-doc Page 14 of 142

287 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 G.5 Financial Guarantees Licence Condition G.5: The licensee shall maintain a financial guarantee for decommissioning that is acceptable to the Commission. Preamble: The General Nuclear Safety and Control Regulations requires that a licence application contain a description of any proposed financial guarantee relating to the activity to be licensed. The licensee is responsible for all costs of decommissioning and all such costs are included in the decommissioning cost estimates and are covered by licensee s consolidated financial guarantee for decommissioning. OPG conducted a complete decommissioning cost estimate review as part of the 5-year Ontario Nuclear Funds Agreement reference plan update cycle. Gaps identified between the preliminary decommissioning plan and CSA standard N294 Decommissioning of Facilities Containing Nuclear Substances that could impact on the decommissioning costs, were addressed by OPG in the cost estimate review. The financial guarantee is composed of the following components: segregated funds established pursuant to the Ontario Nuclear Funds Agreement (ONFA) between the licensee and the Province of Ontario as amended and effective March 1, 2010; trust fund for the management of used fuel established pursuant to the Nuclear Fuel Waste Act; and Provincial Guarantee pursuant to the Provincial Guarantee Agreement between the CNSC and the Province of Ontario, which was amended March 1, Compliance Verification Criteria: The financial guarantee for decommissioning the nuclear facility shall be reviewed and revised by the licensee every five years or when the Commission requires or following a revision of the preliminary decommissioning plan that significantly impacts the financial guarantee. The next full update to the 5 year reference plan for financial guarantee purposes is expected in The licensee shall submit annually to the Commission a written report confirming that the financial guarantees for decommissioning costs remain valid and in effect and sufficient to meet the decommissioning needs. The licensee shall submit this report by the end of February of each year, or at any time as the Commission may request. GENERAL Licence Conditions e-doc Page 15 of 142

288 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Relevant documents that require version control: Document Title Document # Revision # Effective Date CNSC Financial Security and ONFA Access Agreement and Provincial Guarantee Agreement, effective January 1, 2013 N/A Amended Recommendations and Guidance: CNSC guidance document G-206 Financial Guarantees for the Decommissioning of Licensed Activities, provides guidance when reviewing the financial guarantees for decommissioning. GENERAL Licence Conditions e-doc Page 16 of 142

289 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 G.6 Public Information and Disclosure Licence Condition G.6: The licensee shall implement and maintain a public information and disclosure program. Preamble: A public information and disclosure program (PIDP) is a regulatory requirement for licence applicants and licensees under the Class I Nuclear Facilities Regulations, which requires that a licence application contain a program to inform persons living in the vicinity of the site of the general nature and characteristics of the anticipated effects of the licensed activity on the environment, health and safety of persons. Compliance Verification Criteria: The licensee shall implement and maintain a program for public information and disclosure. This program shall comply with the requirements set out in CNSC regulatory document RD/GD-99.3 Public Information and Disclosure. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CNSC Public Information and Disclosure RD/GD Where the public has indicated an interest to know, the PIDP shall include a commitment to and disclosure protocol for ongoing, timely communication of information related to the licensed facility during the course of the licensing period. The following documents require written notification of change: Document Title Document # Prior Notification? Nuclear Public Information Disclosure N-STD-AS-0013 No Recommendations and Guidance: It is recommended that OPG submit annually to CNSC staff a report summarizing the events and developments involving OPGs nuclear facilities. GENERAL Licence Conditions e-doc Page 17 of 142

290 LCH-DNGS-R000 Effective Date: Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA MANAGEMENT SYSTEM The safety and control area Management System covers the framework that establishes the processes and programs required to ensure an organization achieves its safety objectives, continuously monitors its performance against these objectives, and fosters a healthy safety culture. Performance Objective(s) There is an effective management system that integrates provisions to address all regulatory and other requirements to enable the licensee to achieve its safety objectives, continuously monitor its performance against those objectives and maintain a healthy safety culture. 1.1 Management System Requirements Licence Condition 1.1: The licensee shall implement and maintain a management system. Preamble: The General Nuclear Safety and Control Regulations require that a licence application contain information related to the organizational management structure and responsibilities. The Class I Nuclear Facilities Regulations require that a licence application contain the proposed quality assurance program. Safe and reliable operation requires a commitment and adherence to a set of management system principles and, consistent with those principles, the establishment and implementation of processes that achieve the expected results. CSA standard N286 contains the requirements for a management system throughout the life cycle of a nuclear power plant and extends to all safety and control areas. The management system must satisfy the requirements set out in the, regulations made pursuant to the Nuclear Safety and Control Act, the licence and the measures necessary to ensure that safety is of paramount consideration in implementation of the management system. An adequately established and implemented management system provides CNSC staff confidence and evidence that the licensing basis remains valid. Compliance Verification Criteria: The licensee shall implement and maintain a management system. This management system shall comply with the requirements set out in CSA N286 Management System Requirements for Nuclear Facilities. The licensee shall ensure that the management system meets the requirements of N286 at all times throughout operation, refurbishment and return to service for all units. MANAGEMENT SYSTEM Licence Conditions e-doc Page 18 of 142

291 LCH-DNGS-R000 Effective Date: Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CSA Management System Requirements for Nuclear Facilities N Management System The management and operation of OPG nuclear facilities is defined by the programs and associated nuclear governing documents as described in N-CHAR-AS-0002, Nuclear Management System. The management system documentation shall contain sufficient detail to demonstrate that the described processes stated directly or by reference, provides the needed direction to comply with the conditions stated in the PROL and the criteria herein. Organization The licensee shall document the organizational structure for safe and reliable conduct of licensed activities and shall include all positions with responsibilities for the management and control of the licensed activity. OPG s organization is defined by N-STD-AS-0020 Nuclear Organization Standard, OPG s role documents for certified positions and OPG correspondence Persons Authorized to Act on Behalf of OPG in Dealings with the CNSC. Safety Culture Licensees shall ensure that the management of the organization supports the safe conduct of nuclear activities. The licensee shall ensure that sound nuclear safety is the overriding priority in all activities performed in support of the nuclear facilities and has clear priority over schedule, cost and production. The framework, guiding principles and accountabilities for nuclear safety oversight is governed by N-STD-AS-0023 Nuclear Safety Oversight, which summarizes the licensee s internal and external processes used for oversight and assessment. The requirements for such oversight are described in N286. The licensee s approach to worker safety is governed by OPG-PROG-0010, Safety Management System Program, which defines the overall process for managing safety and the responsibilities of the parties, specifically at the corporate level. A safety culture self-assessment methodology is developed following a continuous improvement process, which is governed by N-PROC-AS-0077 Nuclear Safety Culture Assessment. Business Continuity Business Continuity is addressed in N-GUID , Guideline for Maintaining Staff in Key Positions When Normal Station Access is Impeded, which provides a strategic plan for safe shutdown and follow-up activities in the event of labour disruptions, and N-PROG-RA-0018 Nuclear Pandemic Plan. These are also key documents in support of the minimum shift complement (see section 2.2). MANAGEMENT SYSTEM Licence Conditions e-doc Page 19 of 142

292 LCH-DNGS-R000 Effective Date: Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The following documents require written notification of change: Document Title Document # Prior Notification? Management System Nuclear Management System N-CHAR-AS-0002 Yes Managed Systems N-PROG-AS-0001 No Records and Document Control N-PROG-AS-0006 No Project Management Program N-PROG-AS-0007 No Change Management N-STD-AS-0024 No Organization Nuclear Organization N-STD-AS-0020 No Organization Design Change OPG-PROC-0166 No Plant Management (including Safety Culture) Nuclear Safety Policy N-POL-0001 No Nuclear Safety Oversight N-STD-AS-0023 No Safety Management System Program OPG-PROG-0010 No Nuclear Safety Culture Assessment N-PROC-AS-0077 No Program Assessment /Independent Assessment N-PROG-RA-0010 No Guideline for Maintaining Staff in Key Positions N-GUID No When Normal Station Access is Impeded Nuclear Pandemic Plan N-PROG-RA-0018 No Items and Services Management OPG-PROG-0009 No Recommendations and Guidance: The management system should be used to promote and support a healthy safety culture. The CNSC recognizes the following characteristics that form the framework for a healthy safety culture: Safety is a clearly recognized value; Accountability for safety is clear; Safety is integrated into all activities; A safety leadership process exists, and Safety culture is learning-driven. MANAGEMENT SYSTEM Licence Conditions e-doc Page 20 of 142

293 LCH-DNGS-R000 Effective Date: Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The licensee should conduct self-assessments of safety culture periodically. The assessment method should be documented and the framework should include links to the safety culture characteristics listed above. CNSC staff encourage OPG senior management to continue to foster a healthy safety culture to ensure that OPG staff understand the influence that safety culture has over all other organizational processes and its role in maintaining and improving safety performance. MANAGEMENT SYSTEM Licence Conditions e-doc Page 21 of 142

294 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA HUMAN PERFORMANCE MANAGEMENT The safety and control area Human Performance Management covers activities that enable effective human performance through the development and implementation of processes that ensure a sufficient number of licensee personnel are in all relevant job areas and have the necessary knowledge, skills, procedures and tools in place to safely carry out their duties. Performance Objective(s) The licensee has an integrated approach to managing human performance so that all workers have the necessary knowledge, skills and attributes, are fit for duty, are sufficient in number, and are supported to carry out their work tasks safely. 2.1 Human Performance Program Licence Condition 2.1: The licensee shall implement and maintain a human performance program. Preamble: Human performance relates to reducing the likelihood of human error in work activities. It refers to the outcome of human behaviour, functions and actions in a specified environment, reflecting the ability of workers and management to meet the system s defined performance under the conditions in which the system will be employed. Human Factors are factors that influence human performance as it relates to the safety of a nuclear facility or activity over all design and operations phases. These factors may include the characteristics of the person, task, equipment, organization, environment, and training. The consideration of human factors in issues such as interface design, training, procedures, and organization and job design may affect the reliability of humans performing tasks under various conditions. The General Nuclear Safety and Control Regulations require different elements related to the human performance program. CNSC Regulatory Policy P-119 Policy on Human Factors, describes how the CNSC will take human factors into account during its licensing, compliance and standards-development activities. For clarification, CNSC regulatory oversight related to hours of work is for the purpose of nuclear safety not for the purpose of worker protection. Worker protection is covered under the SCA Conventional Health and Safety (LC 8.1). HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 22 of 142

295 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Compliance Verification Criteria: In order to establish, maintain and improve human performance, the licensee shall monitor and control the work hours and shift schedules of nuclear workers, in accordance with governance N-PROC-HR-0002 Limits of Hours of Work. All workers performing safety related tasks or working on safety-related systems are subject to these hours of work and scheduling limits. The licensee shall also monitor and control the fitness for duty of its workers at all times by implementing and maintaining their Continuous Behaviour Observation Program which covers aspect related to fitness for duty. Specific fitness for duty requirements for certified personnel can be found in CNSC regulatory document RD-204, and those for nuclear security officers can be found in CNSC regulatory document RD-363. See LC 2.3 for version control of CNSC RD-204 and LC 12.1 for version control of CNSC RD-363. The following documents require written notification of change: Document Title Document # Prior Notification? Limits of Hours of Work N-PROC-HR-0002 Yes Human Performance N-PROG-AS-0002 No Procedural Usage and Adherence N-STD-AS-0002 No Communications N-STD-OP-0002 No Self-Check N-STD-OP-0004 No Conservative Decision Making N-STD-OP-0012 No Second Party Verification N-STD-RA-0014 No Pre-Job Briefing and Post-Job Debriefing N-PROC-OP-0005 No Continuous Behaviour Observation Program (CBOP) Participants Materials Workbook Components Leadership and Management Training and Qualification Description N-CMT N-TQD No No Recommendations and Guidance: Licensees should implement a program that continuously monitors human performance, takes steps to identify human performance weaknesses, improves human performance, and reduces the likelihood of human performance related causes and root causes of nuclear safety events. HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 23 of 142

296 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The Human Performance Program should address and integrate the range of human factors that influence human performance, which include, but may not be limited to the following: The provision of qualified staff o Certification and Training o Staffing o Minimum Shift Complement o Fitness for duty Hours of Work Fatigue Management The reduction of human error o HF in Design o Procedures Development o Procedural Compliance o Work protection and Work Permit Systems o Shift Turnover o Pre and Post Job Briefings o Safe work strategies/practices Organizational support for safe work activities o Human Actions in Safety Analysis o Organizational Performance and Safety culture The continuous improvement of human performance Additional guidance is provided in G-276 Human Factors Engineering Program Plans, and G-278 Human Factors Verification and Validation Plans. When the CNSC regulatory document on managing worker fatigue and hours of work is published, licensees are to take it into consideration when implementing their human performance program. Until this document is published, the licensee should continue to address the current expectations regarding fitness for duty of workers and hours of work limitations. HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 24 of 142

297 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Minimum Shift Complement Licence Condition 2.2: The licensee shall implement and maintain the minimum shift complement and control room staffing for the nuclear facility. Preamble: The General Nuclear Safety and Control Regulations, require that the licensee ensure the presence of a sufficient number of qualified workers at the nuclear facility. The minimum shift complement specifies the numbers of qualified staff that are required to operate and maintain unit(s) safely under all operating states including normal operations, anticipated operational occurrences, design basis accidents and emergencies. This licence condition ensures the presence of a sufficient number of qualified workers who must be present at all times to ensure safe operation of the nuclear facility, and to ensure adequate emergency response capability. Compliance Verification Criteria: Minimum Shift Complement The licensee s minimum shift complement (MSC) documentation, D-PROC-OP-0009, Station Shift Complement, describes the minimum number of workers with specific qualifications required for the safe operation of the nuclear facilities under all operating states and the measures in place to mitigate the impact of any MSC violations until minimum complement requirements are restored. The licensee shall operate the nuclear facility in accordance with these documents and shall monitor and keep records of each shift s complement. The licensee shall provide a rolling five year profile of certified operators on an annual basis. The MSC is considered part of the licensing basis. Changes to the MSC are subject to LC G.1. The following tables summarize the facility s MSC. These tables are taken from D-PROC-OP In the event of a discrepancy between these tables below and the licensee documentation upon which they are based, the licensee documentation shall be considered the authoritative source (assuming that the licensee has followed its own change control process). HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 25 of 142

298 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Shift Complement by Work Group (Normal Operation) Operations Work Group Minimum Complement Position Minimum Complement # Scheduled Complement # Authorized Nuclear Operators (ANO) 6 7 Unit 0 Control Room Operators (CRO) 2 2 Field Shift Operating Supervisor (FSOS) 1 1 Unit 0 Nuclear Operators 3 3 Nuclear Operators (NO) (Units 1 4) Shift Advisor Technical Support (SATS) 1 1 Shift Manager (SM) 1 1 Control Room Shift Supervisor (CRSS) 1 1 Supervising Nuclear Operators (SNO) 4 4 Unit 0 Field Supervising Nuclear Operator 1 1 Operations Sub-Total HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 26 of 142

299 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Other Work Groups Minimum Complement Work Group Position Minimum Complement # Scheduled Complement # TRF Control Room SNO 1 1 TRF Major Panel Operator (MPO) 1 1 TRF Nuclear Operators 2 (1) 2 (1) Lab Chemical Technician 2 2 FP Emergency Response Maintainer 6 6 (ERM) FP Shift Emergency Response 1 1 Manager (SERM) Maint FLM Control 1 1 Maint Shift Control Technician (3) (4) 2 [1] 3 [2] Maint Mechanical Maintainer (3) (4) 2 [1] 3 [2] Maint FH Mech. Maintainer/Control 1 [0] 2 [0] Technician (4) Maint FLM-FH (4) 1 [0] 1 [0] Supply Chain Stock-keeper 2 2 Security Nuclear Security Officer (NSO) NS (5) NS (5) Number of FH Trolleys Operated (6) FH Field Shift Operating Supervisor FH Supervising Nuclear Operator (2) FH Major Panel Operator (2) FH Nuclear Operator (2) Other Work Groups Sub-Total (4) 24 [20] 26 [22] All Work Groups (including Operations) Total (4) 54 [50] 56 [52] 27 [23] 57 [53] 28 [24] 58 [54] 28 [23] 61 [56] 30 [25] 63 [58] 31 [26] 64 [59] 33 [28] 66 [61] (1) TRF Nuclear Operators minimum and scheduled complements are reduced to 1 during TRF outage (i.e. hydrogen, deuterium and tritium inventories have been removed from the TRF process). Default complement is 2 (TRF in service). (2) The workgroup minimum complement for Fuel Handling is one (1) SNO and one (1) Nuclear Operator, when no trolleys are being operated. However, the station strives to staff to allow for one trolley to be operated (1 SNO, 1 MPO and 2 NO s). (3) One MM and one SCT have Design Basis Accident response duties (see N-INS for details on credited MM/CM response to Loss of Instrument Air event and PHT LRV Fail Open event). (4) Night shift complement, where different from days, shown in [ ]. (5) NS = not specified in this document security protected. See Site Security Report. (6) For the purposes of MCCP alarm limits, complement numbers for 1 trolley operation are used. HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 27 of 142

300 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Shift Complement for Emergency Response Organization (ERO) ERO Requirements (for emergency conditions) Position Work Group (1) Minimum Complement # Scheduled Complement # Authorized Nuclear Operators (ANO) Operations 6 7 Unit 0 Control Room Operator (CRO) Operations 2 2 Chemical Technician Chemistry 2 2 Crew Accounting Supervisor Fuel Handling 1 1 Emergency MCRA (CSP Monitor) Operations 1 1 Emergency Response Maintainer Fire Protection 6 6 (ERM) Emergency TRF Operator TRF 1 1 Emergency Unit Operator (Units 1 4) Operations 5 5 EPGQO - Unit 0 Nuclear Operations 3 3 Operators/FSNO (2) In-Plant Survey Team Operations 2 3 In-Plant Coordinator Operations 1 1 Off-Site Survey Team Captain (3) Maintenance 1 [0] 1 [0] Off-Site Survey Team (3) Maintenance 2 [0] 2 [0] Out-of-Plant Coordinator (3) Maintenance 1 [0] 1 [0] Emergency Shift Assistant (ESA) Operations 1 1 Shift Emergency Response Fire Protection 1 1 Coordinator Shift Manager (4) Operations 1 1 Control Room Shift Supervisor Operations 1 1 (CRSS) Shift Resource Coordinator Maintenance 1 1 Stores Stock-keeper Supply Chain 1 2 TRF SNO TRF 1 1 TRF Major Panel Operator TRF 1 1 Supervising Nuclear Operator Operations 4 4 (Units 1 4) Mechanical Maintainer (7) DBA Maintenance 1 1 action Shift Control Technician (7) DBA Maintenance 1 1 action Security (5) Security NS (6) NS (6) Total 48 [44] 51 [47] HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 28 of 142

301 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 (1) To ensure the assignment of ERO roles is managed, the assignment of staff by each Work Group is identified in the above table. Nevertheless, these positions may be filled by staff from any work group provided they are qualified and incremental to the roles that are Work Group specific. (2) The Unit 0 complement requirements for a Main Steam Line Break or a Common Mode Event are one (1) EPGQO and two (2) Unit 0 NO s. In order to facilitate tracking of the EPG Qualified Operators and the Unit 0 NO s together in the Minimum Complement Coordination Program, the station shall continue to ensure that all Unit 0 NO s are EPG qualified. They are to be available to restore EPS/ESW to all affected units within 30 minutes. (3) Day shift only position (12 hours/day, 7 days/week). Night shift complement, where different from days, shown in [ ]. (4) The Shift Manager executes both the emergency Shift Manager role and the Emergency Response Manager (ERM) role until such time as the Site Management Center is declared operational. (5) Security shall provide two drivers for the Off-Site Survey Team. (6) NS = not specified in this document security protected. See Site Security Report. (7) One MM and one SCT have Design Basis Accident response duties (see N-INS for details on credited MM/CM response to Loss of Instrument Air event and PHT LRV Fail Open event). Control Room Staffing The licensee shall comply with the minimum certified personnel requirements for the nuclear facility and for the main control room. The certified positions are listed in LC 2.3. In conjunction with the minimum shift complement for the facility, the licensee shall maintain adequate control room staffing. For the following certified positions, the licensee shall have the following certified personnel at all times: (ii) (iii) (iv) (i) in the nuclear facility, at least one certified shift manager, one certified control room shift supervisor, six certified authorized nuclear operators, and two certified unit 0 control room operators. in the main control room, at least four certified authorized nuclear operators. in the main control room, at least one certified unit 0 control room operator, except for brief absences to determine the origin of fire alarms. in the main control room, a certified authorized nuclear operator in direct attendance at the control panels of each reactor unit. The minimum certified personnel requirements for the main control room that this condition imposes do not apply where this minimum cannot be met due to emergency conditions that could cause an unwarranted hazard to personnel in the main control room, in which case the licensee shall place the reactor(s) in a safe shutdown state and the nuclear facility in a safe condition. In direct attendance means the certified person must physically be in the direct line of sight and in close proximity to the control room panels to continuously monitor, recognize and differentiate panel displays, alarms and indications. A certified person shall be in a position to rapidly respond, in accordance with his/her role, to changing unit conditions, at all times, as described in OPG document, D-PROC-OP-0009, Station Shift Complement. HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 29 of 142

302 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The following documents require written notification of change: Document Title Document # Prior Notification? Station Shift Complement D-PROC-OP-0009 Yes Duty Crew Minimum Complement Assurance D-INS Yes Recommendations and Guidance: The adequacy of the minimum shift complement should be determined through a systematic analysis of the most resource-intensive conditions under all operating states, design basis accidents, and emergencies. The results of the analysis should then be validated to determine the degree to which the minimum shift complement facilitates the achievement of the overall safety goals. Recommendations and guidance for the development and validation of the minimum shift complement are provided in the following CNSC regulatory guidance documents: G-323 Ensuring the Presence of Sufficient Qualified Staff at Class I Nuclear Facilities Minimum Staff Complement describes the CNSC recommended approach for defining the minimum shift complement and sets out the key factors that CNSC staff will take into account when assessing whether the licensee has made, or the applicant will make, adequate provision for ensuring the presence of a sufficient number of qualified staff. G-278 Human Factors Verification and Validation Plans describes the elements of effective human factors verification and validation planning, including a suggested format for documenting these elements. HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 30 of 142

303 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Training, Certification and Examination Program Licence Condition 2.3: The licensee shall implement and maintain training programs for workers. Certification training, examinations and tests for positions requiring certified personnel shall be conducted in accordance with CNSC regulatory document RD-204 CERTIFICATION OF PERSONS WORKING AT NUCLEAR POWER PLANTS. Persons appointed to the following positions require certification: (i) (ii) (iii) (iv) (v) Responsible Health Physicist; Shift Manager; Control Room Shift Supervisor; Authorized Nuclear Operator; and Unit 0 Control Room Operator. Preamble: The General Nuclear Safety and Control Regulations require the licensee to train the workers to carry on the licensed activity in accordance with the Nuclear Safety and Control Act, the associated regulations and the licence. The Class I Nuclear Facilities Regulations requires that: a licence application to operate a Class I nuclear facility contain the proposed responsibilities of and qualification requirements and training program for workers, including the procedures for the requalification of workers; and the licensee submits the necessary information for certification or renewal of certification of the applicable positions. The licensee s documentation describes the authority and responsibilities of certified positions. This LC provides the regulatory requirements for the development and implementation of training programs for workers, and for the initial certification, the renewal of certification and training of persons for the positions listed in the LC. It also provides the requirements regarding the program and processes necessary to support the certification and training of persons at the nuclear facility. As defined by the General Nuclear Safety and Control Regulations, workers include contractors and temporary employees who perform work that is referred to in the licence. Training requirements apply equally to these types of workers as to the licensees own employees. HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 31 of 142

304 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Compliance Verification Criteria: The licensee shall implement and maintain programs for training which includes certification training and examinations. These programs shall comply with the requirements set out in CNSC regulatory document RD-204 Certification of Persons Working at Nuclear Power Plants. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CNSC Certification of Persons Working at Nuclear Power Plants RD Note: Paragraph of RD-204 will be amended during the next regulatory document revision to align with the written requalification test requirements in CNSC document, Requirements for the Requalification Testing of Certified Shift Personnel at Nuclear Power Plants, Revision 2. In the interim, for RD-204 paragraph , CNSC staff will apply the following compliance criteria: The person must have successfully completed written requalification tests equivalent in number to those referred to in the NPP licence that the person would have had to take during the period of absence, if the person had continued to work in the position. During refurbishment of the nuclear facility, the refresher training specified in subsection 32.1 of RD-204 shall be modified as required to account for the fact that certified persons will not be able to perform most of the operations and maneuvers that are regularly performed during normal operation of the facility. The licensee shall implement and maintain an overall training policy, including initial and continuing training sub-programs for all workers. The program shall be based on long-term qualifications and competencies required for job performance, as well as training goals that acknowledge the critical role of safety. The licensee shall conduct a gap analysis and prepare an implementation plan in order to meet the requirements of REGDOC by March 31, Training Programs for All Workers The licensee shall ensure that all workers are qualified to perform the duties and tasks required of their position. All training programs related to workers in positions where the consequence of human error poses a risk to the environment, the health and safety of persons, or to the security of the nuclear facilities and licensed activities, are evaluated against the criteria for a systematic approach to training (SAT). Training and Certification for Staff Appointed to Certified Positions The Senior Health Physicist referred to in RD-204 is equivalent to the Responsible Health Physicist position at Darlington NGS. The Plant Shift Supervisor at a multi-unit plant referred to in RD-204 is equivalent to the Shift Manager position at Darlington NGS. HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 32 of 142

