Bruce Power. June 13, 2017 NK21-CORR NK29-CORR NK37-CORR

Similar documents
...,... \ u1" . tj.. ' ~i... . '\,,.., \ \ ~~\ i I '. ~-' ' '' f l 4',... 'lfll 6 \l ;, 0 ") \ LUI '"

Application Guide Certification of Radiation Devices or Class II Prescribed Equipment

A Guide to Ventilation Requirements for Uranium Mines and Mills

Type II Inspection Worksheet

CNSC Type I Inspections of Activities and Devices for Nuclear Substances and Radiation Device Licensees Group 3.1 Licensees

Canadian Nuclear Laboratories Comments on REGDOC 2.9.1: Environmental Protection: Environmental Policy, Assessments and Protection Measures

Guidance on the Use of Deterministic and Probabilistic Criteria in Decision-making for Class I Nuclear Facilities

Reliability Programs for Nuclear Power Plants

Reactor Facilities Licence to Prepare Site and Site Evaluation for New Reactor Facilities REGDOC-1.1.1

CIRSA has put forward the following comments, (in random order) in regard to the content of the discussion paper.

Clause 17.(3). PEO suggests if the attendant leaves the workers in the space, the workers must have a suitable means for summoning assistance.

Type II Inspection Worksheet

Licence Application Guide Class II Isotope Production Accelerators RD/GD-289

2 / 1. SUMMARY public, should be well documented, and should be reviewed on a regular basis to determine whether it continues to meet the operational

Major: Title change does not reflect that the intent of the document is the design of NEW nuclear power plants.

) ) ) ) ) ) ) ) ) ) ) ) PCAOB Release No June 9, 2004

National Sealed Source Registry and Sealed Source Tracking System. Annual Report 2014

Également publié en français sous le titre de : Rapport de surveillance réglementaire des centrales nucléaires au Canada : 2014

Radiation Protection of the Public and Protection of the Environment

Challenges for Regulators

Proposed Regulations to Ship Large Objects as Surface Contaminated Objects

Re: A Consultation Paper on the Revision of International Education Standard 8: Competence Requirements for Audit Professionals

Australian Government Auditing and Assurance Standards Board

Exposure Draft: Proposed International Education Standard IES 7 Continuing Professional Development (Revised)

Re: Comments on IASB s Discussion Paper, A Review of the Conceptual Framework for Financial Reporting

National Sealed Source Registry and Sealed Source Tracking System. Annual Report 2016

U.S. Technical Advisory Group to ISO/Technical Committee 207 Clarification of Intent of ISO 14001

SNC-Lavalin Nuclear Comments on Draft Discussion Paper DIS Small Modular Reactors: Regulatory Strategy, Approaches and Challenges

Australian Standard. Non-destructive testing Radiography of welded butt joints in metal. Part 1: Methods of test AS

NATIONAL ENERGY BOARD PIPELINE PERFORMANCE MEASURES REPORTING GUIDANCE

Generic Guidelines for the Preparation of an Environmental Impact Statement. pursuant to the Canadian Environmental Assessment Act, 2012

Safety and Health Office phone , fax GUIDELINES FOR USE OF NUCLEAR MOISTURE/DENSITY GAUGES

Transporting radioactive material - Guidance on radiation and contamination monitoring requirements, and determining a Transport Index

Summary of Laws and Regulations for Nuclear Emergency Preparedness

Oral presentation. Exposé oral. Submission from the Canadian Nuclear Association. Mémoire de l Association nucléaire canadienne CMD 18-H2.

Canada. Record of Decision. In the Matter of. Ontario Power Generation. Applicant

Employment Equity Annual Report INFO-0797

We think the word Professional scepticism needs to be defined in detail to avoid individual interpretation leading to confusion.

STRUCTURAL RADIATION SAFETY AT A NUCLEAR FACILITY

Mark Ramsay BEng MSc MSRP, CRadP

September 19, Mr. Biff Bradley, Director Risk Assessment Nuclear Energy Institute Suite I Street, NW Washington, DC

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

Types of Radiation Units

SPECIFICATION. Straightforward

Safety and Security of Supply of Medical Isotope Production

Question 1 Question 2

TRINITY ENGINEERING ASSOCIATES

Date: December 13, From: W. Turner. To: Lucia Abellan, Environmental Assessment Officer Canadian Nuclear Safety Commission

Draft Regulatory Guide DG-1080 (Proposed Revision 3 of Regulatory Guide 1.149)

Response ed to

Probabilistic Safety Assessment Safety & Regulatory Framework

September 12, Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane, Room 1061 Rockville, MD 20852

Report on Inspection of Deloitte LLP (Headquartered in Toronto, Canada) Public Company Accounting Oversight Board

Oral presentation. Exposé oral. Submission from the Concerned Citizens of Renfrew County and Area

Geoscience Assessment Officer

Enterprise and Industry Directorate-General European Commission B-1049 Brussels Belgium BY TO and

June 10, Dear Ms Fox

Regulation respecting X-ray Safety - made under the Occupational Health and Safety Act

Radiation Environment and Shielding Design Optimization at MEIC

Draft Branch Technical Position on Concentration Averaging and Encapsulation, Revision 1

Delivered Via ;

Summary of Public Comments received on the Challenge substance Hydrazine (CAS ) Draft Screening Assessment Report for Batch 10

February 23, Office of the Secretary Public Company Accounting Oversight Board 1666 K Street, N.W. Washington, D.C.