305 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The Reactor Operator referred to in RD-204 is equivalent to the Authorized Nuclear Operator position at Darlington NGS. The licensee shall ensure persons appointed to the position of Responsible Health Physicist, Shift Manager, Authorized Nuclear Operator, Control Room Shift Supervisor, or Unit 0 Control Room Operator, at the nuclear facility hold a certification for the position to which they have been appointed, in accordance with the requirements of the Class I Nuclear Facilities Regulations. Certified personnel shall carry out their authorities and responsibilities as per their respective role documents. Any person who holds a certification as Shift Manager shall also be qualified to act in the position of Control Room Shift Supervisor. The Control Room Shift Supervisor position may also be filled by a certified Shift Manager. When applying for certification or renewal of certification of a person for the positions listed, the licensee shall submit the information required pursuant to section 9 of Class I Nuclear Facilities Regulations and shall confirm that the person meets the relevant certification requirements applicable to that position, specified in RD-204. The authorities and responsibilities of the certified positions listed above are considered safety and control measures. Any changes to them will be reviewed by CNSC staff to confirm they remain within the licensing basis, in consultation with the designated officer to certify and decertify persons referred to in sections 9 and 12 of the Class I Nuclear Facilities Regulations and the Director of the Personnel Certification Division. The general criteria for reviewing changes include those described in Appendix A.4. Any changes outside the licensing basis would require prior written approval of the Commission, per LC G.1. Until further notification, the incumbent in paragraphs and 26.7 of RD-204 may either be a certified: a) Control Room Shift Supervisor (CRSS) who is working in the certified position of CRSS (duty CRSS), or b) Shift Manager (SM) who is assigned to work in the certified position of CRSS (duty CRSS) and must be qualified to evaluate the performance of the candidate as per section 6.0 of RD-204. Until the revision of RD-204, the procedures specified in section 6.0 shall include the qualification requirements specifying the prerequisite knowledge and level of experience required for the certified incumbent to effectively monitor and evaluate candidate knowledge and performance in that position. HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 33 of 142

306 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Conduct of Examinations and Tests for Certified Personnel Currently, the following three CNSC internal documents contain the requirements for administering the certification examinations and requalification tests required by RD-204: CNSC-EG1, Rev.0: Requirements and Guidelines for Written and Oral Certification Examinations for Shift Personnel at Nuclear Power Plants, CNSC-EG2, Rev.0: Requirements and Guidelines for Simulator-based Certification Examinations for Shift Personnel at Nuclear Power Plants, and CNSC document: Requirements for the Requalification Testing of Certified Shift Personnel at Nuclear Power Plants, Revision 2. The following documents require written notification of change: Document Title Document # Prior Notification? Training N-PROG-TR-0005 No Systematic Approach to Training N-PROC-TR-0008 No Written and Oral Initial Certification Examination for Shift Personnel Simulator-Based Initial Certification Examinations for Shift Personnel Requalification Testing of Certified Shift Personnel N-INS N-INS N-INS Responsible Health Physicist N-MAN CNSC-031 Yes Shift Manager, Darlington Nuclear N-MAN CNSC-006 Yes Authorized Nuclear Operators N-MAN CNSC-010 Yes Control Room Shift Supervisor N-MAN CNSC-008 Yes Unit 0 Control Room Operator N-MAN CNSC-025 Yes No No No Recommendations and Guidance: The licensee should refer to CNSC regulatory document REGDOC Personnel Training, for guidance on training systems used for training programs. With regard to refurbishment activities planned for Darlington NGS, it is recommended that OPG start preparing, in advance, for the additional future training-related requirements, including continuing training for personnel requiring certification or maintenance thereof. HUMAN PERFORMANCE MANAGEMENT Licence Conditions e-doc Page 34 of 142

307 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA OPERATING PERFORMANCE The safety and control area Operating Performance includes an overall review of the conduct of the licensed activities and the activities that enable effective performance. Performance Objective(s) Plant operation is safe and secure, with adequate regard for health, safety, security, radiation and environmental protection, and international obligations. 3.1 Operations Program Licence Condition 3.1: The licensee shall implement and maintain an operations program, which includes a set of operating limits. Preamble: The Class I Nuclear Facilities Regulations require that a licence application contain the proposed measures, policies, methods and procedures for operating and maintaining the nuclear facility. The operations program establishes safe operating practices within the nuclear facility, under all operating conditions (routine and non-routine), and provides the ability to ensure the facility is operated in such a manner that: applicable regulations, licence conditions, and standards are followed; the requirements of the Operating Policies and Principles (OP&Ps) are implemented; and limits are established in accordance with a Safe Operating Envelope (SOE) are not exceeded. The OP&Ps: define the operating rules consistent with the safety analyses and other licensing support documentation within which the facility will be operated, maintained and modified, all of which should ensure nuclear safety; specify the authorities of the facility staff positions to make decisions within the defined boundaries; and identify and differentiate between actions where discretion may be applied and where jurisdictional authorization is required. The SOE is defined in CSA N as "the set of limits and conditions within which the nuclear generating station must be operated to ensure compliance with the safety analysis upon which reactor operation is licensed and which can be monitored by or on behalf of the operator and can be controlled by the operator." OPERATING PERFORMANCE Licence Conditions e-doc Page 35 of 142

308 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The SOE consists of a number of parameters: Safe operating limits; Conditions of operability; Actions and action times; and Surveillances. The safe operating limits are derived from the safety analysis limits. The SOE parameters are currently identified in various station documents, including Operational Safety Requirements (OSR), Instrument Uncertainty Calculations (IUC), the Abnormal Incidents Manual and surveillance documentation. Power limit specifications set limits on parameters that affect reactor core, channel, and fuel bundle powers, to ensure compliance with limits imposed by the Design and Safety Analysis assumptions. The magnitude of the initial reactor power, channel powers and bundle powers in the reactor prior to an accident are the fundamental parameters governing whether fuel or fuel channel failure will occur during anticipated transients and the postulated Design Basis Accidents (DBA). Heat sinks are combination of systems or portions of systems that contribute to conveying heat to the atmosphere or body of water, known as the ultimate heat sink (UHS). The goal of the heat sink systems is to provide heat removal from the heat source (reactor core, pump heat) to the UHS, where the residual heat can always be transferred. The outage heat sink management defines the strategy to ensure the plant is safe throughout the outage duration when the normal (at high power) heat sinks may not be available. The outage is considered to be terminated when the normal heat sinks are re-established as part of the plan to proceed to sustained high power operation. Accident management provisions are to ensure effective defences against radiological hazards resulting from DBAs and Beyond Design Basis Accidents (BDBAs). The fundamental premise underlying accident management is that the licensee has established and maintained overlapping measures for accident prevention and, should an accident occur, is able to: Prevent the escalation of the accident; Mitigate the consequences of the accident; and Achieve a long-term safe stable state after the accident. Compliance Verification Criteria: The licensee shall implement and maintain operations programs. These programs shall consist of, at a minimum, a safe operating envelope, a set of operating policies and principles, and accident management procedures and/or guides for design basis and beyond design basis accidents, including overall strategies for recovery. These programs shall comply with the requirements set out in: CNSC regulatory document REGDOC Accident management: Severe accident management programs for nuclear reactors; and CSA standard N Requirements for the safe operating envelope for nuclear power plants. OPERATING PERFORMANCE Licence Conditions e-doc Page 36 of 142

309 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CSA CNSC Requirements for the safe operating envelope for nuclear power plants Accident management: Severe accident management programs for nuclear reactors N REGDOC Operation in states not considered in, or not bounded by, the safety analyses is not permitted. Aspects of operations or procedures that impact the limits documented in the operating policies and principles or safe operating envelope are considered safety and control measures and therefore subject to LC G.1. Power Limits In accordance with the Safety Analysis (refer to LC 4.1) and the Licensing Basis (refer to LC G.1), during operation: The total power generated in any one fuel bundle shall not exceed 950 kilowatts. The total power generated in any fuel channel shall not exceed 7200 kilowatts under steady-state operating conditions. The total thermal power from the reactor fuel shall not exceed 2776 megawatts under steady-state operating conditions. The reactor, channel and bundle power limits are considered safety and control measures. Any changes to them, or planned operations outside of these limits are subject to LC G.1. Operating Policies and Principles The operating policies and principles shall provide direction for the safe operation and as a minimum, reflect the safety analyses that have been previously submitted to the Commission. The licensee shall, at all times, maintain and operate the nuclear facility within the limits of the OP&Ps and SOE. If operation outside the operating boundaries as defined in the OP&Ps and SOE is discovered, the licensee shall take immediate action to return the facility within the boundaries of safety analyses, in a safe manner. Safe Operating Envelope The licensee s safe operating limits, conditions and surveillance requirements, as well as their bases are documented in station and system specific OSR documents along with any associated IUCs. The limits and conditions defined in the OSRs, including any requirements for corrective or mitigating actions and action times, are specified in the applicable operations and maintenance tests, procedures and processes to ensure compliance with the SOE. OPERATING PERFORMANCE Licence Conditions e-doc Page 37 of 142

310 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The licensee shall maintain a set of OSRs and IUCs that define the limits and conditions of the safe operating envelope. The SOE is considered part of the licensing basis. Changes to the SOE documentation (OSRs and IUCs) are subject to LC G.1. Changes that may reduce safety margins require Commission approval prior to implementation. Accident Management The licensee shall implement and maintain operational procedures for operation in all states analyzed in the design basis, including abnormal and emergency states. The licensee s operational procedures ensure that the operation of the facility can be returned to a safe and controlled state should operation deviate from normal operation. The licensee shall ensure all abnormal operational scenarios analyzed in the design basis are accounted for in the operational procedures with the purpose of mitigating situations that may arise which cause a deviation from the expected state. These documents are conceived to return the plant to a safe and controlled state and to prevent the further escalation of the abnormal incident into a more serious deviation. In addition to the operational guidance for abnormal and emergency states, the licensee shall implement and maintain a severe accident management program to address residual risks posed by severe accidents. The licensee shall also ensure clear instruction is provided directing operations to use an appropriate set of severe accident management guidelines (SAMGs), if a severe accident is detected. Incorporating lessons learned from world events, OPG has issued a series of emergency operating procedures, the Emergency Mitigating Equipment Guidelines (EMEGs). EMEGS were developed to enable the use of portable diesel pumps and generator to provide coolant inventory make up (to steam generators, moderator and heat transport systems), and electrical power to essential instrumentation. The EMEGs are initiated following a total loss of Class IV and Class III electrical power or a Seismic Event where both Emergency Power Generators fail and cannot be restored, with the intention of preventing a Fukushima type core damage event. The licensee shall ensure clear instruction is provided directing operations in abnormal scenarios to the appropriate set of procedures or guides. OPG has committed to complying with REGDOC 2.3.2, Accident Management: Severe accident management programs for nuclear reactors, and shall complete the transition to the 2013 version by January 1, Other Requirements All work related tasks shall be supported by procedures that are fit for purpose and are used appropriately to minimize the potential for human error. Additionally, the licensee shall maintain a set of technical basis documents describing the design basis for chemistry control. In addition to the documents listed in the table below, the licensee shall provide WN to CNSC staff prior to implementation, of any changes to any procedures that could potentially impact on the reactor, the channel or the bundle power limits. Changes that would impact these limits are subject to LC G.1. OPERATING PERFORMANCE Licence Conditions e-doc Page 38 of 142

311 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 In 2013, CNSC staff agreed to the implementation of Rod-based Guaranteed Shutdown State as a Guaranteed Shutdown State at DNGS (e-doc ). RBGSS is established through the application of physical barriers and procedural controls guaranteeing that the shut-off absorbers, control absorbers, and adjuster absorber rods remain in-core to ensure a sub-critical reactor status. In addition, to the inserted rods, a concentration of at least 3.3 ppm of Gadolinium Nitrate (Gd) is maintained in the moderator as a poison providing additional defence-in-depth. The licensee shall provide prior WN for changes to operations or procedures for the Rod-based Guaranteed Shutdown State. CNSC staff will use the criteria in Appendix A.4 and any other applicable criteria to confirm the changes remain within the licensing basis. Changes outside of the licensing basis will require prior written approval by the Commission, per LC 1.1. In 2013, OPG proposed a set of temporary trip set points for neutron overpower protection to account for ageing at DNGS. The proposed trip set points are intended for use while an update of the NOP analysis is prepared and shall be submitted to CNSC by February 1 st, The submission was accepted (e-doc ) with the following conditions: OPG shall provide an annual report summarizing the results of surveillance and monitoring for impact of ageing on minimum margin to dryout, based on actual plant configuration and data. If an NOP trip event occurs, OPG shall submit the associated fitness for service assessment to CNSC for acceptance prior to restart of the affected unit; and If the trip set points are adjusted before December 31 st, 2017; the adjustments shall be performed on the required NOP TSPs as defined by the methodology used in OPG s March 25 submission. The following documents require written notification of change: Document Title Document # Prior Notification? Darlington Nuclear Operating Policies and Principles NK38-OPP Yes Safe Operating Envelope N-STD-MP-0016 Yes Nuclear Operations N-PROG-OP-0001 No Heat Sink Management N-STD-OP-0025 No Nuclear Safety Configuration Management N-STD-OP-0024 No Conduct of Operations/Nuclear Operations N-PROG-OP-0001 No Chemistry N-PROG-OP-0004 No Conservative Decision-Making N-STD-OP-0012 No Operational Decision Making N-STD-OP-0036 No Beyond Design Basis Accident Management N-STD-MP-0019 No Operations Performance Monitoring N-STD-OP-0011 No OPERATING PERFORMANCE Licence Conditions e-doc Page 39 of 142

312 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document Title Document # Prior Notification? Operating Experience Process N-PROC-RA-0035 No Processing Station Conditions Records N-PROC-RA-0022 No Corrective Action N-PROG-RA-0003 No Response to Transients N-STD-OP-0017 No Reactor Safety Program N-PROG-MP-0014 No Reactivity Management N-STD-OP-0009 No Control of Fuelling Operations N-STD-OP-0021 No Recommendations and Guidance: The licensee should manage all outage heat sink work activities in accordance with CSA standard N Requirements for Heat Removal Capability During Outage of Nuclear Power Plants. Licensees are to take in consideration the October 2014 version of CNSC regulatory document REGDOC on accident management. OPERATING PERFORMANCE Licence Conditions e-doc Page 40 of 142

313 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Approval to restart after a serious process failure Licence Condition 3.2: The licensee shall not restart a reactor after a serious process failure without the prior written approval of the Commission, or the prior written consent of a person authorized by the Commission. Preamble: The definition of serious process failure and the associated reporting requirements are provided in REGDOC Compliance Verification Criteria: When an event is found to be a serious process failure or where the determination as to the cause and/or extent of condition has proved inconclusive (i.e. a serious process failure cannot be ruled out), a request for restart of the reactor shall be submitted in writing and approval to restart the reactor must be obtained from the CNSC. If there is sufficient assurance that the cause of the serious process failure has been resolved and it is now safe to return the facility to service, a CNSC authorized person has the authority to give the consent to the licensee to proceed with the restart of the reactor. The written request for restart of the reactor is to include the following information: description of the event; causes of the event; consequences and safety significance of the event; recovery plan including corrective actions, and fitness for service assessment on the systems/components impacted from the failure if applicable. This shall be completed prior to reactor restart; a statement regarding plant readiness to resume safe operation. This shall include any conditions that the licensee proposes to impose upon reactor restart and/or subsequent reactor operation to ensure safe operation of the nuclear facility; and extent of completion of the conditions mentioned in the statement regarding plant readiness to resume safe operation. General criteria for CNSC s review of these requests are provided in Appendix A.4. OPERATING PERFORMANCE Licence Conditions e-doc Page 41 of 142

314 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The following documents require written notification of change: Document Title Document # Prior Notification? Reactor Safety Program N-PROG-MP-0014 No Response to Transients N-STD-OP-0017 No Recommendations and Guidance: In addition to the requirements listed above, the written request to restart a reactor after a serious process failure should also include the following information: a statement specifying that an extent of condition has been completed; documentation and communication to licensee staff (including additional training, if necessary); and applicable historical Operating Experience (OPEX) review for comparable events. OPERATING PERFORMANCE Licence Conditions e-doc Page 42 of 142

315 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Reporting Requirements Licence Condition 3.3: The licensee shall notify and report in accordance with CNSC regulatory document REGDOC REPORTING REQUIREMENTS: NUCLEAR POWER PLANTS. Preamble: CNSC regulatory document REGDOC has comprehensive reporting requirements (scheduled and unscheduled) for operation of NPPs. It describes information that the CNSC needs to evaluate the performance of the facilities it regulates. This document is complementary to the reporting requirements in the Nuclear Safety and Control Act and the associated regulations. Compliance Verification Criteria: Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CNSC Reporting Requirements: Nuclear Power REGDOC Plants The following documents require written notification of change: Document Title Document # Prior Notification? Written Reporting to Regulatory Agencies N-PROC-RA-0005 No Preliminary Event Notifications N-PROC-RA-0020 No Recommendations and Guidance: To ensure consistency of reporting across the fleet of Canadian NPPs, CNSC staff have prepared a list (e-doc ) which provides additional clarification and interpretation of the requirements of REGDOC The list, which is expected to become a controlled CNSC document, was developed in consultation with industry and should be used as guidance, as appropriate. OPERATING PERFORMANCE Licence Conditions e-doc Page 43 of 142

316 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Periodic Safety Review Licence Condition 3.4: The licensee shall prepare and conduct a periodic safety review in support of its subsequent power reactor operating licence application. Preamble: In support of refurbishment activities and continued long term operation, OPG has conducted an Integrated Safety Review in accordance with RD-360 Life Extension of Nuclear Power Plants. An Integrated Safety Review (ISR) is a process which includes an assessment of the current state of the plant and plant performance to determine the extent to which the plant conforms to modern standards and practices, and to identify any factors that would limit safe long-term operation. The process starts with a comprehensive review of the facility and its operations and results in the production of an integrated implementation plan (IIP) which describes practical and reasonable modifications to be carried out by the licensee. The periodic safety review (PSR) process mirrors this approach and is repeated with a 10 year periodicity. OPG s PSR will be focused on ensuring that practical safety improvements, whether identified by condition assessments, operating experience or through revisions of applicable codes and standards, are implemented at Darlington NGS. The IIP will be updated on this same cycle to include new commitments aimed at the continued safe operation of Darlington NGS. Compliance Verification Criteria: The licensee shall conduct a PSR to confirm that the facility remains consistent with a set of modern codes and standards intended to demonstrate that the safety basis remains valid. The PSR shall be conducted in accordance with REGDOC Periodic Safety Reviews. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CNSC Periodic Safety Reviews REGDOC The contents and results of the PSR provide some of the information required for the subsequent licence application. To ensure that a consistent understanding of the scope of work is established and that work is not replicated for the subsequent licence application, OPG shall provide: the basis document for the PSR no later than five years prior to the expiry of this licence; the PSR itself (global assessment report and IIP) no later than two years prior to the expiry of this licence; and subsequent licence application no later than one year prior to the expiry of this licence. OPERATING PERFORMANCE Licence Conditions e-doc Page 44 of 142

317 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Recommendations and Guidance: CNSC is currently engaged in the development of a licence application guide for a power reactor operating licence. The document provides information that supplements and clarifies the basic requirements of the regulations to assist an applicant in providing a sufficient level of detail in the application. It will contain clearly separated references to CNSC REGDOCs and industry codes and standards that an applicant must comply with and those an applicant is recommended to address. Additionally, descriptions of the contents of the programs to be submitted are contained in this REGDOC. At the time of the subsequent OPG Darlington licence application, this document will be published and the application should address it to the extent practicable. OPERATING PERFORMANCE Licence Conditions e-doc Page 45 of 142

318 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA SAFETY ANALYSIS The safety and control area Safety Analysis covers maintenance of the safety analysis that supports the overall safety case for the facility. Safety analysis is a systematic evaluation of the potential hazards associated with the conduct of a proposed activity or facility and considers the effectiveness of preventative measures and strategies in reducing the effects of such hazards. Performance Objective(s) There is demonstration of the acceptability of the frequency and consequences of design-basis and beyond design basis events, and the ability of protective systems and emergency mitigating equipment to adequately control power, cool the fuel and contain or limit any radioactivity that could be released from the plant. 4.1 Safety Analysis Program Licence Condition 4.1: The licensee shall implement and maintain a safety analysis program. Preamble: The General Nuclear Safety and Control Regulations require that a licence application contain a description and the results of any analyses performed. The Class I Nuclear Facilities Regulations require, amongst other requirements, that a licence application contain a final safety analysis report, and additional supporting information. A deterministic safety analysis evaluates the NPP s responses to such events by using predetermined rules and assumptions (conservative or best-estimate methods). The objectives of the deterministic safety analysis are stated in REGDOC Probabilistic safety assessment (PSA) is a comprehensive and integrated assessment of the safety of the nuclear power plant that, by considering the initial plant state and the probability, progression, and consequences of equipment failures and operator response, derives numerical estimates of a consistent measure of the safety of the design. Such assessments are most useful in assessing the relative level of safety. The objectives of the probabilistic safety analysis are stated in REGDOC CSA standard N286.7 Quality Assurance of Analytical, Scientific and Design Computer Programs for Nuclear Power Plants provides the specific requirements related to the development, modification, maintenance and use of computer programs used in analytical, scientific and design applications. These requirements apply to the design, development, modification and use of computer programs that are used in analytical, scientific and design applications at nuclear power plants. SAFETY ANALYSIS Licence Conditions e-doc Page 46 of 142

319 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Compliance Verification Criteria: The licensee shall implement and maintain programs for the development and updates of safety analyses. These programs shall comply with the requirements set out in: CNSC regulatory document REGDOC Deterministic Safety Analysis; CNSC regulatory document REGDOC Probabilistic Safety Assessment (PSA) for Nuclear Power Plants; and CSA standard N286.7 Quality Assurance of Analytical, Scientific, and Design Computer Programs for Nuclear Power Plants. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CNSC Deterministic Safety Analysis REGDOC CNSC CSA Probabilistic Safety Assessment (PSA) for Nuclear Power Plants Quality Assurance of Analytical, Scientific, and Design Computer Programs for Nuclear Power Plants REGDOC N (Reaffirmed 2012) The licensee shall demonstrate compliance of computer programs used in analytical, scientific and design applications used to support the safe plant operation in accordance with N Deterministic Safety Analysis The licensee shall conduct and maintain a deterministic safety analysis as documented in the plant Final Safety Analysis Report. The deterministic safety analysis shall demonstrate that the radiological consequences of the postulated initiating events do not exceed the accident-dependent reference public dose limits in the following table: Class of Postulated Event Reference Dose Limit (most exposed member of the public) Thyroid Dose Whole Body Dose (msv) (msv) Class Class Class Class Class All new analysis will be performed in accordance with REGDOC SAFETY ANALYSIS Licence Conditions e-doc Page 47 of 142

320 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 REGDOC includes modern requirements associated to the lessons learned from the Fukushima nuclear events. OPG has developed an implementation plan for 2014 to 2017 while undertaking gap identification and prioritization in compliance with REGDOC During this licence period, OPG shall begin to upgrade the individual sections and appendices that form Part 3, Accident Analysis, of the Darlington Safety Report, in a staged manner. To support continued safe operation and the refurbishment project, OPG has a well-structured approach to identifying, prioritizing and updating analyses that will be upgraded beyond The implementation plan will be revised in 2017 to fully describe the second phase of implementation. Recognizing that full implementation of REGDOC may not be practicable or provide substantial safety benefit beyond the current safety case; a method of evaluating the significance of gaps (applying a graded approach) against REGDOC and their importance to safety shall be established and applied on an as-needed basis to determine if corrective actions are required. Criteria for implementation of REGDOC include the following elements: Assessment of the current safety analysis practices against REGDOC to identify gaps; Prioritization of the identified gaps using formal methods; Justification of non-conformances (e.g., full compliance with REGDOC is not practicable or does not provide a demonstrable safety benefit); and Development and execution of corrective action plans to address the important gaps. Additional Requirements CSA N293 contains specific requirements for deterministic analysis related to fire protection. CNSC staff review the fire safety assessment primarily to verify that the licensee employs appropriate assumptions, uses validated models, applies adequate scope, and demonstrates results that are within the design acceptance criteria. See LC 10.2 for version control of CSA N293. Probabilistic Safety Assessment The licensee shall complete the transition to compliance with REGDOC over this licence period. The licensee shall provide the subsequent updated PSA within five years of 2015 (2020). This update shall be in full compliance with REGDOC Full details of this implementation plan can be found in OPG letters dated October 31, 2014 (e-doc ) and December 10, 2014 (e-doc ), which have been included in Appendix G of this LCH. The following documents require written notification of change: Document Title Document # Prior Notification? Darlington NGS Safety Report: NK38-SR No Part 2 System Descriptions DN 1-4 Safety Report: Part 3-Accident Analysis NK38-SR No Darlington Analysis of Record NK38-REP No Beyond Design Basis Accident Management N-STD-MP-0019 No SAFETY ANALYSIS Licence Conditions e-doc Page 48 of 142

321 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document Title Document # Prior Notification? Reactor Safety Program N-PROG-MP-0014 No Safety Analysis Basis and Safety Report N-PROC-MP-0086 No Risk and Reliability Program N-PROG-RA-0016 No Preparation, Maintenance and Application of Probabilistic Risk Assessment N-STD-RA-0034 Software N-PROG-MP-0006 No No Recommendations and Guidance: Detailed methodologies and derived acceptance criteria for the conduct of deterministic safety analysis are described in the following COG documents: Principles & Guidelines For Deterministic Safety Analysis P&G COG R2 Guidelines for Application of the Limit of Operating Envelope Methodology to Deterministic Safety Analysis, COG R00 Guidelines for Application of the Best Estimate Analysis and Uncertainty (BEAU) Methodology to Licensing Analysis, COG R01 Principles and Guidelines for NOP/ROP Trip Setpoint Analysis for CANDU Reactors, COG R00 Derived Acceptance Criteria For Determinist Safety Analysis, COG R00 Updates to deterministic safety analysis should contain a revision summary sheet highlighting the key differences between the existing analyses and updated analysis. The revision summary should include: Summary of changes (key differences) such as: o o o o o o o in acceptance criteria In event characterization In safety analysis assumptions In methodology, or in elements of a methodology In plant models In use of computer codes and embedded models In trip coverage Reasons for updating the analysis and for updating models, assumptions, initial conditions or boundary conditions; Significance of changes, and their justification; Significant changes in results that may affect the conclusions of the analysis for the design; operational or emergency safety requirements for a particular situation or event; and Impact on operating and safety margins. SAFETY ANALYSIS Licence Conditions e-doc Page 49 of 142

322 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The licensee should maintain a Safety Report Basis consisting of a listing of Analysis of Record Items and auxiliary documents. The licensee should continue to provide CNSC staff with regular updates of the list indicating the submissions to be included in the next Safety Report update (Part 3). When the deterministic safety analysis methodology is modified as a result of improved knowledge, or to address emerging issues, the licensee should assess the impact of such a modification on the operating limits, as well as procedural and administrative rules. The licensee should not credit results obtained with a modified safety analysis methodology to relax operating conditions and/or change safety margins until the modification of the methodology has been reviewed by CNSC staff. If CNSC staff indicate that the modified methodology is appropriate, the licensee must still fulfill any other requirements or criteria associated with the changes to the operating conditions or safety margins, as documented under other LCs such as those in Section 3. General criteria that CNSC will consider when reviewing such methodologies are provided in Appendix A.4. In addition to industry standards, CNSC staff will refer to the applicable industry verification and validation process practices related to computer codes and software used to support the safe plant operation. SAFETY ANALYSIS Licence Conditions e-doc Page 50 of 142

323 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA PHYSICAL DESIGN The safety and control area Physical Design relates to activities that impact on the ability of systems, components and structures to meet and maintain their design basis given new information arising over time and taking changes in the external environment into account. Performance Objective(s) There is confirmation that systems, structures and components that are important to nuclear safety and security continue to meet their design basis in all operational states and design basis accidents until the end of their design life. 5.1 Design Program Licence Condition 5.1: The licensee shall implement and maintain a design program. Preamble: The Class I Nuclear Facilities Regulations require that a licence application contain a description of the structures, systems and components (SSC), and relevant documentation of the plant design. A design program ensures that the plant design is managed using a well-defined systematic approach. Implementing and maintaining a design program confirms that safety-related SSCs and any modifications to them continue to meet their design bases given new information arising over time and taking changes in the external environment into account. It also confirms that SSCs continue to be able to perform their safety functions under all plant states. An important cross-cutting element of a design program is design basis management. A design program should be composed of elements that consider topics including but not limited to: pressure boundary design, civil structure design, seismic design, mechanical design, fuel design, core nuclear design, core thermal-hydraulic design, safety system design, fire protection design, electrical power system design, as well as instrumentation and control system design. Compliance Verification Criteria: The licensee shall ensure that all safety-related SSCs are designed to perform their required functions under all plant states for which the system must remain available. OPG shall ensure that any modifications made to the facility are in accordance with OPG engineering change control process, and CSA standards: N291 Requirements for Safety Related Structures for CANDU Nuclear Power Plants (Update no. 2, 2011); and N290.0 General Requirements for Safety Systems of Nuclear Power Plants. PHYSICAL DESIGN Licence Conditions e-doc Page 51 of 142

324 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CSA CSA Requirements for Safety Related Structures for CANDU Nuclear Power Plants General Requirements for Safety Systems of Nuclear Power Plants Design Basis Management N N The licensee shall ensure that plant status changes (design modifications) are controlled such that the plant is maintained and modified within the limits prescribed by the design and licensing basis. Aspects of design are considered safety and control measures if changes to them could: invalidate the limits documented in the operating policies and principles or safe operating envelope referred to in LC 3.1; introduce hazards different in nature or greater in probability or consequence than those considered by the safety analyses and probabilistic safety assessment; and/or adversely impact other important safety and control measures, such as those related to operations, radiation protection, emergency preparedness, etc. The licensee shall ensure that changes to those aspects of design remain within the licensing basis and shall notify the CNSC when such changes are planned. When reviewing such changes, CNSC staff will use the criteria in Appendix A.4 and any other applicable criteria. Changes outside the licensing basis would require prior written approval by the Commission. The licensee shall ensure that plant design and changes to plant design are accurately reflected in the safety analysis (see section 4.1 for licensee documents that contain the facilities descriptions and the final safety analysis reports). Where specific reports (e.g., external third party reviews as required by CSA standard N293, which is cited in LC 10.2) are required by the standards in the licensing basis, these shall be submitted to the CNSC. Design Sub-programs See LC 5.2 for compliance verification criteria on pressure boundary design and LC 5.3 for compliance verification criteria on equipment and structure qualification. Modification of the special safety systems (Shutdown System 1, Shutdown System 2, Emergency Core Cooling System and Containment System) or significant changes to systems connected to the special safety systems (e.g. change that would impact safety margins) would require prior notification and engagement of CNSC. When reviewing such changes, CNSC staff will use the criteria in Appendix A.4 and any other applicable criteria. Changes outside the licensing basis would require prior written approval by the Commission. Prior notification is not required for changes to items that serve the same functional characteristics of the originally designed item and does not result in a change to operating procedures or safety system testing. PHYSICAL DESIGN Licence Conditions e-doc Page 52 of 142

325 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 All changes or modifications, temporary or permanent, to the special safety systems (SSS) and systems related to safety (SRS) shall be identified in the annual reliability report. The licensee shall have sub-program elements that address the design and modification of concrete containment structures and safety-related structures. The licensee shall design, build, modify and otherwise carry out work related to the nuclear facility with potential to impact protection from fire in accordance with CSA N293. Any changes that have the potential to impact fire protection are assessed for compliance with CSA standard N293 and, if required, an external third party review shall be performed and the results submitted to the CNSC. See LC 10.2 for version control of N293. The plant electrical power system design shall include the safety classifications of the systems. Its design shall be adequate for all modes of operation under steady-state, voltage and frequency excursion, and transient conditions, as confirmed by electrical analysis. The electrical power systems shall be monitored and tested to demonstrate they comply with the design requirements and to verify the operability for AC systems and DC systems. The licensee shall ensure that the plant overall instrumentation and control (I&C) system and electrical power systems is designed to satisfy the following: the safety classification of the I&C system is in compliance with plant level system classification and is justified by analysis; system meets separation requirements between the groups and channels; safety features for enhancing system reliability and integrity are identified and implemented in the design, for example, fail safe design, redundancy, independence and testing capability system is not vulnerable to common cause failures; and I&C and electrical power systems of safety systems meet the requirements of single failure criteria. The licensee shall demonstrate survivability of the I&C systems and component that are critical to the management of BDBAs, and the availability of power supply to necessary equipment and associated I&C for BDBAs. Prior to making use of a new fuel bundle/fuel bundle string or fuel assembly design in the reactor, the licensee shall perform design verification activities, analyses and testing to demonstrate that design requirements are met. The length and complexities of those activities depend on the novelty of the design. No fuel bundle/fuel bundle string or fuel assembly shall be loaded into a reactor unless the use of the design of the fuel bundle/fuel bundle string or fuel assembly has received prior written approval by the Commission, or a person authorized by the Commission. The licensee shall update and maintain the reactor core nuclear design information found in the safety report and supporting design manuals. Core surveillance activities shall be implemented to ensure compliance with reactor core nuclear design and operation within the design envelope. Significant changes to core nuclear design would require prior notification and engagement of CNSC. When reviewing such changes, CNSC staff will use the criteria in Appendix A.4 and any other applicable criteria. Changes outside the reactor core nuclear design basis would require prior written approval by the Commission. PHYSICAL DESIGN Licence Conditions e-doc Page 53 of 142

326 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The design of the existing safety-related structures and components and any modification shall include consideration for human factors. For proposed modifications, modern requirements that are consistent with the current licensing basis of the plant shall be applied to the extent practicable. The licensee shall ensure configuration management is aligned with the design and safety analysis and incorporated into purchasing, construction, commissioning, operating and maintenance documentation. Conformance is to be maintained between design requirements, physical configuration and facility configuration information. The licensee shall establish a design authority function with the authority to review, verify, approve (or reject), document the design changes and maintain design configuration control. The following documents require written notification of change: Document Title Document # Conduct of Engineering N-PROG-MP-0007 No Engineering Change Control N-PROG-MP-0001 No Configuration Management N-PROG-MP-0005 No Design Management N-PROG-MP-0009 No Fuel N-PROG-MA-0016 No Procurement From Licensed Canadian Nuclear Utilities N-INS No Prior Notification? As per the agreement reached in CNSC letter dated June 22, 2012 (e-doc ) a number of designrelated codes and standards, associated effective dates and conditions were established. The purpose of the agreement is to ensure consistent and stable design requirements are applied throughout the Darlington Refurbishment Project. For refurbishment design, the agreement took effect upon issuance of the letter; for other design activities the agreement took effect on October 30, The agreement will remain valid until the end of the Darlington Refurbishment Project, which is expected to be complete in OPG shall provide to the CNSC the code-over-code reviews conducted for any subsequent editions, addendums and/or updates of the codes and standards that were agreed upon, with OPG s assessment of the changes and their significance upon completion of the review and assessment of significance (e-doc and ). OPG shall submit such assessments on an annual basis. Recommendations and Guidance: With regard to modifications, the design basis for the plant should be documented and maintained to reflect design changes to ensure adequate configuration management. The design basis should be maintained to reflect new information, operating experience, safety analyses, and resolution of safety issues or correction of deficiencies. The impacts of the design changes should be fully assessed, addressed and accurately reflected in the safety analyses prior to implementation. PHYSICAL DESIGN Licence Conditions e-doc Page 54 of 142

327 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The design program should minimize the potential for human error and promote safe and reliable system performance through the consideration of human factors in the design of facilities, systems, and equipment. Recommendations and guidance for considering human factors in design programs are provided in CNSC regulatory documents G-276 Human Factors Engineering Program Plans and G-278 Human Factors Verification and Validation Plans. Recommendations and guidance are found in the following documents: CSA N287 Series (287.1 to 287.6) which covers concrete containment structures; CSA N289 Series (289.1 to 289.5) which covers seismic qualification; CSA N290 series (290.1 to 290.6) which covers shutdown systems, emergency core cooling, containment systems, reactor control, electrical power and instrument air systems, and monitoring and display functions; CSA N which covers qualification of pre-developed software; REGDOC which covers design of reactor facilities; and UFC which covers structures to resist accidental explosions. The licensee s design program should provide a table or roadmap that identifies relevant design basis documents, design sub-programs and processes that are maintained by the licensee. PHYSICAL DESIGN Licence Conditions e-doc Page 55 of 142

328 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Pressure Boundary Program Licence Condition 5.2: The licensee shall implement and maintain a pressure boundary program and have in place a formal agreement with an Authorized Inspection Agency. Preamble: This licence condition provides regulatory oversight with regards to the licensee s implementation of a pressure boundary program and holds the licensee responsible for all aspects of pressure boundary registration and inspections. A pressure boundary program is comprised of the many programs, processes and procedures and associated controls that are required to ensure compliance with CSA standard N285.0, which defines the technical requirements for the design, procurement, fabrication, installation, modification, repair, replacement, testing, examination and inspection of pressure-retaining and containment systems, including their components and supports. This LC also ensures that an Authorized Inspection Agency (AIA) will be subcontracted directly by the licensee. An AIA is an organization recognized by the CNSC as authorized to register designs and procedures, perform inspections, and other functions and activities as defined by N285.0 and its applicable referenced publications (e.g. CSA standard B51, National Board Inspection Code). The AIA is accredited by the American Society of Mechanical Engineers (ASME) as stipulated by NCA-5121 of the ASME Boiler & Pressure Vessel Code. A pressure boundary is a boundary of any pressure retaining vessel, system or component of a nuclear or non-nuclear system, where the vessel, system or component is registered or eligible for registration. Compliance Verification Criteria: The licensee shall implement and maintain a pressure boundary program. This program shall be in accordance with CSA standard N285.0 General Requirements for Pressure Retaining Systems and Components in CANDU Nuclear Power Plants. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CSA General requirements for pressureretaining systems and components in CANDU nuclear power plants N Update no. 2* *Note: (a) Including Update No. 1, (b) Annex M is accepted to be used as a Normative Annex. PHYSICAL DESIGN Licence Conditions e-doc Page 56 of 142

329 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Transitional Provisions to CSA N with Update No. 2 and Annex M: Pressure boundary activities shall be compliant with CSA N with Update No.2; CSA B51-09 and Update No. 1; ASME BPVC 2010 ED with 2011 ADD; ASME B ; ASME B ; and ASME B except as provided below: a) Work packages compliant with CSA N and Update No.1, being produced or underway prior to October 30, 2013 will remain valid for implementation until June 30, b) Design modifications classified (approved by CNSC or using the OPG Classification procedure) after January 1, 2011 and before October 30, 2013 will be designed and installed to the CSA N285.0 and ASME edition or version specified in the System Classification List, when installed no later than June 30, c) Purchase Orders compliant with CSA N and Update No. 1 issued prior to October 30, 2013 will remain valid for installation. d) The Code Effective Dates do not apply to non-design-related requirements under the codes and standards listed above. CNSC may require OPG s programs or processes to be updated for nondesign-related requirements to meet the new version of the standards once it is published. e) OPG shall provide to the CNSC the code-over-code reviews conducted for any subsequent editions, addendums and/or updates of the codes and standards listed above, with OPG s assessment of the changes and their significance upon completion of the review and assessment of significance. OPG shall submit such assessments on an annual basis. Engineering planning activities for the Darlington Refurbishment Project follow CSA N with Update No.2; CSA B51-09 and Update No. 1; ASME BPVC 2010 ED with 2011 ADD; ASME B ; ASME B ; and ASME B The licensee shall maintain a Pressure Boundary Program Document roadmap in compliance with Annex N of CSA N and Update No. 1. The licensee shall operate vessels, boilers, systems, piping, fittings, parts, components, and supports safely and keep them in a safe condition. OPG shall: a) follow work plans and procedures, accepted by the AIA, to test, maintain, or alter over-pressure protection devices; b) comply with operating limits specified in certificates, orders, designs, overpressure protection reports, and applicable codes and standards; and c) have any certified boiler or vessel that is in operation or use inspected and certified by an authorized inspector according to an accepted schedule. Classification, Registration and Reconciliation Procedures Licensee procedures describing the classification, registration and reconciliation processes and the associated controls shall form part of the pressure boundary program. The licensee shall provide prior notification of any changes to the procedures describing the classification, registration and reconciliation processes. PHYSICAL DESIGN Licence Conditions e-doc Page 57 of 142

330 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Overpressure Protection Reports The licensee shall provide WN to CNSC staff, of new or revised overpressure protection reports, after the final registration of the system. General criteria for CNSC s review of such notices are provided in Appendix A.4. Classification and Registration of Fire Protection Systems Fire protection systems and associated fittings and components are to be classified at least as Code Class 6, designed to the ASME B31.1 and registered, unless the exemption criteria noted below are met. The following fittings and components may be exempt from requiring a Canadian Registration Number (CRN) provided they meet the following exemption criteria: a) deluge, fire hose control, pressure control, drain, pre-action, alarm and dry pipe valves and devices, providing they are cul or ULC listed and suitable for the expected environmental conditions and maximum pressure; or b) fire and jockey pumps and their controllers that meet the requirements of the National Fire Protection Association (NFPA)-20, are cul or ULC listed and are suitable for the expected environmental conditions and maximum pressure; or c) sprinkler, nozzles, inductors, proportioners, hoses, strainers and other spray and distribution devices, that are cul or ULC listed and suitable for the expected environmental conditions and maximum pressure; or d) pressurized cylinders and tubes, such as extinguishers, inert gas and foam tanks, that bear Transport Canada approvals and suitable for the expected environmental conditions and maximum pressures; or e) buried fire protection piping that is in compliance with NFPA-24. Buried fire protection piping may be exempt from the ASME testing requirements if testing is performed to NFPA-24. The requirements of CSA N285.0 apply for components higher than Code Class 6. Formal Agreement with an Authorized Inspection Agency The licensee shall always have in place a formal agreement with an AIA to provide services for the pressure boundaries of the nuclear facility as defined by CSA N285.0 and its applicable referenced publications. The AIA must be accredited by the ASME as stipulated by NCA-5121 of the ASME Boiler and Pressure Vessel Code. Design registration services for pressure boundaries shall be provided by an AIA legally entitled under the Provincial Boilers and Pressure Vessels Acts and Regulations to register designs. Registration of piping systems shall be done by the Technical Standards and Safety Authority (TSSA), who is legally entitled to register designs in Ontario. PHYSICAL DESIGN Licence Conditions e-doc Page 58 of 142

331 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 A copy of the signed Agreement shall be provided to the CNSC. During the licence period, the licensee shall notify the CNSC in writing of any change to the terms and conditions of the Agreement, including termination of the Agreement. The licensee shall arrange for the AIA inspectors to have access to all areas of the facility and records, and to the facilities and records of the licensee s pressure boundary contractors and material organizations, as necessary for the purposes of performing inspections and other activities required by the standards. Inspectors of the AIA shall be provided with information, reasonably in advance with notice and time necessary to plan and perform inspections and other activities required by the standards. For a variance or deviation from the requirements of the CSA N285.0 standard, the licensee must first submit the proposed resolution to the AIA for evaluation, and then to the CNSC for consent. Per the agreement with the AIA, the evaluated resolution shall not be implemented without the prior written consent of CNSC staff. General criteria for obtaining prior written consent/approval for a proposed resolution from the CNSC can be found in Appendix A.4. The following documents require written notification of change: Document Title Document # Prior Notification? Pressure Boundary Program N-PROG-MP-00 Yes System and Item Classification N-PROC-MP-0040 Yes Design Registration N-PROC-MP-0082 Yes Pressure Boundary Program Manual N-MAN No Index to OPG Pressure Boundary Program Elements N-LIST No Authorized Inspection Agency Service Agreement N/A Yes* * Termination of the agreement is considered a change that requires WN of the CNSC. Recommendation and Guidance: Recommendations and guidance are found in the following CSA standards and ASME Codes: CSA N285.6 Series, which covers material standards for CANDU reactor components; CSA N289 Series, which covers seismic qualification; ASME Boiler and Pressure Vessel Code; ASME B31.1 for Power Piping; ASME B31.3 Process Piping Code; ASME B31.5 Refrigeration Piping and Heat Transfer Component Code; and CSA B51 Boiler, Pressure Vessel, and Pressure Piping. Note: Where these standards/codes or portions thereof are required for compliance with a governing standard referenced in the LCH under LC 5.2, compliance to the referenced standards/codes or portions thereof is required for compliance with the governing standard and the LC referencing the overlying standard. The AIA, and its authorized inspectors, should be familiar with and capable of applying the CSA N285.0 provisions to perform their activities as defined by the standard. PHYSICAL DESIGN Licence Conditions e-doc Page 59 of 142

332 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Equipment and Structure Qualification Program Licence Condition 5.3: The licensee shall implement and maintain an equipment and structure qualification program. Preamble: Environmental qualification (EQ) ensures that all required equipment in a nuclear facility are qualified to perform their safety functions if exposed to harsh environmental conditions resulting from credited Design Basis Accidents (DBA) and that this capability is preserved for the life of the plant. Condition monitoring assesses variables that indicate the physical state of the equipment, and assesses its ability to perform its intended function following the period of observation. Environmental monitoring measures environmental stressors, such as temperature, radiation and operational cycling during normal operating conditions. Seismic qualification (SQ) ensures that all seismically credited safety-related SSCs in a Nuclear Power Plant are designed, installed and maintained to perform their safety function during and/or after (as needed and pre-defined) a design basis earthquake or site design earthquake and also ensures an adequate margin against review level earthquakes. Compliance Verification Criteria: The licensee shall implement and maintain environmental and seismic qualification programs. The programs shall be in accordance with CSA standards: N Environmental Qualification of Equipment for CANDU Nuclear Power Plant; and N289.1 General Requirements for Seismic, Design and Qualifications of CANDU Nuclear Power Plants. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CSA CSA Environmental Qualification of Equipment for CANDU Nuclear Power Plants General Requirements for Seismic Design and Qualification of CANDU Nuclear Power Plants N & Update 1 (2009) N Environmental Qualification: In addition to the criteria set out in N290.13, the EQ program shall include a monitoring program consisting of condition monitoring and environmental monitoring, to measure degradation and failures of qualified equipment, including cables. PHYSICAL DESIGN Licence Conditions e-doc Page 60 of 142

333 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Seismic Qualification: Seismically credited safety-related SSCs in a nuclear facility shall be designed, installed and maintained to perform their safety function against earthquakes. Seismic qualification or modification of a seismically qualified SSC would require prior notification and engagement of CNSC. When reviewing such changes, CNSC staff will use the criteria in Appendix A.4 and any other applicable criteria. Changes outside the licensing basis would require prior written approval by the Commission. The following documents require written notification of change: Document Title Document # Prior Notification? Environmental Qualification N-PROG-RA-0006 No As per the agreement reached in CNSC letter dated June 22, 2012 (e-doc ) a number of designrelated codes and standards, associated effective dates and conditions were established, including application of CSA N The purpose of the agreement is to ensure consistent and stable design requirements are applied throughout the Darlington Refurbishment Project. For refurbishment design, the agreement took effect upon issuance of the letter; for other design activities the agreement took effect on October 30, The agreement will remain valid until the end of the Darlington Refurbishment Project, which is expected to be complete in OPG shall provide to the CNSC the code-over-code reviews conducted for any subsequent editions, addendums and/or updates of the CSA N and Update No.1, with OPG s assessment of the changes and their significance upon completion of the review and assessment of significance (e-doc ). OPG shall submit such assessments on an annual basis. Recommendations and Guidance: The processes and procedures related to the EQ program should meet the requirements of recognized industrial standards. In addition to addressing the detailed requirements of CSA N289.1, the licensee SQ sub-program should: identify the methods for establishing SQ, including code effective dates; identify the SSCs for which evaluation of their capacity beyond the Design Basis Earthquake has been done; identify the methods used for Beyond Design Basis Earthquake evaluation; include procedural controls for periodic inspection and maintenance of conditions to ensure SQ of existing SSCs for the life of the plant; identify the seismic monitoring system and its design and maintenance requirements; and include procedural controls for establishing SQ for new and replacement items. PHYSICAL DESIGN Licence Conditions e-doc Page 61 of 142

334 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The processes and procedures related to the SQ program should address the following CSA standards: N289.2 Ground Motion Determination for Seismic Qualification of nuclear Power Plants; N289.3 Design Procedures for Seismic Qualification of nuclear Power Plants; N289.4 Testing Procedures for Seismic Qualification of nuclear Power Plant Structures, systems and Components; and N289.5 Seismic Instrumentation Requirements for Nuclear Power Plants and Nuclear Facilities. PHYSICAL DESIGN Licence Conditions e-doc Page 62 of 142

335 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA FITNESS FOR SERVICE The safety and control area Fitness for Service covers activities that impact on the physical condition of systems, components and structures to ensure that they remain effective over time. This includes programs that ensure all equipment is available to perform its intended design function when called upon to do so. Performance Objective(s) Systems, structures and components whose performance may affect safe operations or security remain available, reliable and effective, and are consistent with the design, quality control measures and analysis documents. 6.1 Fitness for Service Programs Licence Condition 6.1: The licensee shall implement and maintain a fitness for service program. Preamble: The Class I Nuclear Facilities Regulations requires that a licence application contain the proposed measures, policies, methods and procedures to maintain the nuclear facility. The following program elements ensure fitness for service of SSCs: maintenance program defining the policies, processes and procedures that provide direction for maintaining SSCs of the plant; effective control of plant chemistry to ensure critical plant equipment performs safely and reliably; aging management activities to ensure the reliability and available of required safety functions of SSCs; periodic and in-service inspection programs to ensure that pressure-boundary components; containment structures and components, continue to meet their design requirements; in-service inspection of balance of plant to ensure safety significant pressure retaining systems; components and safety-related structures are monitored for degradation; and proper reliability program and implementation to ensure that Systems Important to Safety continue to meet their performance requirements. An NPP maintenance program consists of policies, processes and procedures that provide direction for maintaining structures, systems or components (SSCs) of the plant. The intent of a maintenance program is to ensure that the SSCs remain capable of maintaining their function as described in the safety analysis. A maintenance program uses organized activities, both administrative and technical, to keep SSCs in good operating condition, and to ensure that they function as per design. FITNESS FOR SERVICE Licence Conditions e-doc Page 63 of 142

336 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Planned outages represent a key activity that has a high regulatory significance. Therefore a review is required to ensure proper scoping (of safety-related commitments), planning and execution of the commitments (e.g., for heat sinks, dose control, etc.). Compliance Verification Criteria: The licensee shall implement and maintain programs to ensure fitness for service of systems, structures and components. These programs shall be in accordance with: CNSC regulatory document RD/GD-210 Maintenance Programs for Nuclear Power Plants; CNSC regulatory document RD/GD-98 Reliability Programs for Nuclear Power Plants; CNSC regulatory document REGDOC Aging Management; CSA standard N285.4 Periodic Inspection of CANDU Nuclear Power Plant Components; CSA standard N285.5 Periodic Inspection of CANDU Nuclear Power Plant Containment Components; and CSA standard N287.7 In-service Examination and Testing Requirements for Concrete Containment Structures for CANDU Nuclear Power Plants. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CNSC CNSC Maintenance Programs for Nuclear Power Plants Reliability Programs for Nuclear Power Plants RD/GD RD/GD CNSC Aging Management REGDOC CSA CSA Periodic Inspection of CANDU Nuclear Power Plant Components Periodic Inspection of CANDU Nuclear Power Plant Containment Components N N CSA In-service Examination and Testing Requirements for Concrete Containment Structures for CANDU Nuclear Power Plants N * Where N285.4 refers to N285.8, OPG shall comply with N (e-doc ). Maintenance Implementation of RD/GD-210 is verified by CNSC staff through the maintenance-related findings from routine inspections, cross-cutting system inspections and monitoring of maintenance related performance indicators. Maintenance activities include planning and scheduling, SSC monitoring and work execution. Maintenance performance indicators are monitored and compared to best industry practice where practicable. FITNESS FOR SERVICE Licence Conditions e-doc Page 64 of 142

337 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Management of Planned Outages: The maintenance program shall include provisions for the management of planned outages. The licensee s program related to management of planned outages is documented in N-PROC-MA-0013 Planned Outage Management. The licensee shall make outage-related information (including Level 1 and Level 2 Outage Plans, detailing all major work on safety related structures, systems and components to be carried out during the planned outage) available to CNSC staff. Reliability of Systems Important to Safety The licensee shall establish a reliability program that includes setting reliability targets, performing reliability assessments, testing and monitoring, and reporting for plant systems whose failure affect the risk of a release of radioactive or hazardous material. The reliability program assures that the risk-related system functions credited in the PSA and systems important to safety at the plant, can, and will, meet the availability and reliability requirements as stated or assumed in the PSA throughout the lifetime of the facility. Chemistry Control The chemistry control sub-program shall specify processes, specifications, overall requirements, parameter monitoring, data trending and evaluation to ensure effective control of plant chemistry during operational and lay-up conditions. The licensee shall maintain a set of technical basis documents describing the design basis for chemistry control. Aging Management OPG has committed to complying with REGDOC 2.6.3, Aging Management, and shall complete the transition to the 2014 version by July 15, 2017 (e-doc ). SSC-specific aging management plans (AM plans - also in some cases referred to as life cycle management plans (LCMPs)), shall be implemented in accordance with the overall integrated aging management program framework, and address the attributes of an effective aging management program as listed in REGDOC The SSC-specific AM plans or LCMPs shall include structured, forward looking inspection and maintenance schedules, requirements to monitor and trend aging effects and any preventative actions necessary to minimize and control aging degradation of the SSCs. The SSC-specific AM plans or LCMPs which are submitted with, or in support of, the application are licensing basis documents. As such any changes to the SSC-specific AM plans or LCMPs will be reviewed by CNSC staff to confirm that they remain within the licensing basis and provide adequate justification for changes to prior licensee commitments with respect to the inspection scope and other relevant commitments related to the continued operation of the facility. When considering possible changes to activities identified in the AM plans or LCMPs, the licensee shall engage CNSC staff early and provide confirmation that the changes are within the licensing basis prior to implementing the change. Administrative or other such changes to the documents are subject to normal notification requirements as indicated in the WN table for this section. FITNESS FOR SERVICE Licence Conditions e-doc Page 65 of 142

338 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Periodic and In-Service Inspection Programs OPG shall carry out the periodic inspections programs (PIPs) in accordance with the accepted PIP documents. If a deviation from the accepted PIP program is anticipated during inspection planning activities OPG shall obtain CNSC acceptance of the deviation prior to conducting the affected inspections. However, for any findings, discoveries or deviations from the accepted PIP that are identified when conducting an inspection, OPG shall follow OPG governance to provide justification to CNSC in the inspection report submission, based on OPEX and best industry practices. For permanently required exemptions to the requirements of CSA PIP standards, OPG shall document these exemptions in a revised PIP document and submit to the CNSC for acceptance. When PIP requirements are addressed exclusively within an AMP or LCMP document, only those elements of the document that directly address the PIP requirements of the governing CSA standard require acceptance from CNSC staff prior to implementation. CVC Related to CSA N285.4: OPG shall comply with the 2005 edition of this standard, including Update #1 June 2007 and any applicable exemptions accepted by the CNSC. The Darlington NGS N285.4 PIP is divided into four system/component groups addressing specific Clauses of CSA N285.4 including the General Pressure Boundary Components, Fuel Channel Pressure Tubes, Fuel Channel Feeder Pipes, and Steam Generators Tubes. CNSC staff have accepted the Darlington NGS PIP documents listed in the WN table for this section. Notable elements of the acceptance process for the PIP documents are discussed below. OPG has committed to update PIP documents to N with full implementation planned by July 01, 2019 (e-doc ). Fuel Channel Pressure Tubes (Clause 12): CNSC staff have accepted OPG s fuel channels PIP for Darlington station. With respect to N285.4 clause , CNSC staff have reviewed and accepted (e-doc and ) OPG s compliance plan (e-doc and ) for the use of CSA N Update 2, Technical requirements for in-service evaluation of zirconium alloy pressure tubes in CANDU reactors to evaluate inspection results. See Recommendations and Guidance (section CSA N , Clause 12 ) for more information on how CNSC will be reviewing the probabilistic assessments. CNSC staff accepted (e-doc and ) OPG s approach (e-doc ) to fitness for service assessment, regarding the application of new fracture toughness models and probabilistic Leak- Before-Break (LBB) assessments for pressure tubes at increased hydrogen content. OPG has planned continuing research & development to further validate and improve the fracture toughness models (e-doc ). OPG shall implement a long term life management plan for Inconel X-750 spacers in conformity with it submitted plan, e-doc FITNESS FOR SERVICE Licence Conditions e-doc Page 66 of 142

339 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 As indicated in the licensee s design manuals, the fuel channels were designed to meet the intent of Section III of ASME Boiler and Pressure Vessel Code. As a planning assumption, the fuel channels were designed and assembled to satisfy functional and economic life requirements for at least the equivalent of 210,000 hours of full power operation (i.e., 30 years at a capacity factor of 80%). Demonstration that fuel channels continue to meet the intent of Section III of ASME Boiler and Pressure Vessel Code is part of the design basis, which in turn is part of the licensing basis. For operation beyond 210,000 equivalent full power hours (EFPH), the licensee shall provide evidence to demonstrate that the predicted condition of pressure tubes continues to be sufficient to support safe operation. Operation of any unit beyond 210,000 EFPH is not permitted unless approved by the Commission in accordance with LC 1.1. Fuel Channel Annulus Spacers: As an interim approach, until such a time that spacer fitness for service methodology are incorporated into a CSA standard, CNSC staff have accepted OPG s proposal to use NK38-PLAN R01, Long Term Darlington Life Management Plan for Inconel X-750 Spacers. The following criteria shall be applied to evaluation of spacer inspection and material surveillance test results: spacer location inspection results shall show no evidence of spacer mobility; pressure tube to calandria tube gap measurement inspections results shall be consistent with integral spacers; and spacer material surveillance test results shall support spacer integrity beyond the next planned surveillance point. OPG shall submit for CNSC staff acceptance, spacer location inspection results, pressure tube to calandria tube gap results, and available spacer surveillance test results within 90 days of the Chief Nuclear Engineer review of gates #2, #3 and #4, as outlined in NK38-PLAN , including the assessment of any inspection or surveillance results which fail to satisfy the criteria described above. In each submission, OPG shall include the degradation assessment demonstrating fitness for service of spacers beyond the next review gate. Should CNSC staff provide concerns associated with OPG s submission, OPG shall submit to CNSC staff a formal response within 90 days. OPG shall not operate a reactor unit beyond CNSC staff s accepted X-750 fitness for service interval established by the last CNSC staff accepted gate. Fuel Channel Feeder Pipes (Clause 13): CNSC staff have accepted the Darlington Feeder PIP, with an exemption from periodic inspection for outlet feeder dissimilar metal welds. This exemption was based on OPG s preliminary Leak-Before- Break (LBB) assessment and commitment to complete additional work in support of the requested exemption (e-doc and ). OPG s final LBB assessment for the feeder dissimilar welds will be submitted to the CNSC for acceptance. The current target date for this submission is November With respect to N clause , CNSC staff have accepted OPG s request to use COG-JP V06 Rev. 03 Fitness-for-Service Guidelines (FFSG) for Feeders in CANDU Reactors, (e-doc and ). FITNESS FOR SERVICE Licence Conditions e-doc Page 67 of 142

340 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Steam Generator Tubes (Clause 14): CNSC staff have accepted OPG s steam generator tubes PIP for Darlington station. With respect to N clause , CNSC staff has accepted OPG s request to use COG Report R1 Fitness-for-Service Guidelines for Steam Generator and Preheater Tubes, with one exception pertaining to the use of the Level D safety factors stipulated in ID Paragraph (a), Deterministic Leak-Before-Break, to other load levels (levels A, B, C) and any other portions of the FFSG that invoke the use of ID (e-doc ). Instead, OPG is required to continue using the safety factors defined in ID Paragraph (a) of Revision 0 of the fitness-for-service guidelines for the appropriate load levels. CVC Related to CSA N285.5 OPG shall comply with the 2008 edition of this standard, including Update #1 January CNSC staff have accepted the Darlington NGS PIP Program, which meets the requirements of N (e-doc ). CVC Related to CSA N287.7 CNSC staff have accepted the Darlington NGS N PIP documents listed in the Document Version Control table of this section including the leakage rate test documents for the concrete containment structures and the technical specification for the post-tensioning system inspection (e-doc ). OPG shall carry out the inspections and tests of the vacuum building, the dousing system and the pressure relief duct at least once every twelve years, as agreed upon in CNSC correspondence Vacuum Building Test and Inspection Frequency (e-doc ). The next Vacuum Structure Positive Pressure Test shall be conducted in 2015 based on CNSC staff acceptance of OPG s request to defer it from the 2009 Vacuum Building Outage (VBO) to 2015 VBO. OPG shall perform a test to measure the leakage rate, at full positive design pressure, of the Main Containment Structure in 2015 and every twelve years thereafter (e-doc ). In addition, OPG shall inspect the concrete structures of the Main Containment Structures and their components once every six years in accordance with the CSA N287.7 PIP. In-service Inspection of Balance of Plant The licensee shall have adequate knowledge of the current state of BOP pressure retaining systems, components and safety-related structures to ensure that they are capable of operating within their design intent and perform required safety functions if called upon. The licensee shall develop, implement and maintain in-service inspection program(s) and LCMPs for these systems in keeping with industry best practices including: a) An ISI sub-program for safety-significant BOP pressure retaining systems and components; and FITNESS FOR SERVICE Licence Conditions e-doc Page 68 of 142

341 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 b) An ISI sub-program for BOP safety-related structures, excluding concrete containment structures in accordance with CSA N291 Requirements for safety-related structures for CANDU nuclear power plants. OPG document, N-PROG-MA-0017 Components and Equipment Surveillance, includes a comprehensive set of activities to evaluate, inspect, test and report on the health of specific safetysignificant BOP component groups which forms part of the pressure-retaining system and components. Licensee document N-PROG-MP-0008, Integrated Aging Management defines and provides the requirements for the establishment of the aging management scope related to safety-related BOP civil structures. The following documents require written notification of change: Document Title Document # Maintenance Prior Notification? Conduct of Maintenance N-PROG-MA-0004 No Component and Equipment Surveillance N-PROG-MA-0017 No Production Work Management N-PROG-MA-0019 No Integrated Aging Management N-PROG-MP-0008 No Planned Outage Management N-PROC-MA-0013 No Forced Outage Management N-PROC-MA-0049 No Reliability Equipment Reliability N-PROG-MA-0026 No Risk and Reliability Program N-PROG-RA-0016 No Reliability and Monitoring of Systems Important to Safety N-STD-RA-0033 No List of Safety Related Systems and Functions NK38-LIST Yes Aging Management Major Components N-PROG-MA-0025 No Feeders Life Cycle Management Plan N-PLAN Yes* Feeders Darlington Nuclear Unit 1 Fuel Channel Feeder Pipes Periodic Inspection Program Plan Darlington Nuclear Unit 2 Fuel Channel Feeder Pipes Periodic Inspection Program Plan NK38-PIP NK38-PIP Yes Yes FITNESS FOR SERVICE Licence Conditions e-doc Page 69 of 142

342 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document Title Document # Darlington Nuclear Unit 3 Fuel Channel Feeder Pipes Periodic Inspection Program Plan Darlington Nuclear Unit 4 Fuel Channel Feeder Pipes Periodic Inspection Program Plan Pressure Boundary NK38-PIP NK38-PIP Prior Notification? Yes Yes Steam Generators Life Cycle Management Plan N-PLAN Yes* Darlington Units 1-4 Steam Generator Life Cycle Management Plan Steam Generators Fuel Channel NK38-PLAN Yes* Fuel Channels Life Cycle Management Plan N-PLAN Yes* Darlington Nuclear 1-4, Unit 1 Fuel Channel Pressure Tubes Periodic Inspection Program Plan Darlington Nuclear 1-4, Unit 2 Fuel Channel Pressure Tubes Periodic Inspection Program Plan Darlington Nuclear 1-4, Unit 3 Fuel Channel Pressure Tubes Periodic Inspection Program Plan Darlington Nuclear 1-4, Unit 4 Fuel Channel Pressure Tubes Periodic Inspection Program Plan Reactor Components and Structures Life Cycle Management Plan Long Term Darlington Life Management Plan for Inconel X-750 Spacers Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 1 Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 2 Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 3 Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 4 Darlington Nuclear Generating Station Periodic Inspection Program For Unit 0 and Units 1 To 4 Containment Components Darlington Nuclear Unit 0 Containment Periodic Inspection Program Periodic Inspection Plans NK38-PIP NK38-PIP NK38-PIP NK38-PIP N-PLAN NK38-PLAN NK38-PIP NK38-PIP NK38-PIP NK38-PIP NK38-PIP NK38-PIP Aging Management Plan for Containment Structures N-PLAN Yes Darlington Nuclear Reactor Building Periodic Inspection Program Darlington Nuclear Vacuum Building Periodic Inspection Program NK38-PIP NK38-PIP FITNESS FOR SERVICE Licence Conditions e-doc Page 70 of 142 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

343 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document Title Document # Inspection of Post Tensioning Tendons on DNGS Vacuum Building Administrative Requirements for In-Service Examination and Testing for Concrete Containment Structures Aging Management Plan for Darlington NGS Non- Containment Building Structures Balance of Plant NK38-TS N-PROC-MA-0066 NK38-PLAN Prior Notification? Darlington NGS Main Containment Structure In-Service NK38-REP Leakage Rate Test Requirements In Accordance With Yes CSA N Darlington NGS Vacuum Structure In-Service Leakage NK38-REP Rate Test Requirements In Accordance With CSA Yes N *Prior notification is only required when changes to the document result in changes to the PIP that has received regulatory acceptance. Recommendations and Guidance: Maintenance The range of maintenance activities includes monitoring, inspecting, testing, assessing, calibrating, servicing, overhauling, repairing, and parts replacing. The type of maintenance activity and frequency applied to each SSC should be commensurate with importance to safety, design function and required performance. Outage Management The outage program should have designated criteria that the licensee will follow to confirm that planned and discovery work has been satisfactorily completed during the planned outage, and that all safetysignificant SSCs are available to ensure the continued safe operation of the facility. CNSC staff located at the site offices should be invited to the restart meetings in order to verify that all appropriate reviews for restart of the reactor have occurred. Management of Planned Outages Outage completion assurance statement should include the status of planned work that was identified in the notification of regulatory undertakings but not completed. Inspection Programs for Balance of Plant The licensee should document the current status of all of the safety-significant pressure-retaining components and develop aging management or LCMPs following the regulatory requirements of REGDOC The licensee may elect to use alternative approaches, provided the elements identified in REGDOC are addressed in an equivalent manner, and are demonstrated to be effective in managing aging. The plans should apply a systematic and integrated approach to establish, implement and improve programs to manage aging and obsolescence of SSCs. SSC-specific LCMPs and AMPs should be implemented in accordance with the licensee s overall integrated AMP framework. FITNESS FOR SERVICE Licence Conditions e-doc Page 71 of 142 Yes Yes Yes

344 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Non-destructive examination (NDE) procedures used in the Components and Equipment Surveillance sub-program should be developed and implemented using a level of rigour consistent with the safety significance of systems and components and the nature of the degradation. For NDE procedures necessary to carry out inspections in the BOP programs, guidance may be obtained from NDE requirements for the PIP program addressed in CSA N Aging Management Whenever a revision to the AMP, SSC-specific AMP or LCMP is submitted to CNSC for review, the licensee should identify whether the revision(s), affects the previously planned inspection and maintenance activities, with supporting technical basis for the change. The licensee should maintain a roadmap outlining the programs and procedures that ensure a welldocumented overall integrated aging management framework exists. CSA N , Clause 12 In the probabilistic core assessments for flaw, Leak Before Break and Pressure Tube to Calandria Tube contact, OPG should provide a comparison of the derived 95 % upper bound PT failure frequency with the criterion identified in Table C.1 of CSA N Update 2 and Table 3 of COG-JP V078-R01 (e-doc ). CNSC staff will compare the 95% upper bound of the calculated PT failure frequency with Table 3 of COG-JP-4363-V078 R01, until such time as the CSA N285.8 committee completes its review of the application of Table C. l of the CSA N (e-doc ). Note that the derived failure frequency from a given degradation mechanism should be compared against its individual contribution (based on the number of degradation mechanisms) to the total acceptable failure frequency in Table 3 of COG-JP-4363-V078 R01. However, it is acceptable to combine the allowable failure frequency for multiple degradation mechanisms, provided that the contribution has been quantified for each known mechanism. FITNESS FOR SERVICE Licence Conditions e-doc Page 72 of 142

345 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA RADIATION PROTECTION The safety and control area Radiation Protection covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations. This program must ensure that contamination and radiation doses received are monitored and controlled, and maintained as low as reasonably achievable (ALARA). Performance Objective(s) The health and safety of persons inside the facility are protected through the implementation of a radiation protection program that ensures that occupational exposures are below regulatory dose limits and are optimized and maintained ALARA. 7.1 Radiation Protection Program and Action Levels Licence Condition 7.1: The licensee shall implement and maintain a radiation protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within seven days. Preamble: The Radiation Protection Regulations require that the licensee implement a radiation protection program and also ascertain and record doses for each person who perform any duties in connection with any activity that is authorized by the Nuclear Safety and Control Act or is present at a place where that activity is carried on. This program must ensure that doses to workers do not exceed prescribed dose limits and are kept As Low As Reasonably Achievable (the ALARA principle), social and economic factors being taken into account. Note that the regulatory dose limits are explicitly provided in the Radiation Protection Regulations. Action Levels (ALs) are designed to alert licensees before regulatory dose limits are reached. By definition, if an action level referred to in a licence is reached, a loss of control of some part of the associated radiation protection program may have occurred, and specific action is required, as defined in the Radiation Protection Regulations and the licence. ALs are not intended to be static and are to reflect operating conditions in the station. Administrative Dose Limits (ADLs) are the licensee s internal dose limits designed to ensure individuals do not exceed regulatory dose limits. Certain ADLs that are exceeded without prior approval from the designated licensee authority are considered AL exceedances, as defined in the Radiation Protection Regulations. RADIATION PROTECTION Licence Conditions e-doc Page 73 of 142

346 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Compliance Verification Criteria: Radiation Protection Program Provisions for respiratory protection are captured in OPG document OPG-PROC- 0132, Respiratory Protection, identified as a document requiring WN under LC 8.1. Additionally, the radiation protection program shall ensure that occupational exposures are ascertained and recorded in accordance with the Radiation Protection Regulations, through the establishment of dosimetry requirements. Radiation Protection Action Levels The ALs and ADLs are considered part of the licensing basis. Changes to these limits are subject to LC G.1. The current ALs and ADLs for this facility are extracted from N-REP and N-PROC- RA-0019 summarized in the table below. In the event of a discrepancy between these tables below and the licensee documentation upon which they are based, the licensee documentation shall be considered the authoritative source (assuming that the licensee has followed its own change control process). Action Levels: Worker Dose Field of application Value Action Level DOSE TO WORKERS: Individual worker external radiation dose received on a job greater than planned 2mSv (200 mrem) A person receives an external whole body dose that equals or exceeds 2 msv (200 mrem) above the Electronic Personal Dosimeter (EPD) dose alarm set point. DOSE TO WORKERS: Individual worker internal exposures greater than planned DOSE TO WORKERS: Individual worker internal exposure to radionuclides (other than tritium as tritium oxide) greater than planned DOSE TO WORKERS: Cumulative annual Individual radiation dose exceeds annual administrative dose limits without approval kbq/l (65 μci/l) [2 msv or (200 mrem)] 0.1 ALI for a radionuclide other than tritium (tritium oxide). [2 msv or (200 mrem)] The Administrative Dose Limits (ADLs) are shown in the Table below. A person receives a single intake of tritium oxide (tritiated water) in which the unplanned component of the initial concentration immediately after intake is estimated to equal or exceed 2400 kbq/l (65 μci/l) (representing a nominal unplanned exposure of 2 msv (200 mrem)). A person receives an intake of a radionuclide other than tritium (in the form of tritium oxide) attributable to a single event that equals or exceed 0.1 of an Annual Limit of Intake (ALI) as defined in ICRP 68 Dose Coefficients for Intakes of Radionuclides by Workers (representing a nominal unplanned exposure of 2 msv [200 mrem] An individual s total whole body radiation dose accumulated over calendar year exceeds his ADL without approval. Doses that are to be compared with the ADLs include doses received at all places of employment during the year. RADIATION PROTECTION Licence Conditions e-doc Page 74 of 142

347 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Administrative Dose Limits: Whole Body Dose (Effective) limits (one calendar year) Category of Worker Nuclear Part D&G Employees Ontario Power Generation Employees Contract and Building Trades Union Employees Nuclear Energy Workers (NEW) NEW with a lifetime whole body dose greater than 500 msv (50 rem) 20 msv (2 rem) 20 msv (2 rem) 40 msv (4 rem) 10 msv (1 rem) 10 msv (1 rem) Not applicable Non-New 0.5 msv (0.050 rem) 0.5 msv (0.05 rem) 0.5 msv (0.050 rem) Whole Body Dose (Effective) limits (rolling 5 calendar years) NEW 50 msv (5 rem) 90 msv (9 rem) 90 msv (9 rem) Action Levels: Surface Contamination Levels Field of application Action Level Observations CONTAMINATION CONTROL: Alpha or Beta-gamma surface contamination levels beyond limits in Zone kbq/m 2 (1 µci/m 2 ) (beta-gamma); 3.7 kbq/m 2 (0.1 µci/m 2 ) (alpha) Total (fixed and loose) surface contamination levels greater than 37 kbq/m 2 (1 µci/m 2 ) (beta-gamma) or 3.7 kbq/m 2 (0.1 µci/m 2 ) (alpha) are found in Zone 1. The following documents require written notification of change: Document Title Document # Prior Notification? Radiation Protection N-PROG-RA-0013 Yes Controlling Exposure As Low As Reasonably Achievable N-STD-RA-0018 No Occupational Radiation Protection Action Levels for Power Reactor Operating Licenses N-REP Yes Dose Limits and Exposure Control N-PROC-RA-0019 Yes Recommendations and Guidance: CNSC regulatory guide G-129, Keeping Radiation Exposures and Doses As Low As Reasonably Achievable (ALARA) provides the licensee guidance for developing, implementing and maintaining a radiation protection program to ensure that exposures will be ALARA. RADIATION PROTECTION Licence Conditions e-doc Page 75 of 142

348 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 CNSC regulatory guide G-228 Developing and Using Action Levels provides the licensees guidance for developing ALs in accordance with the General Nuclear Safety and Control Regulations and section 6 of the Radiation Protection Regulations. The licensee should conduct a documented review and, if necessary, revise the ALs specified above at least once every five years in order to validate their effectiveness. The results of such reviews should be provided to CNSC staff. RADIATION PROTECTION Licence Conditions e-doc Page 76 of 142

349 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA CONVENTIONAL HEALTH AND SAFETY The Safety and Control Area Conventional Health and Safety covers the implementation of a program to manage workplace safety hazards and to protect personnel and equipment. Performance Objective: Conventional health and safety work practices and conditions achieve a high degree of personnel safety. 8.1 Conventional Health and Safety Program Licence Condition 8.1: The licensee shall implement and maintain a conventional health and safety program. Preamble: The Class I Nuclear Facilities Regulations require that a licence application contain the proposed worker health and safety policies and procedures. NPPs in Ontario are regulated by the Ontario Occupational Health and Safety Act and the Labour Relations Act. Compliance Verification Criteria: The licensee has the prime responsibility for safety at all times. This responsibility cannot be delegated or contracted to another organization or entity. The licensee shall ensure that contractors and other organizations present on site are informed of and uphold their roles and responsibilities related to conventional health and safety. OPG s documents N-PROG-RA-0012 Fire Protection and NK38-LIST , Application of CSA N to Structures, System and Components for Darlington Nuclear may identify specific SSCs in the protected area or exclusion zone to which the requirements of CSA N293 Fire Protection for CANDU Nuclear Power Plants are not applied, in which case the requirements of the National Building Code of Canada and National Fire Code shall be applied. See LC 10.2 for version control of CSA N293. The following documents require written notification of change: Document Title Document # Prior Notification? Work Protection N-PROG-MA-0015 No Health and Safety Policy OPG-POL-0001 No Health and Safety Management System Program OPG-PROG-0010 No Respiratory Protection OPG-PROC No Fire Protection N-PROG-RA-0012 Yes CONVENTIONAL HEALTH AND SAFETY Licence Conditions e-doc Page 77 of 142

350 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document Title Document # Prior Notification? Application of CSA N to Structures, System and Components for Darlington Nuclear Recommendations and Guidance: NK38-LIST It is expected that OPG will apply the Ontario Building and Fire Codes to SSCs within the exclusion zone but external to the protected area. For fire protection, OPG s documents N-PROG-RA-0012 Fire Protection and NK-38-LIST Application of CSA N293 to Structures, Systems and Components for Darlington Nuclear may identify specific SSCs in the exclusion zone to which the requirements of CSA N293 are applied. No CONVENTIONAL HEALTH AND SAFETY Licence Conditions e-doc Page 78 of 142

351 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA ENVIRONMENTAL PROTECTION The safety and control area Environmental Protection covers programs that identify, control, and monitor all releases of radioactive and hazardous substances and the effects on the environment from facilities or as the result of licensed activities. Performance Objective(s) The environment and the health and safety of persons are protected by the licensee taking all reasonable precautions, including identifying, controlling and monitoring the release of nuclear substances and hazardous substances to the environment. 9.1 Environmental Protection Program Licence Condition 9.1: The licensee shall implement and maintain an environmental protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within 7 days. Preamble: The Class I Nuclear Facilities Regulations set out requirements related to environmental protection that must be met by the applicant. The General Nuclear Safety and Control Regulations require every licensee to take all reasonable precautions to protect the environment and to control the release of radioactive nuclear substances or hazardous substances within the site of the licensed activity and into the environment as a result of the licensed activity. The Radiation Protection Regulations prescribe the radiation dose limits for the general public of 1 msv per calendar year. CNSC Regulatory Policy, P-223 Protection of the Environment describes the principles and factors that guide the CNSC in regulating the development, production and use of nuclear energy and the production, procession and use of nuclear substances, prescribed equipment and prescribed information in order to prevent unreasonable risk to the environment in a manner that is consistent with Canadian environmental policies, acts and regulations and with Canada s international obligations. Derived Release Limits: Derived Release Limits (DRLs) are calculated or derived using environmental transfer modeling that describes transfer of radioactive materials through environmental pathways to humans. DRLs are required for the purpose of protecting members of the public from unreasonable risk resulting from releases of radionuclides into the environment from the normal operation of the licensed facility. ENVIRONMENTAL PROTECTION Licence Conditions e-doc Page 79 of 142

352 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The release of hazardous substances is regulated by the CNSC as well as both the Ontario Ministry of Environment (MOE) and Environment Canada (EC) through various acts and regulations. Action Levels: OPG has set Environmental Action Levels (EAL) and related parameters, to provide early warnings of any actual or potential losses of control of the Environmental Protection Program. EALs are precautionary levels and are set far below the actual DRLs. EALs are designed to alert licensees before DRLs are reached. They are required by regulations to be specific doses of radiation or other parameter that, if reached, may indicate a loss of control of the licensee s Environmental Protection Program. Compliance Verification Criteria: The licensee shall implement and maintain programs to ensure environmental protection. These programs shall comply with the requirements set out in: CNSC regulatory document REGDOC Environmental Protection Policies, Programs and Procedures; CSA standard N288.1 Guidelines for calculating derived release limits for radioactive material in airborne and liquid effluents for normal operation of nuclear facilities; CSA standard N288.4 Environmental monitoring program at Class I nuclear facilities and uranium mines and mills; CSA standard N288.5 Effluent Monitoring Programs at Class I nuclear facilities and uranium mines and mills; and CSA standard N288.6 Environmental Risk Assessments at Class I nuclear facilities and uranium mines and mills. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CNSC Environmental Protection Policies, REGDOC Programs and Procedures CSA CSA CSA CSA Guidelines for calculating derived release limits for radioactive material in airborne and liquid effluents for normal operation of nuclear facilities Environmental monitoring program at Class I nuclear facilities and uranium mines and mills Effluent Monitoring Programs at Class I nuclear facilities and uranium mines and mills Environmental Risk Assessments at Class I nuclear facilities and uranium mines and mills N Update no N N N OPG's governing documents OPG-POL-0021 Environmental Policy and N-PROG-OP-0006 Environmental Management are key documents of the Environmental protection program. ENVIRONMENTAL PROTECTION Licence Conditions e-doc Page 80 of 142

353 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Effluent Monitoring The licensee shall ensure effluent monitoring for nuclear and hazardous substances is designed, implemented and managed to respect applicable laws and to incorporate best practices. The effluent monitoring program shall incorporate airborne and waterborne effluents. Measures to Control Releases of Nuclear and Hazardous Substances Nuclear Substances The licensee shall control radiological releases to ALARA, within the DRLs, and take action to investigate cause(s) and correct the cause(s) of increased releases. The licensee shall also monitor and report these releases. The licensee shall establish the DRLs in accordance with CSA standard N If any of the individual radionuclide DRLs are exceeded, or if the sum of individual releases (expressed as a fraction of the relevant DRL) exceeds unity, it indicates that the licensee is in non-compliance with the public dose limit of 1mSv/year as per the CNSC Radiation Protection Regulations. The DRLs are considered part of the licensing basis. Changes to these limits are subject to LC G.1. The DRLs for this facility are summarized in the table below. In the event of a discrepancy between these tables below and the licensee documentation upon which they are based, the licensee documentation shall be considered the authoritative source (assuming that the licensee has followed its own change control process). Release Category Radionuclide DRL(Becquerel/year) Air Tritium (HTO) 5.90E+16 Iodine (mixed fission products) Carbon-14(CO2) Noble Gases Particulate Gross Beta-Gamma (Co-60) Particulate Gross Alpha (Pu-239, Pu-240) 1.40E E E E E+11 Water Tritium 5.30E+18 Carbon-14 (as carbonate) Gross Alpha (Pu-239/Pu-240) Gross Beta-Gamma (P-32) 9.70E E E+13 These DRLs for radionuclides and radionuclide groups account for the most significant releases and are the focus of monitoring and reporting requirements. ENVIRONMENTAL PROTECTION Licence Conditions e-doc Page 81 of 142

354 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Hazardous Substances The licensee shall control hazardous substances releases according to the limits defined in the licensing basis in accordance with the applicable environmental compliance approvals and take action to investigate and correct the cause(s) of increased releases. Environmental Risk Assessment The environmental risk assessment (ERA) shall be updated periodically with the results from the environmental and effluent monitoring programs in order to confirm the effectiveness of any additional mitigation measures needed. The ERA update shall be completed by December 1, Environmental Action Levels For the licensee, the established EALs are ~10% of the DRLs for respective radionuclides released via airborne, waterborne or sewage discharge pathways. The EALs are considered part of the licensing basis. Changes to these limits are subject to LC G.1. The EALs for this facility are summarized in the table below. In the event of a discrepancy between these tables below and the licensee documentation upon which they are based, the licensee documentation shall be considered the authoritative source (assuming that the licensee has followed its own change control process). The current EALs for Darlington NGS are given in the following table: Release Category Radionuclide Action Levels: Gaseous releases (Becquerel/week) Air Tritium (HTO) 1.20E+14 Elemental Tritium (HT) 1.70E+15 Iodine 2.80E+9 Carbon Noble Gases* 8.90E+13 Particulate Gross Beta-Gamma) 1.30E+09 Release Category Radionuclide Action Levels: Liquid releases (Becquerel/month) Water Tritium (HTO) 4.30E+16 Carbon E+12 Gross Beta-Gamma 5.70E+11 * Units for noble gas action level are Bq-MeV/week ENVIRONMENTAL PROTECTION Licence Conditions e-doc Page 82 of 142

355 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The following documents require written notification of change: Document Title Document # Prior Notification? Environmental Policy OPG-POL-0021 No Environmental Management N-PROG-OP-0006 Yes Environment Manual NK38-MAN No Environmental Monitoring Programs N-PROC-OP-0025 Yes Hazardous Materials Management OPG-PROC-0126 No Monitoring of Nuclear and Hazardous Substances in Effluents Contaminated Lands and Groundwater Monitoring Management Derived Release Limits and Action Levels for Darlington Nuclear Generating Station Recommendations and Guidance: N-STD-OP-0031 N-PROC-OP-0044 NK38-REP Guiding principles and factors for CNSC staff consideration are also given in CNSC regulatory policy P-223 Protection of the Environment. It is recommended that the licensee provide to the CNSC a copy of the reports sent to the Ministry of the Environment and Environment Canada on hazardous releases. The licensee should review and, if necessary, revise and reissue the DRLs specified above at least once every five years. The next review of the DRLs is expected in 2016 and should be carried out in accordance with the 2014 version of N CNSC staff use the criteria set out in the CNSC guidance document G-228 Developing and Using Action Levels as guidance to help assess the adequacy of EALs established by the licensee. The licensee should review and, if necessary revise the EALs specified above at least once every five years in order to validate their effectiveness. No No Yes ENVIRONMENTAL PROTECTION Licence Conditions e-doc Page 83 of 142

356 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA EMERGENCY MANAGEMENT AND FIRE PROTECTION The safety and control area Emergency Management and Fire Protection covers emergency plans and emergency preparedness programs that exist for emergencies and for non-routine conditions. This area also includes any results of participation in exercises. Performance Objective(s) The licensee is ready to respond effectively to any fire or emergency situation Emergency Preparedness Program Licence Condition 10.1: The licensee shall implement and maintain an emergency preparedness program. Preamble: The Class I Nuclear Facilities Regulations require that a licence application contain information on the licensee s proposed mitigating measures for on-site and off-site events. This includes measures to prevent or mitigate the effects of accidental releases of nuclear and hazardous substances to the environment, to protect the health and safety of persons, to ensure the maintenance of national security, as well as measures to assist off-site planning authorities regarding an accidental release for: - planning and preparing to limit the effects; - notification; - reporting of information during and after; - assisting off-site authorities with dealing with effects; and - testing the implementation of the measures to prevent or mitigate the effects. As part of the emergency preparedness program, the licensee shall have a public information program consistent with CNSC regulatory document RD/GD-99.3 Public Information and Disclosure. This is addressed in licence condition G.6. The licensee also has processes in place to ensure business continuity in the event of an emergency (see LC 2.1). In addition to the nuclear emergency plan, the licensee maintains a set of emergency operating procedures and abnormal plant operating procedures. This aspect is covered under licence condition 3.1. A security response to malevolent acts is governed by a separate plan under OPG s Nuclear Security program (licence condition 12.1) but provisions of the licensee s site security report apply to any associated potential threat of release of radioactive material - for example, the need for off-site notification, situation updates and confirmation of any radioactive releases. EMERGENCY MANAGEMENT AND FIRE PROTECTION Licence Conditions e-doc Page 84 of 142

357 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Liquid release response and radioactive materials transportation emergency response plan are also governed by separate plans (licence conditions 9.1 and 14.1, respectively). Compliance Verification Criteria: The licensee shall implement and maintain programs to ensure emergency preparedness. These programs shall comply with the requirements set out in CNSC regulatory document REGDOC Nuclear Emergency Preparedness and Response. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CNSC Nuclear Emergency Preparedness and Response REGDOC The licensee shall complete the transition to compliance with REGDOC by December 31, The emergency program consists of a description to cope with accidental releases. This program encompasses both emergency preparedness and emergency response measures. It ensures that appropriate emergency response capabilities are developed and maintained available for use. The emergency preparedness program consists of: basis for emergency planning; personnel selection and qualification; emergency preparedness and response organizations; staffing levels; emergency training, drills and exercises; emergency facilities and equipment; emergency procedures; assessment of emergency response capability; assessment of accidents; activation and termination of emergency responses; protection of facility personnel and equipment, interface with off-site organizations; recovery program; public information program; and public education program. The licensee s Consolidated Nuclear Emergency Plan (CNEP) deals with emergency situations that could endanger the safety of on-site staff, the environment and the public. It is predominantly conceived to deal with releases of radioactive materials from fixed facilities and to outline interfaces with the Provincial Nuclear Emergency Response Plan (PNERP). The licensee shall maintain equipment, procedures and staff to support off- site response activities for an accidental release. Infrastructures defined within the PNERP may be used in planning and response to virtually all emergencies. The licensee s Nuclear Emergency Plan also represents a basis for controlling changes and modifications to the licensee s nuclear emergency preparedness program. EMERGENCY MANAGEMENT AND FIRE PROTECTION Licence Conditions e-doc Page 85 of 142

358 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 OPG is required to conduct Emergency Exercises and Drills as described in the CNEP. Drills and/or exercises are required at least annually in most areas. The drill and exercise program details the requirements for corporate exercises, testing of drill and exercise objectives, and coordination with non- OPG facilities. Participation by municipal and provincial emergency response groups is scheduled by mutual agreement. The licensee implements and maintains a Nuclear Pandemic Plan, to support minimum shift complement staffing and makes provisions should a labour dispute arise by implementing and maintaining strike contingency documentation, Guideline for Maintaining Staff in Key Positions When Normal Station Access is Impeded (refer to LC 2.2). The licensee shall provide the necessary resources and support to provincial and municipal authorities in implementing the provincial and municipal plans to do the following, or the licensee shall do the following: ensure that a sufficient quantity of iodine thyroid blocking (ITB) agents are pre-distributed, to all residences, businesses and institutions within the primary zone, together with instructions on their proper administration; ensure that a sufficient quantity of ITB agent is pre-stocked and available within the secondary zone to the extent practicable. This pre-stocked inventory of ITB agents shall be located so that it can be promptly and efficiently obtained by, or provided to, members of the public with particular consideration to sensitive populations such as children and pregnant women; ensure that pre-distributed and pre-stocked ITB agents are maintained within their expiry date; ensure that pre-distribution plans are supported by a robust, ongoing, and cyclical public education program; and ensure that public emergency preparedness information is provided to all residences, businesses and institutions within the primary zone and readily available to the general public, including online. The following document requires WN of change: Document Title Document # Prior Notification? Consolidated Nuclear Emergency Plan N-PROG-RA-0001 Yes Recommendations and Guidance: The licensee should provide emergency communications outlining what surrounding community residents need to know and do before, during and after a nuclear emergency. Information should be in plain language, readily accessible and include the following: how the public is notified of an emergency; what protective actions may be required during an emergency; what the public is expected to do, and why, when directed to take protective actions; what the public can do now to be better prepared for an emergency; and where can the public get more information on emergency plans. Regarding the distribution of ITB agents, recognizable locations with credible persons within the community, such as fire stations, police stations and pharmacies should be considered in the selection of pre-stocking locations. EMERGENCY MANAGEMENT AND FIRE PROTECTION Licence Conditions e-doc Page 86 of 142

359 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Fire Protection Program Licence Condition 10.2: The licensee shall implement and maintain a fire protection program. Preamble: Licensees require a comprehensive Fire Protection Program (FPP) to ensure the licensed activities do not result in unreasonable risk to the health and safety of persons and to the environment due to fire and to ensure that the licensee is able to efficiently and effectively respond to emergency fire situations. Fire protection provisions, including response, are required for the design, construction, commissioning, operation, and maintenance nuclear facilities, including structures, systems, and components (SSCs) that directly support the plant and the protected area. External events such as an aircraft crash or threats are addressed by licence condition Compliance Verification Criteria: The licensee shall implement and maintain programs to ensure fire protection. These programs shall comply with the requirements set out in CSA standard N293 Fire Protection for CANDU Nuclear Power Plants. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CSA Fire Protection for CANDU Nuclear Power Plants N Fire Protection The licensee shall assess the Fire Hazard Assessment and Fire Safe Shutdown Analysis revisions against the requirements of the CSA N293 and provide a justification of any non-conformances found and development a plan for the execution of corrective actions to address the identified gaps. As required by CSA N293, the licensee shall ensure that a qualified third party performs a plant condition inspection annually and an FPP audit every three years. The resulting inspection and audit reports shall be submitted to CNSC staff. Fire Response In accordance with N293, the licensee shall arrange for third party audits of one industrial fire brigade fire drill once every two years. The purpose of a Third Party Audit is to provide an in-depth analysis of the Industrial Fire Brigade s (IFB) fire response performance against applicable regulatory criteria. A fire response is a planned, coordinated and controlled activity to provide emergency response to a fire. EMERGENCY MANAGEMENT AND FIRE PROTECTION Licence Conditions e-doc Page 87 of 142

360 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 An independent third party auditor is required to be an expert in their discipline, normally firefighting and qualified through specific education and relevant experience. The third party auditor is required to be independent or at arm s length from the facility to ensure total impartiality. The review shall be of sufficient depth and detail that the reviewer can attest with reasonable confidence on the competencies of the IFB at the facility. The following document requires WN of change: Document Title Document # Prior Notification? Fire Protection N-PROG-RA-0012 Yes Recommendations and Guidance: The Nuclear Energy Institute in NEI Guidance for Post Fire Safe Shutdown Circuit Analysis is used by CNSC staff to help determine the adequacy of safe shutdown electrical circuit analysis. The results of the Third Party Audit report will typically consist of a report which compares the requirements of the applicable codes and standards against the implementation of the FPP or the Fire Response exercised (based on the scope of the audit). The report should identify any non-compliance and formulate a conclusion if the licensee s FPP or IFB meets the requirements of N293. As a guideline the report should provide sufficient detail to support the conclusion and to convey that the requirements of CSA 293 are met. As a minimum, the documentation for a Third Party Audit should include: Scope and objective of the review; A list of applicable codes and standards; Summary of the review methodology, including areas and documents reviewed; Detailed observations or issues that have been identified; Conclusion should identify whether the FPP or the IFB response meets applicable requirements, achieves the FPP or IFB response objectives; Summary of any non-compliance, recommendations (if any) and the corrective action plan; and The report to be signed by the person taking responsibility for the review. EMERGENCY MANAGEMENT AND FIRE PROTECTION Licence Conditions e-doc Page 88 of 142

361 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA WASTE MANAGEMENT The safety and control area Waste Management covers internal waste-related programs that form part of the facility s operations up to the point where the waste is removed from the facility to a separate waste management facility. This area also covers the planning for decommissioning. Performance Objective(s) There is full development, implementation and auditing of a facility- and waste stream- specific waste management program to control and minimize the volume of nuclear waste generated by the licensed activity; waste management is included as a key component of licensee s corporate and safety culture; and a decommissioning plan is maintained Waste Management Program Licence Condition 11.1: The licensee shall implement and maintain a waste management program. Preamble: The General Nuclear Safety and Control Regulations require that a licence application contain information related to the in-plant management of radioactive waste or hazardous waste resulting from the licensed activities. The Class I Nuclear Facilities Regulations require that a licence application contain the proposed procedures for handling, storing, loading and transporting nuclear substances and hazardous substances. Compliance Verification Criteria: The licensee shall implement and maintain a program for waste management that includes strategies for waste minimization. Low and intermediate level waste shall be managed in accordance with CSA standard N292.3 Management of Low and Intermediate-Level Radioactive Waste. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CSA Management of Low and Intermediate- Level Radioactive Waste N WASTE MANAGEMENT Licence Conditions e-doc Page 89 of 142

362 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The licensee shall: characterize its waste streams and minimize the production of all wastes taking into consideration the health and safety of workers and the environment; integrate waste management programs as a key element of the facility s safety culture; and audit on a regular basis its program to maximize its efficiency. The following documents require written notification of change: Document Title Document # Prior Notification? Environmental Management N-PROG-OP-0006 No Waste Management N-PROC-OP-0043 No Segregation and Handling of Radioactive Wastes N-PROC-RA-0017 No Recommendations and Guidance: Additional guidance related to this LC can be found in CSA standard N292.2 Interim Dry Storage of Irradiated Fuel. With respect to the storage and management of spent nuclear fuel, the waste management practices should reflect the fundamental safety concerns related to criticality, exposure, heat control, containment and retrievability. Namely, the systems that are designed and operated should assure subcriticality, control radiation exposure, assure heat removal, assure containment and allow retrievability. WASTE MANAGEMENT Licence Conditions e-doc Page 90 of 142

363 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Program for Planning the Decommissioning of the Nuclear Facility Licence Condition 11.2: The licensee shall implement and maintain a decommissioning strategy. Preamble: The Class I Nuclear Facilities Regulations require that a licence application contain the proposed plan for decommissioning of the nuclear facility. The decommissioning plan includes strategies for the management of low and intermediate level waste, reactor and waste storage facility decommissioning, and the used fuel arising from the operation of the nuclear facility. Compliance Verification Criteria: CSA standard N294 Decommissioning of Facilities Containing Nuclear Substances provides direction on the decommissioning of licensed facilities and specifies requirements for the planning, preparation, execution and completion of decommissioning. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CSA Decommissioning of Facilities Containing Nuclear Substances N The following documents require written notification of change: Document Title Document # Prior Notification? Decommissioning Management System OPG-CHAR-0001 Yes Preliminary Decommissioning Plan - Darlington Nuclear Generating Station NK38-PLAN Yes The decommissioning plan shall be kept current to reflect any changes in the site or nuclear facility. The decommissioning plan shall be revised at a minimum every five years, unless specified otherwise by the Commission. OPG s NK38-PLAN Preliminary Decommissioning Plan Darlington Nuclear Generating Station will be revised and submitted to the CNSC by January 31, Recommendations and Guidance: CNSC regulatory document G-219 Decommissioning Planning for Licensed Activities provides guidance regarding the preparation of decommissioning plans for activities licensed by the CNSC. It also provides the basis for calculating the financial guarantees discussed in the regulatory document G-206 Financial Guarantees for the Decommissioning of Licensed Activities (further discussed under licence condition G.5) WASTE MANAGEMENT Licence Conditions e-doc Page 91 of 142

364 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA SECURITY The safety and control area Security covers the programs required to implement and support the security requirements stipulated in the Nuclear Security Regulations, the licence, orders, or expectations for the facility or activity. Performance Objective(s) Loss, theft or sabotage of nuclear material or sabotage of the licensed facility are prevented Nuclear Security Program Licence Condition 12.1: The licensee shall implement and maintain a security program. Preamble: The General Nuclear Safety and Control Regulations require that a licence application contain information related to site access control and measures to prevent loss or illegal use, possession or removal of the nuclear substance, prescribed equipment or prescribed information. The Class I Nuclear Facilities Regulations require that a licence application contain the proposed measures to prevent acts of sabotage or attempted sabotage at the nuclear facility. The Nuclear Security Regulations require that a licence application contain specific information related to nuclear security, stipulates the requirements for High-Security Sites, and contains specific requirements pertaining to the transportation of Category I, II or III nuclear material. The Nuclear Security Regulations require that a licensee of a high security site: maintain at all times a qualified onsite nuclear response force; obtain the applicable certifications, before issuing an authorization to a nuclear security officer; prevent unauthorized removal of nuclear material; prevent and detect unauthorized entry into a protected area or inner area; and prevent unauthorized entry of weapons and explosive substances into a protected area or inner area. The Nuclear Security Regulations require every licensee to: conduct, at least once every 12 months, a threat and risk assessment specific to a facility where it carries on licensed activities in order to determine the adequacy of its physical protection system; make modifications to its physical protection system, as necessary, to counter any credible threat identified as a result of the threat and risk assessment; keep a written record of each threat and risk assessment that it conducts and provide a copy of the written record, together with a statement of actions taken as a result of the threat and risk assessment, to the Commission upon request (within 60 days) after completion of the assessment. SECURITY Licence Conditions e-doc Page 92 of 142

365 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 CNSC regulatory document REGDOC describes how, when required by a CNSC licence or order, a trained and equipped on-site nuclear response force shall be established and deployed at a nuclear facility. Compliance Verification Criteria: The licensee shall implement and maintain programs to ensure security of the nuclear facility. These programs shall comply with the requirements set out in CNSC regulatory documents: REGDOC High Security Sites: Nuclear Response Force; REGDOC Site Access Security Clearance; RD-321 Criteria for Physical Protection Systems and Devices at High-Security Sites; RD-361 Criteria for Explosive Substance Detection, X-Ray Imaging and Metal Detection Devices at High-Security; and RD-363 Nuclear Security Officer Medical, Physical, and Psychological Fitness. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CNSC High Security Sites: Nuclear Response REGDOC Force CNSC Site Access Security Clearance REGDOC CNSC CNSC CNSC Nuclear Security Officer Medical, Physical, and Psychological Fitness Criteria for Physical Protection Systems and Devices at High-Security Sites Criteria for Explosive Substance Detection, X-Ray Imaging and Metal Detection Devices at High-Security Sites RD RD RD The licensee shall ensure the identified vital areas within the nuclear facility are protected against design basis threats and any other credible threat identified in their Threat and Risk Assessment documentation. The prime functions that must be maintained to prevent unacceptable radiological consequences are those of control, cool, and contain. The licensee shall maintain the operation, design and analysis provisions credited in the above assessments as required to ensure adequate engineered safety barriers for the protection against malevolent acts. The provisions for the protection against malevolent acts shall be documented as part of a managed sub-program or process within the management system. The licensee shall summarize changes in design, analysis or operational procedures that are credited for the protection against malevolent acts in the annual threat and risk assessment, and submit a copy to the Commission upon request. All detection devices shall be installed, operated and maintained in accordance with manufacturers specifications and meet the criteria in RD-321 and RD-361. SECURITY Licence Conditions e-doc Page 93 of 142

366 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The licensee shall, in accordance with RD-363, ensure that the required documentation and necessary medical, physical, and psychological certification of a person is obtained before authorizing that person to act as a nuclear security officer. The licensee shall implement measures for the purpose of preventing and detecting unauthorized entry into a protected area or inner area at a high-security site, including: Vehicle barriers and vehicle access control points; Perimeter intrusion detection systems and devices; Closed-circuit video systems/ devices for applications in a protected area or inner area; Security monitoring rooms; and Security monitoring room systems and devices. Licensee shall develop, implement and maintain a cyber-security program to protect against cyber-attacks on the critical cyber assets for nuclear safety, nuclear security, and emergency preparedness functions. The licensee s cyber-security program shall be implemented and maintained to protect the cyber-critical assets for nuclear safety, physical protection and emergency preparedness functions from cyber-attacks. The cyber-security program includes the following elements: roles and responsibilities; policies and procedures; staff training and awareness; overall approach to cybersecurity; configuration management; incident response and recovery; periodic self-assessments; security controls; and identification and classification of cyber-critical assets. The following documents require written notification of change: Document Title Document # Darlington Nuclear Generating Station Security Report 8300-REP Prior Notification? Nuclear Security N-PROG-RA-0011 Yes Transport Security Plan TRAN-PLAN No Threat and Risk Assessment NK38-REP No Security for Real-Time Process Computing Systems N-PROC-MP-0103 No Cyber Asset Identification for Real-time Process Computer Systems N-STI Yes No SECURITY Licence Conditions e-doc Page 94 of 142

367 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document Title Document # Cyber Security for Real-time Process Computing Systems N-STI Prior Notification? Significant Cyber Assets NK38-LIST No Recommendations and Guidance: CNSC REGDOC Security of Nuclear Substances: Sealed Sources provides security measures to prevent the loss, sabotage, illegal use, illegal possession or illegal removal of sealed sources. It also provides the same regarding transportation activities. OPG should provide a transition plan to meet the documents requirements and guidance. CNSC regulatory document G-274 Security Programs for Category I or II Nuclear Material or Certain Nuclear Facilities provides guidance for preparing, submitting and revising the Station Security Report. CNSC regulatory document G-208 Transportation Security Plans for Category I, II, or III Nuclear Material provides guidance to the licensee on how to prepare and submit a written transportation security plan. Guidance may be obtained in the IAEA Nuclear Security Series No. 4 Technical Guidance Engineering Safety Aspects of the Protection of Nuclear Power Plants Against Sabotage, IAEA Nuclear Security Series No.13, Recommendations Nuclear Security Recommendations on Physical Protection of Nuclear Material and Nuclear Facilities (INFCIRC/225/Revision 5), and IAEA Nuclear Security Series No. 17 Technical Guidance Computer Security at Nuclear Facilities. No SECURITY Licence Conditions e-doc Page 95 of 142

368 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA SAFEGUARDS AND NON-PROLIFERATION The safety and control area Safeguards and Non-Proliferation covers the programs required for the successful implementation of the obligations arising from the Canada/IAEA Safeguards Agreement, as well as all other measures arising from the Treaty on the Non-Proliferation of Nuclear Weapons. Performance Objective(s) Conformity with measures required by the facility to meet Canada s international safeguards obligations through: timely provision of accurate reports and information; provision of access and assistance to IAEA inspectors for verification activities; submission of annual operational information and accurate design information of plant structures, processes and procedures; development and satisfactory implementation of appropriate facility safeguards procedures; and demonstration of capability, as confirmed through CNSC onsite evaluations, to meet all requirements in support of physical inventory verifications of nuclear material by the IAEA Safeguards Program Licence Condition 13.1: The licensee shall implement and maintain a safeguards program. Preamble: Safeguards is a system of inspection and other verification activities undertaken by the IAEA in order to evaluate a Member State s compliance with its obligations pursuant to its safeguards agreements with the IAEA. The General Nuclear Safety and Control Regulations require the licensee to take all necessary measures to facilitate Canada s compliance with any applicable safeguards agreement, and defines reporting requirements for safeguards events. The Class I Nuclear Facilities Regulations require that a licence application contain information on the licensee s proposed measures to facilitate Canada's compliance with any applicable safeguards agreement. Canada has entered into a Safeguards Agreement and an Additional Protocol (hereafter referred to as safeguards agreements ) with the IAEA pursuant to its obligations under the Treaty on the Non- Proliferation of Nuclear Weapons (INFCIRC/140). The objective of the Canada-IAEA safeguards agreements is for the IAEA to provide assurance on an annual basis to Canada and to the international community that all declared nuclear materials are in peaceful, non-explosive uses and that there is no indication of undeclared nuclear materials or activities. This conclusion confirms that Canada is in compliance with its obligations under the following Canada-IAEA safeguards agreements: SAFEGUARDS Licence Conditions e-doc Page 96 of 142

369 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Agreement Between the Government of Canada and the International Atomic Energy Agency for the Application of Safeguards in Connection with the Treaty on the Non-Proliferation of Nuclear Weapons; and Protocol Additional to the Agreement Between Canada and the International Atomic Energy Agency for the Application of Safeguards in Connection with the Treaty on the Non-Proliferation of Nuclear Weapons. These are reproduced in information circulars INFCIRC/164, and INFCIRC/164/Add. 1. CNSC regulatory document RD-336, Accounting and Reporting of Nuclear Material, replaced AECB Rev 2, Reporting Requirements for Fissionable and Fertile Substances, on January 1, The scope of non-proliferation activities carried out under this licence is limited to tracking and reporting of foreign obligations and origins of nuclear material. Additionally, the import and export of controlled nuclear substances, equipment and information identified in the Nuclear Non-proliferation Import and Export Control Regulations require separate authorization from the CNSC, consistent with the General Nuclear Safety and Control Regulations. Compliance Verification Criteria: The licensee shall ensure that accounting and reporting of nuclear materials is carried out in accordance with CNSC regulatory document RD-336 Accounting and Reporting of Nuclear Material. Relevant documents that require version control: Source Document Title Document # Revision # Effective Date CNSC Accounting and Reporting of Nuclear Material RD According to Sections and of RD-336, the licensee is required to submit to the CNSC both a List of Inventory Items (LII) and a Physical Key Measurement Point Inventory Summary (P-KMPIS) within seven business days of a Physical Inventory Taking. However, based on initial experience, it has been determined that while the P-KMPIS will continue to be a mandatory document as per RD-336, LIIs will only be required upon request (e-doc ). To ensure the safeguards program enables Canada to meet its international safeguards obligations, the licensee shall: Provide the IAEA, an IAEA inspector, or a person acting on behalf of the IAEA, with such reasonable services and assistance as are required to enable the IAEA to carry out its duties and functions pursuant to a safeguards agreement. Grant prompt access at all reasonable times to all locations at the nuclear facility to an IAEA inspector, or to a person acting on behalf of the IAEA, where such access is required for the purposes of carrying on an activity pursuant to a safeguards agreement. In granting access, the licensee will provide health and safety services and escorts as required in order to facilitate activities pursuant to a safeguards agreement. Disclose to the Commission, to the IAEA, or to an IAEA inspector, any records that are required to be kept or any reports that are required to be made under a safeguards agreement. SAFEGUARDS Licence Conditions e-doc Page 97 of 142

370 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Provide such reasonable assistance to an IAEA inspector, or to a person acting on behalf of the IAEA, as is required to enable sampling and removal or shipment of samples required pursuant to a safeguards agreement. Provide such reasonable assistance to an IAEA inspector, or to a person acting on behalf of the IAEA, as is required to enable measurements, tests and removal or shipment of equipment required pursuant to a safeguards agreement. At the request of the Commission, or of a person authorized by the Commission, install safeguards equipment at the nuclear facility. Permit an IAEA inspector, or a person acting on behalf of the IAEA, to service safeguards equipment at the nuclear facility. Operate safeguards equipment at the nuclear facility in accordance with the methods and procedures specified by the IAEA. Provide the services required for the operation of the safeguards equipment at the nuclear facility, in accordance with the specifications of the IAEA. Not interfere with or interrupt the operation of safeguards equipment at the nuclear facility, or alter, deface or break a safeguards seal, except pursuant to a safeguards agreement. Implement measures to prevent damage to, or the theft, loss or sabotage of safeguards equipment or samples collected pursuant to a safeguards agreement or the illegal use, possession, operation or removal of such equipment or samples. Make and submit reports to the Commission on the inventory and transfer of fissionable and fertile substances in accordance with the regulatory document RD-336 Accounting and Reporting of Nuclear Material, or as otherwise stipulated in any regulatory document that replaces RD-336. Make such reports and provide such information to the Commission as are required to facilitate Canada's compliance with any applicable safeguards agreement. The licensee shall not make changes to operation, equipment or procedures that would affect the implementation of safeguards measures, except with the prior written approval of the Commission or CNSC staff as follows: Director, International Safeguards Division; Director General, Directorate of Security and Safeguards; Vice-President, Technical Support Branch; and Executive Vice-President and Chief Regulatory Operations Officer, Regulatory Operations Branch With respect to the implementation of safeguards measures, changes made by the licensee to operation, equipment or procedures as of the result of agreement between the licensee, the CNSC and the IAEA are considered routine. If a requested change would adversely impact Canada s compliance its safeguards agreements, CNSC staff does not have the authority to give approval, as this would violate the obligations arising from the Canada-IAEA safeguards agreement. SAFEGUARDS Licence Conditions e-doc Page 98 of 142

371 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The following documents require written notification of change: Document Title Document # Prior Notification? Nuclear Safeguards N-PROG-RA-0015 Yes Nuclear Safeguards Implementation N-STD-RA-0024 Yes Recommendations and Guidance: Guidance may be obtained from CNSC guidance document GD-336 Guidance for Accounting and Reporting of Nuclear Material. SAFEGUARDS Licence Conditions e-doc Page 99 of 142

372 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ SCA PACKAGING AND TRANSPORT The safety and control area Packaging and Transport covers programs for the safe packaging and transport of nuclear substances to and from the licensed facility. Performance Objective(s) All radioactive shipments leaving the site adhere to the Packaging and Transport of Nuclear Substances Regulations and the Transportation of Dangerous Goods Regulations Packaging and Transport Program Licence Condition 14.1: The licensee shall implement and maintain a packaging and transport program. Preamble: The Class I Nuclear Facilities Regulations require that a licence application contain information on the proposed procedures for transporting nuclear substances. Every person who transports radioactive material, or requires it to be transported, shall act in accordance with the requirements of the Transportation of Dangerous Goods Regulations (TDGR) and the Packaging and Transport of Nuclear Substances Regulations (PTNSR). The PTNSR and the TDGR provide specific requirements for the design of transport packages, the packaging, marking and labeling of packages and the handling and transport of nuclear substances. Compliance Verification Criteria: The licensee shall implement and maintain a packaging and transport program that will ensure compliance with the requirements of the TDGR and the PTNSR. The following documents require written notification of change: Document Title Document # Prior Notification? Radioactive Material Transportation W-PROG-WM-0002 No Radioactive Materials Transportation Emergency Response Plan N-STD-RA-0036 No Recommendations and Guidance: Not applicable to this LC. PACKAGING AND TRANSPORT Licence Conditions e-doc Page 100 of 142

373 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ NUCLEAR FACILITY-SPECIFIC 15.1 Tritium Removal Facility Operations Licence Condition: The licensee shall implement and maintain an operations program for the Tritium Removal Facility including a set of operating limits. Preamble: The Darlington NGS PROL authorizes OPG to operate the Tritium Removal Facility (TRF) housed in the Heavy Water Management Building on the site. Tritium is produced in the moderator and primary heat transport circuit of CANadian Deuterium Uranium (CANDU) reactors. The TRF is designed to reduce levels of radioactive tritium from these heavy water (deuterium oxide, D 2 O) inventories. This in turn reduces the potential radiation exposure of licensee staff and reduces releases to the environment. The systems of the TRF have been designed to perform three primary functions: tritium extraction, tritium immobilization/storage and tritium clean up. In addition to reducing tritium levels in Darlington NGS heavy water inventories, the TRF is also used to reduce tritium levels in heavy water inventories from the other Canadian NPPs. Compliance Verification Criteria: The licensee shall ensure that the operation of the TRF is addressed in the operating policies and principles (OP&Ps). The licensee shall ensure that the concentration of tritium in any tritiated deuterium oxide feedstock to be treated in the Darlington TRF does not exceed 1.26 TBq/kg D 2 O (34 Ci/kg D 2 O). D-INS , "TRF Planned Outage Management" is specific to managing outages in the TRF. While this document takes its authority from N-PROC-MA-0013, Planned Outage Management (listed under LC 6.1), the document also takes into account the specific nature and timing of TRF outages, allowing OPG to achieve a higher degree compliance with their own documentation. Condition assessments of the TRF conducted by the OPG indicate that detritiation capacity may be extended to 2055 to match the end of extended life of Darlington NGS, instead of the currently expected end of design life in The decision to extend TRF life is expected by SITE SPECIFIC Licence Conditions e-doc Page 101 of 142

374 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The following documents require written notification of change: Document Title Document # Prior Notification? Darlington Nuclear Operating Policies and Principles NK38-OPP Yes TRF Planned Outage Management D-INS No Heavy Water Management Plan N-PROG-AS-0008 No Recommendations and Guidance: Not applicable to this LC. SITE SPECIFIC Licence Conditions e-doc Page 102 of 142

375 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Refurbishment - Return to Service Licence Condition: The licensee shall implement a return to service plan for refurbishment. Preamble: Reactor units will be removed from service for replacement of internal reactor components and other activities that can only be accomplished in a refurbishment outage. Refurbishment outages differ from planned maintenance outages in that the duration is longer, work activities are more complex, and the configuration of the unit is significantly altered to allow work to proceed. Return to service (RTS) involves returning the reactor and associated nuclear and non-nuclear systems to commercial operation. The licensee must demonstrate that all regulatory requirements have been met and that the associated work has been done to the satisfaction of the CNSC. Compliance Verification Criteria: The licensee s Return to Service Program Management Plan describes the processes, procedures, and organization that will be used during the Darlington Refurbishment Project to manage the modification and restart activities. This plan identifies OPG internal restart control hold points (RCHPs) that will be the focus of the run-up activities leading up to full power and unit availability for commercial operation. For each RCHP, the licensee will produce a Completion Assurance Document (CAD) which provides confirmation that all pre-requisites, modification commissioning, testing, system restart activities and commitments have been addressed to the allow OPG s release of the specific hold point. The CAD will include references to the following reports with detail applicable to the specific activities associated with the RCHP: Construction Completion Declarations o Confirm that construction and installation activities are sufficiently complete and that it is safe to proceed with modification commissioning and re-start testing on the affected SSCs Modification Commissioning Reports o Confirm that new or modified SSCs meets the design specifications and performance criteria System Available for Service Packages o Confirm that individual systems, or a group of systems, can be credited to safety and reliability perform their design functions Re-start Reports o Confirm that non-modified SSCs are ready to return to normal operation after the refurbishment outage Unit Readiness for Service Packages o Confirm that each unit is returned to service in a manner which demonstrates that new and existing plant SSCs conform to the defined physical, function, performance, safety and control requirements SITE SPECIFIC Licence Conditions e-doc Page 103 of 142

376 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 The following documents require written notification of change: Document Title Document # Darlington Refurbishment Return to Service Program Management Plan NK38-NR-PLAN , Sheet: 0003 Prior Notification? No Recommendations and Guidance: Not applicable to this LC. SITE SPECIFIC Licence Conditions e-doc Page 104 of 142

377 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Integrated Implementation Plan Licence Condition: The licensee shall implement the Integrated Implementation Plan. Preamble: The Integrated Implementation Plan (IIP) contains commitments, including the timeframes for implementation, resulting from the Environmental Assessment (EA) for Darlington Refurbishment and Continued Operations as well as the Darlington Integrated Safety Review (ISR). These commitments include, but are not limited to: Replacement of fuel channels, feeders, calandria tubes, and end fittings; Installation of two auxiliary shutdown cooling pumps per unit; Installation of a containment filtered venting system; Provision of shield tank overpressure protection; Enhancements to the powerhouse steam venting system; Installation of a 3 rd emergency power generator; Provision of an alternate, independent supply of water as an emergency heat sink; Implementation of safety related recommendations from component condition assessments; and Implementation of mitigation and follow up activities stemming from the Environmental Assessment conducted under the Canadian Environmental Assessment Act, Compliance Verification Criteria: In implementing the commitments identified in the IIP, OPG committed to submitting to CNSC staff formal progress reports on the status of all IIP commitments on an annual basis by March 31st of each year during the licence period. Any proposed non-intent changes to the IIP shall be subject to the licensee s IIP Change Control Process Principles (e-doc ), as further developed in Darlington NGS Integrated Implementation Plan (IIP) Change Control and Closeout Process, N-INS The following documents require written notification of change: Document Title Document # Prior Notification? Darlington NGS Integrated Implementation Plan (IIP) Change Control and Closeout Process Recommendations and Guidance: Not applicable to this LC. N-INS No SITE SPECIFIC Licence Conditions e-doc Page 105 of 142

378 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/ Regulatory Hold Points for Return to Service and Continued Operations Licence Condition: The licensee shall obtain the approval of the Commission, or consent of a person authorized by the Commission, prior to the removal of established regulatory hold points. Preamble: CNSC selected four (4) regulatory hold points for which CNSC approval will be sought prior to proceeding to the subsequent commissioning phase. These hold points require regulatory verification to confirm operational readiness of the plant safety systems to satisfy regulatory requirements for staged progress through the commissioning phases up to full power operation. These regulatory hold points are consistent with the regulatory approach described in RD-360, Life Extension of Nuclear Power Plants. Compliance Verification Criteria: The licensee shall seek approval of the Commission or consent of a person authorized by the Commission prior to the removal of the following regulatory hold points for the return to service of each unit. The regulatory hold points that mark the completion of the commissioning phases are as follows: 1. Prior to Fuel Load - Phase A 2. Prior to removal of Guaranteed Shutdown State - Phase B 3. Prior to exceeding 1% Full Power - Phase C 4. Prior to exceeding 35% Full Power - Phase D For each of the regulatory hold points, the licensee shall submit Completion Assurance Documents (CAD). In addition to these CAD s, the licensee shall submit CADs following sustained operation at 100% full power that will specify activities that were completed between 35% and 100% full power. Each CAD shall present evidence that all pre-established conditions for removal have been met. Prior to GSS removal, all plant personnel who work on the refurbished reactor shall have completed update training appropriate to the knowledge and skill requirements of the applicable position covering the changes to facility systems, equipment and procedures made during refurbishment. For each ANO, CRSS and SM this includes, at a minimum: Principles of reactor operation with new fuel; Principles of nuclear safety relevant to the operation of the reactor unit with new fuel; Operating constraints and limits associated with the operation of the reactor unit with new fuel; The initial approach to criticality and power increase until control by the reactor regulating system is established, including the systems and equipment required and their operation; and Changes in fuel composition and core reactivity until reaching equilibrium fuel conditions. SITE SPECIFIC Licence Conditions e-doc Page 106 of 142

379 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 This training shall include formal knowledge and performance evaluations that confirm and document that, at the time of GSS removal, the person has the required knowledge and skills to perform the duties of the applicable position. Low power testing (Phase C) shall be carried out at the lowest possible power level, with a maximum of 1% of full power. Pre-requisites for Release of Hold Points: Pre-requisites for Fuel Load 1. All IIP commitments required prior to fuel load are complete; 2. All SSCs required for safe operation beyond fuel load are available for service; 3. Staffing levels to safety operate the unit are adequate; 4. Specified operating procedures for fuel load have been formally validated; 5. Specified training for fuel load is complete and staff qualified; 6. Specified SSCs meet the quality and completion requirements of CSA N286; 7. All non-conformances and open items identified leading up to the fuel load are addressed; and 8. Verification by CNSC staff that all construction, commissioning, re-start, and available for service activities required prior to fuel load have been successfully completed. With respect to pre-requisite #3: Staffing levels refers to a sufficient number of qualified workers present at all times to ensure the safe operation of the nuclear facility and to ensure adequate emergency response capability. The licensee should have adequate staff available such that absences due to vacation, sick leave and training do not cause violations of the minimum shift complement levels. Pre-requisites for GSS Removal 1. All IIP commitments required prior to GSS removal are complete; 2. All SSCs required for safe operation beyond GSS removal are available for service; 3. Specified operating procedures for GSS removal have been formally validated; 4. Specified training for GSS removal is complete and staff qualified; 5. All non-conformances and open items identified leading up to GSS removal are addressed; 6. Specified SSCs meet the quality and completion requirements of CSA N286; and 7. Verification by CNSC staff that all construction, commissioning, re-start, and available for service activities required prior to GSS removal have been successfully completed. Pre-requisites for Reactor Power Increases Prior to exceeding 1% Full Power 1. All IIP commitments required prior to increasing reactor power are complete; 2. All SSCs required for safe operation are available for service; 3. Specified operating procedures have been formally validated; 4. Specified training is complete and staff qualified; 5. All non-conformances and open items identified leading up to reactor power increases are addressed; 6. Specified SSCs meet the quality and completion requirements of CSA N286; and 7. Verification by CNSC staff that all construction, commissioning, re-start, and available for service activities required prior to increasing reactor power have been successfully completed. SITE SPECIFIC Licence Conditions e-doc Page 107 of 142

380 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Pre-requisites for Reactor Power Increases Prior to exceeding 35 % Full Power 1. All IIP commitments required prior to normal operation are complete; 2. All SSCs required for safe operation are available for service; 3. Specified operating procedures have been formally validated; 4. Specified training is complete and staff qualified; 5. All non-conformances and open items identified leading up to reactor power increases are addressed; 6. Specified SSCs meet the quality and completion requirements of CSA N286; and 7. Verification by CNSC staff that all construction, commissioning, re-start, and available for service activities required prior to increasing reactor power have been successfully completed. The licensee s criteria for release of hold points are contained in Nuclear Refurbishment Unit Readiness for Service, NK38-INS The following documents require written notification of change: Document Title Document # Prior Notification? Nuclear Refurbishment Unit Readiness for Service NK38-INS Yes Recommendations and Guidance: Not applicable to this LC. SITE SPECIFIC Licence Conditions e-doc Page 108 of 142

381 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 APPENDIX A Administrative Processes This appendix describes the administrative process necessary for managing the LCH, such as delegation of authority, change control, reporting to Commission, document version control, record-keeping and dispute resolution. A.1 Delegation of Authority Throughout the licence, the statement or consent of a person authorized by the Commission reflects to whom the Commission may delegate certain authority (hence consent ) to CNSC staff. Unless otherwise specified, the delegation of authority by the Commission to act as a person authorized by the Commission is only applied to the incumbents of the following positions: DPRR Regulatory Program Directors; Director General (DG), Directorate of Power Reactor Regulation (DPRR); and Executive Vice-President and Chief Regulatory Operations Officer, Regulatory Operations Branch. Delegations of authority are recorded in the Commission Record of Proceedings, Including Reasons for Decision, but they may be documented elsewhere by the Commission. A.2 LCH Change Control The CNSC will apply a change control process, with clear procedures to the LCH in accordance with the CNSC Management System to ensure that: preparation and use of the LCH is properly controlled; all referenced documents are correctly identified and maintained; changes are conducted in accordance with CNSC Regulatory Policy P-299 entitled Regulatory Fundamentals ; and procedures for modifying the LCH are followed. The licensing basis is defined at licence issuance/renewal. The principles for achieving compliance with the licensing basis will not change greatly during the licence period. However, changes to the LCH may be requested by either CNSC staff or the licensee, which impact the specific details of these principles in order to achieve greater clarity and achieve an equivalent level of safety. Whenever CNSC staff request a change to the LCH the licensee will be consulted. The following are examples of LCH change requests: Operating experience with the LCH may reveal instances where the Compliance Verification Criteria text may leave room for varying interpretation between the licensee and CNSC staff. Such instances would require further clarity. The transitional provisions for new codes, standards and regulatory documents, which are documented in the compliance verification criteria, may be revised. Assuming that the implementation plan was part of the licence application (and hence part of the licensing basis), APPENDIX A Administrative Processes e-doc Page 109 of 142

382 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 such a development would result in a LC non-compliance (reportable in S-99 as such) and CNSC staff modifying the date and taking any necessary other actions, including possible enforcement action, based on the time at risk. As a result of a licensing decision being issued by the Commission. (i.e., amendment to the licence). One example is the inclusion of, or revision to, regulatory documents, codes and standards. These amendments may involve amending the CVC in the LCH. An Environmental Assessment relevant to the licensed facility may lead to licensee commitments that should be recorded as CVC in the LCH. Changes to recommendations and guidance, such as the inclusion or amendment of CNSC regulatory guidance documents or recommendations. For licensee-requested changes to the LCH, that include the licensee s alternative cost effective approach where applicable, CNSC staff will review the proposed changes, as required by CNSC Regulatory Policy P-242, Considering Cost-benefit Information, and decide if the LCH should be modified. The CNSC document Risk Informed Approach for the CNSC Power Reactor Regulatory Program Basis Document contains information on how to consider cost benefit information in licensee submissions. The Director General, Directorate of Power Reactor Regulation, has the authority to approve changes to the LCH. In order to effect a modification to the LCH, the CNSC Regulatory Program Officer will: initiate a request using the Document Change Request (DCR) Form; liaise with the Power Reactor Licensing and Compliance Integration Division (PRLCID); coordinate the review by the identified Subject Matter Expert; consult licensee, as required; obtain endorsement from the Regulatory Program Director; obtain approval and signature from the DG of DPRR; update the LCH; and distribute the updated version of the LCH. If the change involves the revision of a WN document, the Regulatory Program Division will also update the registry it uses to track the version history and e-doc number of the WN documents. The Power Reactor Licensing and Compliance Integration Division (PRLCID) will: assess if the request is generic to the Power Reactor Regulatory Program; endorsement of the change by the PRLCID Director; and update the generic LCH, if required. A.3 Reporting to the Commission Changes to the LCH will be tracked through the DCR. CNSC staff will summarize all the changes made to the LCH and report them to the Commission for information in the CNSC staff's annual report entitled "Integrated Safety Assessment of Canadian Nuclear Power Plants. This report is presented annually in a APPENDIX A Administrative Processes e-doc Page 110 of 142

383 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 public proceeding of the Commission at a scheduled date. The report should emphasize instances where the CVC were relaxed (such as modifying target dates as discussed above). CNSC staff will review the content of the LCH annually to ensure that the collective changes made to the document did not result in an unauthorized change of scope. For example, CNSC staff will ensure that the LCH continues to maintain a clearly-documented set of compliance verification criteria and that any changes remain within the licensing basis. The results of this review should also be reported to the Commission annually. A.4 Document Control and Approval/Consent A.4.1 Document Control and Oversight Whenever proposed changes to version control documents are accepted by the CNSC, the compliance verification criteria in the LCH must be updated (per the LCH change control process described in Appendix A.2). The Director General, Directorate of Power Reactor Regulation, has the authority to make the changes to the compliance verification criteria as long as the changes remain within the licensing basis. The CNSC uses a risk-informed process to determine the type of regulatory oversight that is appropriate for each licensee document in the licensing basis. WN documents do not require prior Commission approval or CNSC staff consent of changes, but the changes are still reviewed by CNSC staff. Changes to WN documents are not tracked through the LCH; they are tracked by the CNSC licensing division using the registry described in Section A.2. A.4.2 Approval/Consent of Changes (other than document changes) CNSC facility operating licences may include LCs that address situations where the licensee has to apply to make, or at least provide notification before making, a change that is not linked to a specific document. The LCH may also specify similar mechanisms. These situations could include potential design, organizational, or operational changes. The LC or LCH could indicate that the change must be approved by the Commission. Alternately, the LC or LCH may indicate the circumstances under which consent for the change can be granted by a delegated authority. In some cases, the associated compliance verification criteria in the LCH may indicate specific criteria that the Commission and/or delegated authority would assess when considering the request for approval/consent. A.4.3 CNSC Review Criteria Related to Document Changes and Approvals/Consent For the approvals of document changes or other changes described above in Sections A.4.1 and A.4.2, the CNSC checks that the licensee submission includes the appropriate level of information with regards to the proposed changes or action, to the extent relevant: a summary description; an indication of the duration (temporary or permanent); a justification; any relevant supporting documentation; APPENDIX A Administrative Processes e-doc Page 111 of 142

384 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 an evaluation of the impact on health, safety, security, the environment and Canada s international obligations; and an evaluation to determine if the resultant effects remain within the limits defined by the licensing basis. The CNSC then assesses whether the following general criteria would be met for the proposed change/action: The proposed change or action will be made or done in accordance with licensee s quality assurance and change control processes, applicable design guides, design requirements, standards, operating documentation, regulatory documents, applicable safety principles and applicable safeguards agreement. Following the proposed change or action, the licensee remains in compliance with the requirements set out in the applicable laws, regulations and licence conditions, including appendices of the licence. The proposed change or action is in the safe direction. Following the proposed change or action: o o o the licensee remains qualified to carry out the licensed activity; the licensee has adequate provision for the protection of the health and safety of persons, protection of the environment, maintenance of national security and measures required to implement international obligations to which Canada has agreed; and the licensed activity remains within the limits defined by the licensing basis. (The above criteria can also apply when CNSC staff review a notification of a licensee change that was already made.) If the licensee s request is being assessed by a delegated authority and it is found that the request for change or action does not meet all of the above criteria, the delegated authority will address the situation with the licensee to determine if adjustments to the proposal can satisfy all the criteria. If not, consideration of the change must be turned from the delegated authority back to the Commission. A.5 Record Keeping A.5.1 Records Management The DCR and accompanying documentation will be archived in Records and referenced in the Revision History section of the LCH. Marked-up documents by the reviewers and any other supporting information will be kept in Records Office (File No. 2.01). Electronic communication related to the change, such as comments from reviewers will be stored in the CNSC's "e-access." A.5.2 Distribution A copy of the updated version of the LCH will be provided to the following: responsible Regulatory Program Director; responsible Site Office; responsible Administrative Assistant; and licensee s single point of contact. APPENDIX A Administrative Processes e-doc Page 112 of 142

385 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 A.6 Dispute Resolution In the event of disagreement on a proposed change to the LCH, staff and the licensee will attempt to resolve the issue. The following steps will be followed: a meeting with the appropriate parties, including Directors, will be scheduled by the Regulatory Program Officer; the rationale supporting the decision and the decision will be documented; and if any party is not satisfied with the decision, the disagreement will be brought to the next level of authority, Directors General or Vice-Presidents, as required. Any unresolved issue will be referred to the Commission. APPENDIX A Administrative Processes e-doc Page 113 of 142

386 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 APPENDIX B Glossary of Terms B.1 Acronyms The following is the list of acronyms used in the LCH: ADL AIA AL ALARA ASME CANDU CMD CNSC COG CSA CVC DBA DCR DG DPRR DRL EAL EQ GSS IAEA LCH LCMP NDE NEW NFPA NGS NPP OP&P OPEX OSR PCB PIP PRA PROL PSA RPD SAT SCA SOE SSCs Administrative Dose limits Authorized Inspection Agency Action Levels As Low As Reasonably Achievable American Society of Mechanical Engineers Canadian Deuterium Uranium Commission Member Document Canadian Nuclear Safety Commission CANDU Owners Group Canadian Standards Association Compliance Verification Criteria Design Basis Accident Document Change Request Director General Directorate of Power Reactor Regulation Derived Release Limits Environmental Action Levels Environmental Qualification Guaranteed Shutdown State International Atomic Energy Agency Licence Conditions Handbook Life Cycle Management Plans Non-destructive Examination Nuclear Energy Worker National Fire Protection Association Nuclear Generating Station Nuclear Power Plant Operating Policies and Principles Operating Experience Operational Safety Requirements Polychlorinated Biphenyls Periodic Inspection Program Probabilistic Risk Assessment Nuclear Power Reactor Operating Licence Probabilistic Safety Assessment Regulatory Program Division Systematic Approach to Training Safety and Control Area Safe Operating Envelope Systems, structures and components APPENDIX B Glossary of Terms e-doc Page 114 of 142

387 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 B.2 Definitions The following is a list of definitions of words or expressions used in the LCH that may need clarification. Unless a reference source is provided in parenthesis, the words or expressions have been defined for the purpose of the LCH. Accept/ed/able/ance Meet regulatory requirements, which mean it is in compliance with regulatory documents or technical standards referenced in the licence. Approval Commission s permission to proceed, for situations or changes where the licensee would be: not compliant with a regulatory requirements set out in applicable laws and regulations; not compliant with a licence condition; and not in the safe direction but the objective of the licensing basis is met. Boundary conditions Procedural, administrative rules and operating limits for ensuring safe operation of the facility based on safety analysis. It also includes any applicable regulatory requirements. Certified Staff Trained licensee staff, certified by the Commission to be competent in completing tasks identified in their respective roles. Compliance verification criteria Criteria used to verify compliance with a licence condition. CVC provides the licensee and CNSC staff with detailed information to clarify regulatory requirements for compliance purposes. Consent Written permission to proceed, given by CNSC delegated authority, for situations or changes where the licensee would: comply with a regulatory requirements set out in applicable laws and regulations; comply with a licence condition; and not adversely impact the licensing basis. Defense-in-depth The application of more than one protective measure for a given safety objective, such that the objective is achieved even if one of the protective measures fails. Design basis The range of conditions and events taken into account in the design of the facility, according to established criteria, such that the facility can withstand them without exceeding authorized limits for the planned operation of safety systems. [CNSC regulatory document, RD-360: Life Extension of Nuclear Power Plants ] APPENDIX B Glossary of Terms e-doc Page 115 of 142

388 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Design basis accident Accident conditions against which an NPP is designed according to established design criteria, and for which the damage to the fuel and the release of radioactive material are kept within authorized limits. [CNSC regulatory document, RD-310: Safety Analysis for Nuclear Power Plants ] Effective Date The date that a given document becomes effective within the licensing period. The effective date is either set to the licence issue date or to a future date when the given document becomes effective. Extent of condition An evaluation to determine if an issue has potential or actual applicability to other activities, processes, equipment, programs, facilities, operations or organizations. Graduated enforcement A process for escalating enforcement action. If initial enforcement action does not result in timely compliance, gradually more severe enforcement actions may need to be used. It takes into account such things as: the risk significance of the non-compliance with respect to health, safety, security, the environment and international obligations; the circumstances that lead to the non-compliance (including acts of willfulness); previous compliance record; operational and legal constraints (for example, Directive on the Health of Canadians); and industry specific strategies. [CNSC process document: Assure Compliance- Select and Apply Enforcement Tools ] Human factors engineering Is the application of knowledge about human capabilities and limitations to plant or facility, system, and equipment design. Human factors engineering ensures that the plant or facility, system, or equipment design, human tasks, and work environment, are compatible with the sensory, perceptual, cognitive, and physical attributes of the personnel who operate, maintain, and support it. [CNSC regulatory document G-276: Human Factors Engineering Program Plans ] Important to safety Items important to safety include, but are not limited to: Structures, Systems or Components (SSC) whose malfunction or failure could lead to undue radiation exposure of the facility/site personnel, or members of the public; SSCs that prevent anticipated operational occurrences from leading to accident conditions; those features that are provided to mitigate the consequences of malfunctions or failures of SSCs; and tasks, duties, activities, aging mechanisms, findings, or any work that improperly performed could lead to radiation exposure of the facility/site personnel, or members of the public. Levels 1 and 2 Outage Plans A level 1 outage plan is a schedule which identifies the key components of the finalized critical path, major projects and programs. A level 2 outage plan is a schedule which identifies the system windows with durations. APPENDIX B Glossary of Terms e-doc Page 116 of 142

389 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Licensee documents requiring notification of change As determined by CNSC staff, these are documents needed to support the licence application which contain the necessary safety and control measures. Depending on the risk significance of the document, changes may require either a notification or a notification prior to implementation. Program(s) A documented group of planned activities, procedures, processes, standards and instructions coordinated to meet a specific purpose. Programmatic failure A programmatic failure (or programmatic non-compliance), arises under one or more of the following circumstances: Failure to establish a required program or program element; Failure of a program or program element to meet a mandated standard; Failure to comply with a specific, objective provision of a program; and Aggravated or systemic failure(s) to adhere to applicable procedures. [OPG governance Regulatory Interpretation CNSC-024] Probabilistic safety assessment (PSA) For a NPP or nuclear fission reactor, a comprehensive and integrated assessment of the safety of the plant or reactor. The safety assessment considers the probability, progression and consequences of equipment failures or transient conditions to derive numerical estimates that provide a consistent measure of the safety of the plant or reactor, as follows: (i) A Level 1 PSA identifies and quantifies the sequences of events that may lead to the loss of core structural integrity and massive fuel failures. (ii) A Level 2 PSA starts from Level 1 results, and analyses the containment behaviour, evaluates the radionuclides released from the failed fuel and quantifies the releases to the environment. (iii) A Level 3 PSA starts from the Level 2 results, and analyses the distribution of radionuclides in the environment and evaluates the resulting effect on public health. A PSA may also be referred to as a Probabilistic Risk Assessment (PRA). [CNSC regulatory document, S-294 Probabilistic Safety Assessment (PSA) for Nuclear Power Plants ] Qualified Staff Trained licensee staff, deemed competent and qualified to carry out tasks associated to their respective positions. Recommendation and Guidance Non-mandatory suggestions on how to comply with the licence condition. Recommendations and guidance may include regulatory advice and/or recommended industry best practices to guide the licensee towards a higher level of safety and/or fully satisfactory performance/implementation of its programs. Regulatory undertakings Refers to high level commitments that ensure safety, not component work orders or regulatory predefined maintenance tasks. The licensee s deferral and Station Condition Record process focus on these lower level commitments. APPENDIX B Glossary of Terms e-doc Page 117 of 142

390 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Restart of the reactor Removal of the Guaranteed Shutdown State (GSS). Safe direction Changes in plant safety levels which would not result in: a reduction in safety margins; a breakdown of barrier; an increase (in certain parameters) above accepted limits; an increase in risk; impairment(s) of special safety systems; an increase in the risk of radioactive releases or spills of hazardous substances; injuries to workers or members of the public; introduction of a new hazard; reduction of the defense-in-depth provisions; reducing the capability to control, cool and contain the reactor while retaining the adequacy thereof; and causing hazards or risks different in nature or greater in probability or magnitude than those stated in the safety analysis of the nuclear facility. Safety and control measures Measures or provisions that demonstrate that the applicant: (i) is qualified to carry on the licensed activities; and (ii) has made adequate provision for the protection of the environment, the health and safety of persons, the maintenance of national security and any measures required to implement international obligations to which Canada has agreed. Safety-related system(s) A system, including its components and structures that, by failing to perform in accordance with the design intent, has the potential to impact on the radiological safety of the public or plant staff. Safetyrelated systems are associated with: (i) the regulation (including controlled startup and shutdown) and cooling of the reactor core under all normal operating and shutdown conditions; (ii) the regulation, shutdown, and cooling of the reactor core under anticipated transient conditions and accident conditions, and the maintenance of the reactor core in a safe shutdown state for an extended period following such conditions; and (iii) limiting the release of radioactive material and the radiation exposure of plant staff and/or the public in accordance with the criteria established by the regulatory/licensing authority during and following normal, anticipated transient, and accident conditions. [CSA standard N Requirements for safety-related structures for CANDU nuclear power plants ] APPENDIX B Glossary of Terms e-doc Page 118 of 142

391 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Safety significance Refers to the significance of a discovery/issue with respect to the impact on meeting the fundamental nuclear safety objectives as defined by the IAEA. In general, a discovery/event has safety significance if it denotes a deviation away from the safety case accepted in the licence, in the direction detrimental to safety, such as: Reducing margins to, or exceeding the accepted limits; Increasing risk; Impairments (various degrees) of the special safety systems or of the safety functions for accident mitigation; Human factor issues; and Events causing radioactive releases and spills of hazardous substances, injuries to workers, public, etc. [CNSC internal document, Risk-Informing CNSC Planning, Licensing, and Compliance Activities ] Serious process failure Means a failure of a process system, a component or a structure that: (i) leads to a systematic fuel failure or to a significant release from the nuclear power plant, or (ii) could lead to a systematic fuel failure or a significant release in the absence of action by any special safety system. [CNSC regulatory document, S-99: Reporting Requirements for Operating Nuclear Power Facilities ] Version-controlled documents Refers to documents which require a certain type of CNSC control and are captured in the Document Version Control subsection of the LCH. Such documents include regulatory/industry standards as referenced in the licence (may include regulatory/industry standards which require transition). Worker Any person adequately trained to work at the facility covered under the associated operating licence. Written notification A physical or electronic communication between a CNSC delegated authority and a person authorized to act on behalf of the licensee. Written notification prior to implementation CNSC must receive the WN for the proposed changes within a reasonable time (based on the extent of the proposed changes and the potential impact on safe operation of the facility) prior to the implementation. This will allow sufficient time for CNSC staff to review the submission and determine the acceptability. APPENDIX B Glossary of Terms e-doc Page 119 of 142

392 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 APPENDIX C List of All Version-Controlled Documents C.1 All Canadian Standards Association (CSA) documents referenced in the LCH Document # Document Title Version L.C. E-Doc # N286 Management System Requirements for Nuclear Facilities N Requirements for the safe operating envelope for nuclear power plants N286.7 Quality Assurance Of Analytical, Scientific And Design Computer Programs For Nuclear Power Plants N285.0 General Requirements For Pressure-Retaining Systems And Components In CANDU Nuclear Power Plants N Environmental Qualification of Equipment for CANDU Nuclear Power Plants N289.1 General Requirements for Seismic Design and Qualification of CANDU Nuclear Power Plants N285.4 Periodic Inspection Of CANDU Nuclear Power Plant Components N285.5 Periodic Inspection Of CANDU Nuclear Power Plant Containment Components N287.7 In-Service Examination And Testing Requirements For Concrete Containment Structures For CANDU Nuclear Power Plant Components N288.1 Guidelines for calculating derived release limits for radioactive material in airborne and liquid effluents for normal operation of nuclear facilities N288.4 Environmental monitoring program at Class I nuclear facilities and uranium mines and mills N288.5 Effluent Monitoring Programs at Class I nuclear facilities and uranium mines and mills N288.6 Environmental Risk Assessments at Class I nuclear facilities and uranium mines and mills 1999 Reaffirmed & Update 1 & Update & Update Reaffirmed Sept N293 Fire Protection for CANDU Nuclear Power Plants N292.3 Management of Low and Intermediate-Level Radioactive Waste N294 Decommissioning of facilities containing nuclear substances APPENDIX C List of Version-Controlled Documents e-doc Page 120 of 142

393 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 C.2 All Canadian Nuclear Safety Commission (CNSC) documents referenced in the LCH Document # Document Title Version L.C. e-doc # INFO-0795 Licensing Basis Objective and Definition 2010 G.1 CNSC Website N/A CNSC Financial Security and ONFA Access 2013 G Agreement and Provincial Guarantee Agreement, effective January 1, 2013 RD/GD 99.3 Public Information and Disclosure 2012 G.6 CNSC Website RD-204 Certifications of Persons Working at Nuclear Power Plants CNSC Website REGDOC Accident management: Severe accident management programs for nuclear reactors CNSC Website REGDOC Reporting Requirements: Nuclear Power Plants CNSC Website REGDOC Periodic safety Reviews CNSC Website REGDOC Deterministic Safety Analysis CNSC Website REGDOC Probabilistic Safety Assessment (PSA) for Nuclear Power Plants CNSC Website RD/GD-210 Maintenance Programs for Nuclear Power Plants CNSC Website RD/GD-98 Reliability Programs for Nuclear Power Plants CNSC Website REGDOC Fitness for Service: Aging Management CNSC Website REGDOC Environmental Protection: Policies, Programs And Procedures CNSC Website REGDOC Testing and Implementation of Emergency Measures CNSC Website REGDOC High Security Sites: Nuclear Response Force N/A REGDOC Site Access Security Clearance CNSC Website RD-363 Nuclear Security Officer Medical, Physical and Psychological Fitness CNSC Website RD-321 Criteria for Physical Protection Systems and N/A Devices at High Security Sites RD-361 Criteria for Explosive Substance Detection, X N/A Ray Imaging and Metal Detection at High Security Sites. RD-336 Accounting and Reporting of Nuclear Material CNSC Website APPENDIX C List of Version-Controlled Documents e-doc Page 121 of 142

394 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 APPENDIX D List of Licensee Documents Requiring Written Notification Document # N-PROG-AS-0006 NK38-SR NK38 DOH NK38 DOH LO4254 DZS N-STD-AS-0013 Document Title GENERAL Records and Document Control Darlington NGS Safety Report: Part 1 Plant/Site Description Ontario Hydro layout drawing, Rev. 9, November 1981 Ontario Hydro layout drawing, Rev. 4, March Darlington NGS-A Plant Survey June 7, 1999 Nuclear Public Information Disclosure MANAGEMENT SYSTEM Notification Requirements When implemented When implemented When implemented When implemented PRIOR to implementation When implemented N-CHAR-AS-0002 Nuclear Management System PRIOR to implementation N-PROG-AS-0001 Managed Systems When implemented N-PROG-AS-0006 Records and Document When Control implemented N-PROG-AS-0007 Project Management Program When implemented N-STD-AS-0024 Change Management When implemented N-STD-AS-0020 Nuclear Organization When implemented OPG-PROC-0166 Organization Design Change When implemented N-POL-0001 Nuclear Safety Policy When implemented N-STD-AS-0023 Nuclear Safety Oversight When implemented OPG-PROG-0010 Safety Management System When Program implemented N-PROC-AS-0077 Nuclear Safety Culture When Assessment implemented N-PROG-RA-0010 Program Assessment When /Independent Assessment implemented L.C. G.2 G.3 G.3 G.3 G.3 G APPENDIX D List of Licensee Documents Requiring Written Notification e-doc Page 122 of 142

395 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # N-GUID N-PROG-RA-0018 OPG-PROG-0009 Document Title Guideline for Maintaining Staff in Key Positions When Normal Station Access is Impeded Nuclear Pandemic Plan Items and Services Management Notification Requirements When implemented When implemented When implemented L.C N-PROC-HR-0002 N-PROG-AS-0002 N-STD-AS-0002 N-STD-OP-0002 N-STD-OP-0004 N-STD-OP-0012 N-STD-RA-0014 N-PROC-OP-0005 N-CMT N-TQD D-PROC-OP-0009 D-INS N-PROG-TR-0005 N-PROC-TR-0008 N-INS HUMAN PERFORMANCE MANAGEMENT Limits of Hours of Work Human Performance Procedural Usage and Adherence Communications Self-Check Conservative Decision Making Second Party Verification Pre-Job Briefing and Post-Job Debriefing Continuous Behaviour Observation Program (CBOP) Participants Materials Workbook Components Leadership and Management Training and Qualification Description Station Shift Complement Duty Crew Minimum Complement Assurance Training Systematic Approach to Training Written and Oral Initial Certification Examination for Shift Personnel PRIOR to implementation When implemented When implemented When implemented When implemented When implemented When implemented When implemented When implemented When implemented PRIOR to implementation PRIOR to implementation When implemented When implemented When implemented APPENDIX D List of Licensee Documents Requiring Written Notification e-doc Page 123 of 142

396 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # N-INS N-INS N-MAN CNSC-031 N-MAN CNSC-006 N-MAN CNSC-010 N-MAN CNSC-008 N-MAN CNSC-025 Document Title Simulator-Based Initial Certification Examinations for Shift Personnel Requalification Testing of Certified Shift Personnel Responsible Health Physicist Shift Manager, Darlington Nuclear Authorized Nuclear Operators Control Room Shift Supervisor Unit 0 Control Room Operator Notification Requirements When implemented When implemented PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation L.C NK38-OPP N-STD-MP-0016 N-PROG-OP-0001 N-STD-OP-0025 N-STD-OP-0024 N-PROG-OP-0003 N-PROG-OP-0004 N-STD-OP-0012 N-STD-OP-0036 N-STD-OP-0011 N-PROC-RA-0035 N-PROC-RA-0022 N-PROG-RA-0003 OPERATING PERFORMANCE Darlington Nuclear Operating Policies and Principles Safe Operating Envelope Conduct of Operations/Nuclear Operations Heat Sink Management Nuclear Safety Configuration Management Plant Status Control Chemistry Conservative Decision- Making Operational Decision Making Operations Performance Monitoring Operating Experience Process Processing Station Conditions Records Corrective Action PRIOR to implementation PRIOR to implementation When implemented When implemented When implemented When implemented When implemented When implemented When implemented When implemented When implemented When implemented When implemented APPENDIX D List of Licensee Documents Requiring Written Notification e-doc Page 124 of 142

397 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # N-STD-OP-0017 N-PROG-MP-0014 N-STD-OP-0009 N-STD-OP-0021 N-STD-MP-0019 N-PROG-MP-0014 N-STD-OP-0017 N-PROC-RA-0005 N-PROC-RA-0020 Document Title Response to Transients Reactor Safety Program Reactivity Management Control of Fuelling Operations Beyond Design Basis Accident Management Reactor Safety Program Response to Transients Written Reporting to Regulatory Agencies Preliminary Event Notifications SAFETY ANALYSIS Notification Requirements When implemented When implemented When implemented When implemented When implemented When implemented When implemented When implemented When implemented NK38-SR Darlington NGS Safety When Report: Part 2 System implemented Descriptions NK38-SR DN 1-4 Safety Report: Part 3- When Accident Analysis implemented NK38-REP Darlington Analysis of When Record implemented N-STD-MP-0019 Beyond Design Basis When Accident Management implemented N-PROG-MP-0014 Reactor Safety Program When implemented N-PROC-MP-0086 Safety Analysis Basis and Safety Report When implemented N-PROG-RA-0016 Risk and Reliability Program When implemented Preparation, Maintenance and When Application of Probabilistic Risk N-STD-RA-0034 implemented Assessment When N-PROG-MP-0006 Software implemented L.C APPENDIX D List of Licensee Documents Requiring Written Notification e-doc Page 125 of 142

398 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # Document Title Notification Requirements L.C. N-PROG-MP-0007 N-PROG-MP-0001 N-PROG-MP-0005 N-PROG-MP-0009 N-PROG-MA-0016 N-INS N-PROG-MP-0004 N-PROC-MP-0040 N-PROC-MP-0082 N-MAN N-LIST N/A N-PROG-RA-0006 PHYSICAL DESIGN Conduct of Engineering Engineering Change Control Configuration Management Design Management Fuel Procurement From Licensed Canadian Nuclear Utilities Pressure Boundary Program System and Item Classification Design Registration Pressure Boundary Program Manual Index to OPG Pressure Boundary Program Elements Authorized Inspection Agency Service Agreement Environmental Qualification When implemented When implemented When implemented When implemented When implemented When implemented PRIOR to implementation PRIOR to implementation PRIOR to implementation When implemented When implemented PRIOR to implementation When implemented N-PROG-MA-0004 N-PROG-MA-0017 N-PROG-MA-0019 N-PROG-MP-0008 N-PROC-MA-0013 N-PROC-MA-0049 N-PROG-MA-0026 FITNESS FOR SERVICE Conduct of Maintenance Component and Equipment Surveillance Production Work Management Integrated Aging Management Planned Outage Management Forced Outage Management Equipment Reliability When implemented When implemented When implemented When implemented When implemented When implemented When implemented APPENDIX D List of Licensee Documents Requiring Written Notification e-doc Page 126 of 142

399 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # N-PROG-RA-0016 N-STD-RA-0033 NK38-LIST N-PROG-MA-0025 N-PLAN NK38-PIP NK38-PIP NK38-PIP NK38-PIP N-PLAN NK38-PLAN N-PLAN NK38-PIP NK38-PIP NK38-PIP Document Title Risk and Reliability Program Reliability and Monitoring of Systems Important to Safety List of Safety Related Systems and Functions Major Components Feeders Life Cycle Management Plan Darlington Nuclear Unit 1 Fuel Channel Feeder Pipes Periodic Inspection Program Plan Darlington Nuclear Unit 2 Fuel Channel Feeder Pipes Periodic Inspection Program Plan Darlington Nuclear Unit 3 Fuel Channel Feeder Pipes Periodic Inspection Program Plan Darlington Nuclear Unit 4 Fuel Channel Feeder Pipes Periodic Inspection Program Plan Steam Generators Life Cycle Management Plan Darlington Units 1-4 Steam Generator Life Cycle Management Plan Fuel Channels Life Cycle Management Plan Darlington Nuclear 1-4, Unit 1 Fuel Channel Pressure Tubes Periodic Inspection Program Plan Darlington Nuclear 1-4, Unit 2 Fuel Channel Pressure Tubes Periodic Inspection Program Plan Darlington Nuclear 1-4, Unit 3 Fuel Channel Pressure Tubes Periodic Inspection Program Plan Notification Requirements When implemented When implemented PRIOR to implementation When implemented PRIOR to implementation** PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation** PRIOR to implementation** PRIOR to implementation** PRIOR to implementation PRIOR to implementation PRIOR to implementation L.C APPENDIX D List of Licensee Documents Requiring Written Notification e-doc Page 127 of 142

400 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # NK38-PIP N-PLAN NK38-PIP NK38-PIP NK38-PIP NK38-PIP NK38-PIP NK38-PIP N-PLAN NK38-PIP NK38-PIP NK38-TS N-PROC-MA-0066 Document Title Darlington Nuclear 1-4, Unit 4 Fuel Channel Pressure Tubes Periodic Inspection Program Plan Reactor Components and Structures Life Cycle Management Plan Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 1 Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 2 Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 3 Darlington Nuclear Generating Station Periodic Inspection Plan For Unit 4 Darlington Nuclear Generating Station - Periodic Inspection Program For Unit 0 and Units 1 To 4 Containment Components Darlington Nuclear - Unit 0 Containment Periodic Inspection Program Aging Management Plan for Containment Structures Darlington Nuclear Reactor Building Periodic Inspection Program Darlington Nuclear - Vacuum Building Periodic Inspection Program Inspection of Post Tensioning Tendons on DNGS Vacuum Building Administrative Requirements for In-Service Examination and Testing for Concrete Containment Structures Notification Requirements PRIOR to implementation When implemented PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation PRIOR to implementation L.C APPENDIX D List of Licensee Documents Requiring Written Notification e-doc Page 128 of 142

401 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # NK38-PLAN Document Title Aging Management Plan for Darlington NGS Non- Containment Building Structures Notification Requirements PRIOR to implementation L.C. 6.1 N-PROG-RA-0013 N-STD-RA-0018 N-REP N-PROC-RA-0019 RADIATION PROTECTION Radiation Protection Controlling Exposure As Low As Reasonably Achievable Occupational Radiation Protection Action Levels for Power Reactor Operating Licenses Dose Limits and Exposure Control PRIOR to implementation When implemented PRIOR to implementation PRIOR to implementation N-PROG-MA-0015 OPG-PROC-0132 OPG-POL-0001 OPG-PROG-0010 N-PROG-RA-0012 NK-38-LIST CONVENTIONAL HEALTH AND SAFETY Work Protection Respiratory Protection Health and Safety Policy Health and Safety Management System Program Fire Protection Application of CSA N293-7 to Structures, System and Components for Darlington Nuclear When implemented When implemented When implemented When implemented PRIOR to implementation When implemented OPG-POL-0021 NK38-MAN N-PROC-OP-0025 N-PROG-OP-0006 OPG-PROC-0126 ENVIRONMENTAL PROTECTION Environmental Policy Environment Manual Environmental Monitoring Programs Environmental Management Hazardous Material Management When implemented When implemented When implemented When implemented When implemented APPENDIX D List of Licensee Documents Requiring Written Notification e-doc Page 129 of 142

402 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # N-STD-OP-0031 N-PROC-OP-0044 NK38-REP N-PROG-RA-0001 N-PROG-RA-0012 N-PROG-OP-0006 N-PROC-OP-0043 N-PROC-RA-0017 OPG-CHAR-0001 NK38-PLAN REP N-PROG-RA-0011 TRAN-PLAN NK38-REP N-PROC-MP-0103 N-STI Document Title Monitoring of Nuclear and Hazardous Substances in Effluents Contaminated Lands and Groundwater Monitoring Management Derived Release Limits and Action Levels for Darlington Nuclear Generating Station EMERGENCY MANAGEMENT AND FIRE PROTECTION Consolidated Nuclear Emergency Plan Fire Protection WASTE MANAGEMENT Environmental Management Waste Management Segregation and Handling of Radioactive Wastes Decommissioning Management System Preliminary Decommissioning Plan - Darlington Nuclear Generating Station SECURITY Darlington Nuclear Generating Station Security Report Nuclear Security Transport Security Plan Threat and Risk Assessment Security for Real-Time Process Computing Systems Cyber Asset Identification for Real-time Process Computer Systems Notification Requirements When implemented When implemented PRIOR to implementation PRIOR to implementation PRIOR to implementation When implemented When implemented When implemented PRIOR to implementation PRIOR to implementation PRIOR to implementation L.C PRIOR to 12.1 implementation When 12.1 implemented When 12.1 implemented When implemented 12.1 When implemented 12.1 APPENDIX D List of Licensee Documents Requiring Written Notification e-doc Page 130 of 142

403 LCH-DNGS-R000 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # N-STI Document Title Cyber Security for Real-time Process Computing Systems Notification Requirements L.C. When implemented 12.1 NK38-LIST Significant Cyber Assets When implemented 12.1 N-PROG-RA-0015 N-STD-RA-0024 W-PROG-WM-0002 N-STD-RA-0036 N-PROG-AS-0008 NK38-OPP D-INS NK38-NR-PLAN Sheet 0003 NK38-REP NK-38-INS SAFEGUARDS Nuclear Safeguards Nuclear Safeguards Implementation PACKAGING AND TRANSPORT Radioactive Material Transportation Radioactive Materials Transportation Emergency Response Plan SITE SPECIFIC Heavy Water Management Plan Darlington Nuclear Operating Policies and Principles TRF Planned Outage Management Return to Service Program Management Plan Darlington NGS Integrated Implementation Plan (IIP) Change Control and Closeout Process Nuclear Refurbishment Unit Readiness for Service PRIOR to implementation PRIOR to implementation When implemented When implemented When implemented PRIOR to implementation When implemented When implemented When implemented PRIOR to implementation *Should a document listed as a WN document within this LCH also require submission for approval/acceptance per a standard referenced in the associated Nuclear Power Reactor Operating Licence (PROL), the licensee shall submit that document for approval/acceptance to comply with the governing standard and the associated LC. **Prior notification is only required when changes to the document result in changes to the PIP that has received regulatory acceptance APPENDIX D List of Licensee Documents Requiring Written Notification e-doc Page 131 of 142

404 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 APPENDIX E List of Documents used as Guidance or Criteria E.1 Other Codes or Standards referenced in the LCH Document # Document Title L.C. e-doc # CSA N Requirements for heat sink removal capability during outage of nuclear power plants N/A Interpretation of REGDOC Reporting Requirements for Nuclear Power Plants CSA N287.1 General Requirements for Concrete Containment Structures for CANDU Nuclear Power Plants CSA N287.2 Material requirements for concrete containment structures for CANDU nuclear power plants CSA N287.3 Design Requirements for Concrete Containment Structures for CANDU Nuclear Power Plants CSA N287.4 Construction, fabrication, and installation requirements for concrete containment structures for CANDU nuclear power plants CSA N287.5 Examination and testing requirements for Concrete Containment Structures for CANDU Nuclear Power Plants CSA N287.6 Re-Operational Proof and Leakage Rate Testing Requirements for Concrete Containment Structures for CANDU Nuclear Power Plants CSA N289.1 General requirements for seismic design and qualification of CANDU nuclear power plants 5.2 CSA N289.2 Ground Motion Determination for Seismic Qualification of CANDU Nuclear Power Plants CSA N289.3 CSA N289.4 CSA N289.5 CSA N290.0 Series CSA N290.1 CSA N290.2 CSA N290.3 Design Procedures for Seismic Qualification of CANDU Nuclear Power Plants Testing Procedures for Seismic Qualification of CANDU Nuclear Power Plants Seismic Instrumentation Requirements for CANDU Nuclear Power Plants General requirements for safety systems of nuclear power plants Requirements for the Shutdown Systems of Nuclear Power Plants General requirements for emergency core cooling systems for nuclear power plants Requirements for containment system of nuclear power plants APPENDIX E List of Documents used as Guidance or Criteria e-doc Page 132 of 142

405 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # Document Title L.C. e-doc # CSA N290.5 Requirements for Electrical Power and Instrument Air Systems of CANDU Nuclear Power Plants CSA N Qualification of Pre-Developed Software UFC Structures to Resist the Effects of Accidental Explosions 5.1 N/A ASME B31.1 Power Piping 5.2 N/A ASME B31.3 Process Piping Code 5.2 N/A ASME B31.5 Refrigeration Piping and Heat Transfer Component Code 5.2 N/A ASME Boiler and Pressure Vessel Code 5.2 N/A CSA B51 Boiler, Pressure Vessel and Piping 5.2 N/A CSA N285.6 General Requirements for Pressure-Retaining Systems Series and Components in CANDU Nuclear Power Plants/Material Standards for Reactor Components for CANDU Nuclear Power Plants COG Interim Implementation Guidelines for CANDU Nuclear Plant Reliability Programs CSA N285.8 Technical requirements for in-service evaluation of zirconium alloy pressure tubes in CANDU reactors NEI Guidance for Post Fire Safe Shutdown Circuit Analysis 10.2 N/A CSA N292.2 Interim Dry Storage of Irradiated Fuel IAEA IAEA IAEA Nuclear Security Series No. 4 Technical Guidance: Engineering Safety Aspects of the Protection of Nuclear Power Plants Against Sabotage INFCIRC/225/Revision 5: IAEA Nuclear Security Recommendations on Physical Protection of Nuclear Material and Nuclear Facilities 12.1 IAEA Website 12.1 IAEA Website APPENDIX E List of Documents used as Guidance or Criteria e-doc Page 133 of 142

406 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 E.2 Other CNSC documents referenced in the LCH Document # Document Title L.C. e-doc # P-211 Compliance N/A CNSC Website P-242 Considering Cost-benefit Information N/A CNSC Website N/A Select and Apply Enforcement Tools N/A INFO-0795 Licensing Basis Objective and Definition G.1 CNSC Website G-206 Financial Guarantees for the Decommissioning of Licensed Activities G.5 CNSC Website G-276 Human Factors Engineering Program Plans CNSC Website G-278 Human Factors Verification and Validation Plans G-323 Ensuring the Presence of Sufficiently Qualified Staff at Class I Nuclear Facilities- Minimum Shift Compliment CNSC-EG1, Rev.0 CNSC-EG2, Rev.0 N/A Requirements and Guidelines for Written and Oral Certification Examinations for Shift Personnel at Nuclear Power Plants Requirements and Guidelines for Simulator-based Certification Examinations for Shift Personnel at Nuclear Power Plants Requirements for the Requalification Testing of Certified Shift Personnel at Nuclear Power Plants, Revision 2 CNSC Website 2.2 CNSC Website REGDOC Personnel Training 2.3 CNSC Website REGDOC (2014) Accident Management 3.1 CNSC Website G-276 Human Factors Engineering Program Plans 5.1 CNSC Website G-129 Keeping Radiation Exposures and Doses As Low As Reasonably Achievable (ALARA) 7.1 CNSC Website G-228 Regulatory Guide, Developing and Using Action Levels CNSC Website P-223 Protection of the Environment 9.1 CNSC Website G-206 Financial Guarantees for the Decommissioning of Licensed Activities 11.2 CNSC Website G-219 Decommissioning Planning for Licensed Activities 11.2 CNSC Website APPENDIX E List of Documents used as Guidance or Criteria e-doc Page 134 of 142

407 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 Document # Document Title L.C. e-doc # REGDOC Security of Nuclear Substances: Sealed Sources 12.1 CNSC Website G-274 Security Programs for Category I or II Nuclear Material or Certain Nuclear Facilities 12.1 CNSC Website G-208 Transportation Security Plans for Category I, II or III Nuclear Material 12.1 CNSC Website GD-336 Guidance for Accounting and Reporting of Nuclear Material 13.1 CNSC Website APPENDIX E List of Documents used as Guidance or Criteria e-doc Page 135 of 142

408 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 APPENDIX F Approvals pursuant to a PROL LC granted by the Commission L.C Subject of the Approval e-doc # Licensee s reference # Effective Date Expiry Date APPENDIX F Approvals Pursuant to a Licence Condition Granted by the Commission e-doc Page 136 of 142

409 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 APPENDIX G Consents pursuant to a PROL LC L.C Subject of the Consent e-doc # Licensee s reference # 3.1 Implementation of Rod-Based Guaranteed Shutdown State 3.1 Acceptability of Proposed Neutron Overpower Protection (E-NOP) Trip Setpoints 5.1 Request to Load Modified 37 Element Fuel Bundles for Demonstration Irradiation 5.1 Concurrence to Use the Municipality of Clarington as the AHJ to Process and Approve Building Permits for Future Modifications for the OSB 5.1 Approval for Full Core Implementation of Modified 37 Element Fuel Bundles Design Codes and Standards Effective Dates for OPG Nuclear Fleet Design Codes and Standards Effective Dates for OPG Nuclear Fleet - Clarification NK38-CORR N-CORR NK38-CORR NK38-CORR NK38-CORR N-CORR N-CORR Temporary Leak Suppression NK38-CORR CNSC Agreement for Use of Class 6 Valves for Repair and Replacement in Instrument Lines Darlington, Pickering NGS-A and Pickering NGS-B 5.2 Units 1-4: Request for Generic Ice Plug Approval 5.2 CNSC Approval for a Variance to Table 3 of CSA Standard N Approval of a Variance to ASME B31.1 Para (C.3) Copper Tubing N-CORR NK38-CORR N-CORR N-CORR Effective Date Expiry Date N/A N/A N/A N/A Upon N/A completion of OPG EC activities Refurb. design Other design Refurb. design Other design N/A N/A N/A N/A N/A APPENDIX G Consents Given by an Authorized Person e-doc Page 137 of 142

410 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 L.C Subject of the Consent e-doc # Licensee s reference # 5.2 for Acceptance of Legacy Pressure Boundary (PB) Systems List Class Concurrence to Complete Installation and Commissioning of Primary Heat Transport System Liquid Relief Valves (LRV) in Refurbishment Outages 5.2 Federal/Provincial Requirements Applicable to Operations Support Building 5.2 CNSC Acceptance of Transition Plan for Repair/Replacement Process for Pressure Boundary Legacy Systems 5.2 Concession Request to use ASME BPVC SEC IIII and section XI APPL L Methodology for the LRV replacement Project 5.2 Request to Reinstate the agreement for Welded Joints in Small Diameter Tubing 5.2 CNSC Acceptance of Process for Submission of Variances for Replacement of Non-Registered Items in Pressure Boundary Legacy Systems 5.2 CNSC Acceptance for OPG Use of ASME OM Code Case OMN OPG Transition Plan to 2014 Edition of CSA Standard N Periodic Inspection of CANDU Nuclear Power Plant Components 6.1 Darlington and Pickering NGS: OPG Revised CSA N285.8 Compliance Plan, New Action Item 2014-OPG Darlington and Pickering NGS: OPG CSA N285.8 Compliance Plan, Action Item 2014-OPG Revised OPG CSA N285.8 Compliance Plan Submission N-CORR NK38-CORR NK38-CORR N-CORR NK38-CORR N-CORR N-CORR N-CORR N-CORR N-CORR N-CORR N-CORR Effective Date Expiry Date N/A Last unit refurbishment outage N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A APPENDIX G Consents Given by an Authorized Person e-doc Page 138 of 142

411 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 L.C Subject of the Consent e-doc # Licensee s reference # 6.1 OPG CSA N285.8 Compliance Plan - Response Regarding Action Item PG CNSC response to Ontario Power Generation s Approach to Fitness for Service Assessment for Pressure Tubes 6.1 Approach to Fitness for Service Assessment for Pressure Tubes New Action Item 2014-OPG Approach to Fitness for Service Assessment for Pressure Tubes 6.1 Submission of Continuing Research and Development Work Plan to Enhance Pressure Tube Fracture Toughness Models 6.1 Darlington NGS - Submission of Updated Darlington NGS - Long Term Darlington Life Management Plan for lnconel X-750 Spacers 6.1 Darlington NGS A Request for CNSC Acceptance of the DNGS Outlet Feeder Dissimilar Metal Weld Leak-Before-Break Assessment 6.1 Darlington NGS A - CSA N Compliant Periodic Inspection Programs Revision for Fuel Channels and Feeders - Closure of Action Item Submission of Fitness-for-Service Guidelines tor Feeders in CANDU Reactors COG-JP V06 Revision Submission of Fitness-for-Service Guidelines for Feeders in CANDU Reactors COG-JP-4107-V06 Revision N-CORR N-CORR N-CORR N-CORR N-CORR NK38-CORR NK38-CORR N-CORR N-CORR N-CORR Effective Date Expiry Date N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A APPENDIX G Consents Given by an Authorized Person e-doc Page 139 of 142

412 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 L.C Subject of the Consent e-doc # Licensee s reference # 6.1 Darlington NGS and Pickering NGS Units 1 to 8: CNSC Conditional Acceptance of Fitness-for-Service Guidelines for Steam Generator and Preheater Tubes 6.1 Vacuum Building Test and Inspection Frequency 6.1 Darlington NGS Request for Approval to Change the Main Containment System Positive Pressure Test Frequency 6.1 OPG s request to use COG Procedures for In-Service Evaluation of Zirconium Alloy Pressure Tubes in CANDU Reactors 6.1 OPG s compliance plan for the long-term use of CSA standard N following the expiration period of the trial-use period for COG Darlington Feeder PIP, with an exemption from periodic inspection in place for outlet feeder dissimilar metal welds 6.1 OPG s request to use COG-JP V06 Rev. 03 Fitness-for- Service Guidelines (FFSG) for Feeders in CANDU Reactors 6.1 OPG s request to use COG Report Fitness-for- Service Guidelines for Steam Generator and Preheater Tubes, Section I: Evaluation Procedures and Acceptance Criteria 6.1 Deferral of repairs to Vacuum Building caulking until VBO 6.1 OPG Transition to 2008 Edition of CSA Standard N285.5 Update No.1 Periodic Inspection of CANDU Nuclear Power Plant Containment Components N-CORR NK38-CORR NK38-CORR N-CORR N-CORR NK38-CORR N-CORR N-CORR NK38-CORR NK38-CORR Effective Date Expiry Date N/A N/A N/A N/A N/A N/A N/A N/A VBO/ N/A APPENDIX G Consents Given by an Authorized Person e-doc Page 140 of 142

413 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 L.C Subject of the Consent e-doc # Licensee s reference # 6.1 Acceptance of OPG s PIP except for two areas: leakage rate testing of the concrete containment structures and inspection of the post tensioning system 6.1 Letter accepting OPG request to use a new approach for the evaluation of crevice corrosion flaws 10.2 Request for Acceptance to change the inspection and testing frequency of Deluge and Turbine Generator sprinkler System Check 13.1 Clarification on requirements for reporting nuclear material inventory listings to the CNSC NK38-CORR N-CORR NK38-CORR / NK38-CORR Effective Date Expiry Date N/A N/A N/A TBD APPENDIX G Consents Given by an Authorized Person e-doc Page 141 of 142

414 LCH-DNGS-R001 Effective Date: January 1, 2016 Licence Conditions Handbook associated with PROL 13.00/2025 APPENDIX H Resolution of Inconsistencies L.C. Subject of Conflict or Inconsistency e-doc # Licensee s reference # Identifier Approved Date APPENDIX H Resolution of Inconsistencies e-doc Page 142 of 142

415 Word Ref.: e-doc PDF Ref.: e-doc File / Dossier: 2.01 NUCLEAR POWER REACTOR OPERATING LICENCE DARLINGTON NUCLEAR GENERATING STATION I) LICENCE NUMBER: PROL 13.01/2015 (Effective Date: January 1, 2015) II) LICENSEE: Pursuant to section 24 of the Nuclear Safety and Control Act this licence is issued to: Ontario Power Generation Inc 700 University Avenue Toronto, Ontario M5G 1X6 III) LICENCE PERIOD: This licence is valid from March 1, 2013 to December 31, 2015, unless suspended, amended, revoked or replaced. IV) LICENSED ACTIVITIES: This licence authorizes the licensee to: (i) (ii) (iii) operate the Darlington Nuclear Generating Station which includes the Darlington Tritium Removal Facility housed within the Heavy Water Management Building (hereinafter the nuclear facility ) at a site located in the Township of Darlington, in the Municipality of Clarington, in the Regional Municipality of Durham, in the Province of Ontario; possess, transfer, use, package, manage and store the nuclear substances that are required for, associated with, or arise from the activities described in (i); possess and use prescribed equipment and prescribed information that are required for, associated with, or arise from the activities described in (i); V) EXPLANATORY NOTES: (i) (ii) (iii) Nothing in this licence shall be construed to authorize non-compliance with any other applicable legal obligation or restriction. Unless otherwise provided for in this licence, words and expressions used in this licence have the same meaning as in the Nuclear Safety and Control Act and associated Regulations. The Darlington NGS Licence Conditions Handbook (LCH) provides compliance verification criteria in order to meet the conditions listed in the licence. The LCH also provides information regarding delegation of authority, applicable versions of documents and non-mandatory recommendations and guidance on how to achieve compliance.

416 Page 2 of 5 Nuclear Power Reactor Operating Licence PROL 13.01/2015 VI) CONDITIONS: 1. General 1.1 The licensee shall conduct the activities described in Part IV of this licence in accordance with the licensing basis, as defined in Canadian Nuclear Safety Commission (CNSC) document INFO-0795 LICENSING BASIS OBJECTIVE AND DEFINITION, unless otherwise approved in writing by the CNSC (hereinafter the Commission ). 1.2 The licensee shall give written notification of changes made to the licensee documents submitted to support the licence application. 1.3 Licence condition withdrawn. [Amended ] 1.4 The licensee shall control the use and occupation of any land within the exclusion zone so that no permanent dwelling is permitted. 1.5 The licensee shall provide, at the nuclear facility and at no expense to the Commission, office space for employees of the Commission who customarily carry out their functions on the premises of that nuclear facility (on-site Commission staff). The licensee shall keep the office space of on-site Commission staff separate from the remainder of the building in which it is located by walls or other suitable structures. 1.6 The licensee shall maintain financial guarantees for decommissioning acceptable to the Commission and shall satisfy the Commission that the financial guarantee remains valid and in effect and sufficient to meet the decommissioning needs. 1.7 The licensee shall, in the event of any conflict or inconsistency between licence conditions, codes or standards or regulatory documents referenced in this licence, direct the conflict or inconsistency to the Commission, or a person authorized by the Commission, for resolution. 1.8 The licensee shall implement and maintain a public information and disclosure program in accordance with CNSC regulatory document RD/GD-99.3 PUBLIC INFORMATION AND DISCLOSURE. 2. Management System 2.1 The licensee shall implement and maintain a management system in accordance with the Canadian Standards Association (CSA) standard N286 MANAGEMENT SYSTEM REQUIREMENTS FOR NUCLEAR POWER PLANTS. 3. Human Performance Management 3.1 The licensee shall implement and maintain a human performance program. 3.2 The licensee shall implement and maintain the minimum shift complement for the nuclear facility.

417 Page 3 of 5 Nuclear Power Reactor Operating Licence PROL 13.01/ The licensee shall implement and maintain a training program that includes certification training and examinations for positions requiring certified personnel in accordance with CNSC regulatory document RD-204 CERTIFICATION OF PERSONS WORKING AT NUCLEAR POWER PLANTS. Persons appointed to the following positions require certification: (i) (ii) (iii) (iv) (v) Responsible Health Physicist; Shift Manager; Control Room Shift Supervisor; Authorized Nuclear Operator; and Unit 0 Control Room Operator. 4. Operating Performance 4.1 The licensee shall implement and maintain an operations program, which must have as components: (i) (ii) (iii) a Safe Operating Envelope in accordance with CSA standard N REQUIREMENTS FOR THE SAFE OPERATING ENVELOPE FOR NUCLEAR POWER PLANTS; a set of operating policies and principles; and accident management procedures and/or guides for design basis and beyond design basis accidents, including overall strategies for recovery. 4.2 The licensee shall not restart the reactor after a serious process failure or a potential serious process failure, without the prior written approval of the Commission, or prior written consent of a person authorized by the Commission. 4.3 The licensee shall notify and report in accordance with CNSC regulatory document REGDOC [Amended REPORTING REQUIREMENTS FOR NUCLEAR POWER PLANTS ] 5. Safety Analysis 5.1 The licensee shall implement and maintain a safety analysis program in accordance with CNSC regulatory documents: [Amended ] (i) (ii) REGDOC DETERMINISTIC SAFETY ANALYSIS; and REGDOC PROBABILISTIC SAFETY ASSESSMENT (PSA) FOR NUCLEAR POWER PLANTS. 5.2 The licensee shall ensure that design and analysis computer codes and software used to support the safe operation of the nuclear facility are in accordance with CSA standard N286.7 QUALITY ASSURANCE OF ANALYTICAL, SCIENTIFIC AND DESIGN COMPUTER PROGRAMS FOR NUCLEAR POWER PLANTS. 6. Physical Design 6.1 The licensee shall implement and maintain a design program. 6.2 The licensee shall implement and maintain a pressure boundary program in accordance with CSA standard N285.0 GENERAL REQUIREMENTS FOR PRESSURE RETAINING SYSTEMS AND COMPONENTS IN CANDU NUCLEAR POWER PLANTS and have in place a formal agreement, deemed acceptable to the Commission or a person authorized by the Commission, with an Authorized Inspection Agency.

418 Page 4 of 5 Nuclear Power Reactor Operating Licence PROL 13.01/ The licensee shall implement and maintain an environmental qualification program in accordance with CSA standard N ENVIRONMENTAL QUALIFICATION OF EQUIPMENT FOR CANDU NUCLEAR POWER PLANTS. 7. Fitness for Service 7.1 The licensee shall implement and maintain a fitness for service program in accordance with CNSC regulatory documents and CSA standards: (i) S-210 MAINTENANCE PROGRAMS FOR NUCLEAR POWER PLANTS; (ii) RD/GD-98 RELIABILITY PROGRAMS FOR NUCLEAR POWER PLANTS; (iii) N285.4 PERIODIC INSPECTION OF CANDU NUCLEAR POWER PLANT COMPONENTS; (iv) N285.5 PERIODIC INSPECTION OF CANDU NUCLEAR POWER PLANT CONTAINMENT COMPONENTS; and (v) N287.7 IN SERVICE EXAMINATION AND TESTING REQUIREMENTS FOR CONCRETE CONTAINMENT STRUCTURES FOR CANDU NUCLEAR POWER PLANTS. In addition, the fitness for service program shall include an in-service inspection program for the safety significant balance of plant pressure retaining systems and components, and safety-related structures. 8. Radiation Protection 8.1 The licensee shall implement and maintain a radiation protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within three working days. 9. Conventional Health and Safety 9.1 The licensee shall implement and maintain a conventional health and safety program. 10. Environmental Protection 10.1 The licensee shall implement and maintain an environmental protection program in accordance with CNSC regulatory document S-296 ENVIRONMENTAL PROTECTION POLICIES, PROGRAMS AND PROCEDURES AT CLASS 1 NUCLEAR FACILITIES AND URANIUM MINES AND MILLS The licensee shall control and monitor releases of nuclear substances to the environment in accordance with CSA standard N288.1 GUIDELINES FOR CALCULATING DERIVED RELEASE LIMITS FOR RADIOACTIVE MATERIAL IN AIRBORNE AND LIQUID EFFLUENTS FOR NORMAL OPERATION OF NUCLEAR FACILITIES. The licensee shall also have a set of environmental action levels. When the licensee becomes aware that an environmental action level has been reached, the licensee shall notify the Commission within three working days The licensee shall control and monitor the releases of hazardous substances. 11. Emergency Management and Fire Protection 11.1 The licensee shall implement and maintain an emergency preparedness program, and conduct exercises in accordance with CNSC regulatory document RD-353 TESTING AND IMPLEMENTATION OF EMERGENCY MEASURES The licensee shall implement and maintain a fire protection program in accordance with CSA standard N293 FIRE PROTECTION FOR CANDU NUCLEAR POWER PLANTS.

419 Nuclear Power Reactor Operating Licence Page 5 of5 PROL 13.01/ Waste Management 12.1 The licensee shall implement and maintain an in-plant waste management program The licensee shall implement and maintain a decommissioning program in accordance with CSA standard N294 DECOMMISSIONING OF FACILITIES CONTAINING NUCLEAR SUBSTANCES. 13. Security 13.1 The licensee shall implement and maintain a security program in accordance with CNSC regulatory documents: (i) (ii) (iii) (iv) S-298 NUCLEAR RESPONSE FORCE STANDARD; RD-363 NUCLEAR SECURITY OFFICER MEDICAL, PHYSICAL, AND PSYCHOLOGICAL FITNESS; RD-321 CRITERIA FOR PHYSICAL PROTECTION SYSTEMS AND DEVICES AT HIGH SECURITY SITES; and RD-361 CRITERIA FOR EXPLOSIVE SUBSTANCE DETECTION, X-RAY IMAGING, AND METAL DETECTION DEVICES AT HIGH-SECURITY SITES. 14. Safeguards 14.1 The licensee shall implement and maintain a safeguards program and undertake all measures required to ensure safeguards implementation at the nuclear facility, including physical inventory accounting and reporting of inventory changes in accordance with CNSC regulatory document RD- 336 ACCOUNTING AND REPORTING OF NUCLEAR MATERIAL. [Amended 20I4.12] 15. Packaging and Transport 15.1 The licensee shall implement and maintain a packaging and transport program. 16. Nuclear Facility-Specific 16.1 The licensee shall implement and maintain an operations program for the Tritium Removal Facility, which includes as a component a set of operating policies and principles. SIGNED at OTTA WA 0 2 _ 2 _2_01_, i-tichael Binder President CANADIAN NUCLEAR SAFETY COMMISSION