INVITATION TO COMMENT: IASB AND IFRS INTERPRETATIONS COMMITTEE DUE PROCESS HANDBOOK

Design of Transport Container

IAEA SAFETY STANDARDS for protecting people and the environment. Predisposal Management of Radioactive Waste from Nuclear Fuel Cycle Facilities

Job Evaluation Guide for TMG. October 2016

Readiness for Regulating Small Modular Reactors

Subject: Peer review of Duntroon Quarry hydrogeologic modelling: Report #1

A Status Report of the Auditor General of Canada to the House of Commons

RADIOLOGICAL PROTECTION

Int. J. Nuclear Energy Science and Technology, Vol. X, No. Y, xxxx 1

June 9, 2008 PARTIES INTERESTED IN EVALUATION REPORTS ON TERMITE- RESISTANT FOAM PLASTICS

Subject: Comments on the Retail Tariff Notification Framework Documentation

Regulation of existing and new nuclear power stations in South Africa in the light of the Fukushima Accident

Expanded Use of Gamma Gauges for Security Screening. L. Bray

Near-surface Disposal Facilities on Land for Solid Radioactive Wastes

RESEARCH REACTOR FRJ-1 (MERLIN) THE CORE STRUCTURES OF THE REACTOR BLOCK ARE DISMANTLED

10 June 2011 Dear Stephenie, COMMENTS ON PHASE I, II AND III OF THE IPSASB S CONCEPTUAL FRAMEWORK PROJECT

A Critique of CNSC s Presentation to Owen Sound City Council. Table of Contents

Safeguards and Nuclear Material Accountancy REGDOC

RE: Proposed Rule Questions Under Consideration for GMO Disclosure and Labeling

, ( ) ( TELUS

Office of Internal Audit

Office of the Secretary PCAOB 1666 K Street, N.W. Washington DC USA. 15 February Dear Sir or Madam,

Arnold Schilder Chairman International Auditing and Assurance Standards Board 529 Fifth Avenue 6th Floor New York, NY

BCIT Safety Manual. Radiation Safety Program Manual. Part 6; Section 90

Inspection of Petrie Raymond, Chartered Accountants L.L.P. (Headquartered in Montreal, Canada) Public Company Accounting Oversight Board

November 15, 2017 Office of the Secretary Public Company Accounting Oversight Board 1666 K Street, N.W. Washington, D.C.

Power JoIst ADI-40, ADI-60, ADI-80 I-joists

New Swedish Regulations for Clearance of Materials, Rooms, Buildings and Land Efraimsson, Henrik Swedish Radiation Safety Authority, SWEDEN

Radiological Services Radiation Protection Technician Development Program

OBJECTIVE 24: POST-EMERGENCY SAMPLING OBJECTIVE

Act No. 56 of May 23, 2007

July 23, 2010 PARTIES INTERESTED IN REFLECTIVE FOIL INSULATION

Auditing Practices Board

GCSE BITESIZE Examinations

RADIOGRAPHIC EVALUATION OF CORROSION AND DEPOSITS: IAEA CO-ORDINATED RESEARCH PROJECT ON LARGE DIAMETER STEEL PIPES

Regulating Uranium Mines and Mills in Canada

Licensing Nuclear Power Plants in Canada. Ensuring Safe and Environmentally Acceptable Operations

Transcription:

June 13, 2017 NK21-CORR-00531-13629 NK29-CORR-00531-1 4271 NK37-CORR-00531-02792 CNSC CCSN 1111111111111111111111111 5275647 ~ Bruce Power Mr. B. Torrie Director General, Regulatory Policy Directorate Canadian Nuclear Safety Commission P.O. Box 1046 280 Slater Street Ottawa, Ontario K1 P 5S9 Dear Mr. Torrie: Bruce Power comments on draft REGDOC-2.5.5. Design of Industrial Radiography Installations The purpose of this letter is to provide feedback on this draft Regulatory Document, which offers concise, well-written guidance on the design of industrial radiography installations. As always, Bruce Power appreciates the CNSC's efforts to seek stakeholder input. Following a collaborative review of this draft with our industry peers at Ontario Power Generation, New Brunswick Power and Canadian Nuclear Laboratories, we found this document to be properly written at a guidance level and in a manner truly helpful to radiation protection experts. While pleased with the overall quality of this draft, which could serve as an example of how other Regulatory Documents should be written, our collective review did generate some suggestions and requests for clarification as detailed in Attachment A. If you require further information or have any questions regarding this submission, please contact Mr. Maury Burton, Manager, Nuclear Regulatory Affairs, at (519)-361-2673 extension 15291, or maury.burton@brucepower.com. Yours truly, Frank Saunders Vice President Nuclear Oversight and Regulatory Affairs Bruce Power cc: Bruce Site Office (Letter only) K. Lafreniere, CNSC Ottawa K. Owen-Whitred, CNSC Ottawa NK21-CORR-00531-13629 NK29-CORR-00531-14271 NK37-CORR-00531-02792 Bruce Power Frank Saunders Vice President - Nuclear Oversight and Regulatory Affairs P.O. Box 1540 B 10 4th floor W Tiverton ON NOG 2TO Telephone 519 361-5025 Facsimile 519 361-4559 frank. saunders@brucepower.com

Attachment A Bruce Power comments on draft REGDOC-2.5.5, Design of Industrial Radiography Installations NK21-CORR-00531-13629 NK29-CORR-00531-14271 NK37-CORR-00531-02792

Suggested Change (if applicable) 1 1. Preface and Radiography may be performed in Define 'radiography installation' to Inclusion of locations not specifically designed for radiography imposes requirements for Glossary locations that were not designed as exclude locations which are not radiography type shielding for areas not designed for radiography. radiography installations. These locations specifically designed for radiography, may have shielding (e.g. structural walls) by revising: even though they were not designed for - Preface, 3rd paragraph, 1st sentence, the purpose of radiography. The "A radiography installation... cell or document's scope should be more clearly vault specifically designed for defined and not so general as to include radiography, where... II such locations. The definition used to - Glossary definition, describe a radiography installation is too Radiography installation general and inconsistent with current A shielded enclosure... specifically industry practice. designed for radiography, where..." 2. Intro Not all CNSC regulatory requirements Remove the last sentence of the 4th apply to uses of nuclear substances and paragraph, which currently reads, "All radiation devices within a radiography CNSC regulatory requrrements, installation. including those specific to radiography, apply to all uses of nuclear substances and radiation devices within a radiography installation." 3. 2 The following statement in the 3rd Remove, "which are always functional" The statement may lead some licensees who have not experienced failure in the General Design paragraph has not always been observed: and replace with wording suggestive of engineered controls (e.g. interlock not working as expected) to believe that engineered Principles "The design of a radiography installation high reliability. controls are fool proof, which is not the case. should give preference to the use of engineered controls where ever possible, which are always functional." 4. 2 The 4tn paragraph currently reads: Remove skyshine from list of General Design "Engineered controls include: radiation engineered radiation exposure Principles exposure controls - distance, shielding, controls. skyshine..." Skyshine is an outcome of the level of shielding, not an engineered control. It is a component of exposure that can be managed or reduced via implementation of engineered controls. NK21-CORR-00531-13629 I NK29-CORR-00531-14271 I NK37-CORR-00531-02792 Page 1of4

Suggested Change (tf applicable) 1 5. 3.1.2 The 3rd paragraph currently reads: "For Suggest being specific about the Shielding any given nuclear substance, the proportional relationship by relating relationship between radiation dose and the activity of the source is directly dose rate to activity. Dose is an inferred consequence. proportional... II 6. 3.1.2 Consistency needed relative to other Add " may" to 4th sentence of 1st Shielding references in the document w ith respect paragraph to read "... radiography may to high- and low-energy gamma. emit high-energy gamma... " 7. 3.1.2 The 1st sentence in the 2nd last paragraph Add the words "to non-n EWs" after The document could be misinterpreted and overly restrictive beyond the existing Shielding (page 6) currently reads, "If the design 0.5 msv/year. The sentence should regulations without the suggested addition. Th is regulatory requirement only applies to does not or cannot provide enough then read: "If the design does not or non-news. shielding to meet the dose rate limit of cannot provide enough shielding to 0.1 msv/week or 0.5 msv/year, as well as meet the dose rate limit of 0.1 demonstrate... II msv/week or 0.5 msv/year to non- NEWs, as well as demonstrate... II 8. 4.2 The 4tn paragraph, 1st sentence reads, "All Request clarification on what is meant Restricting use of locations adjacent to the radiography by the plan (design layout, approval areas adjacent to installation should be clearly marked on a documentation, operating installation the radiography plan of the installation... II procedures). 9. 4.2 The 5th paragraph, 1st sentence reads, is required with respect to Restricting use of (( Based on the exposure potential for the design requirements for shortareas adjacent to areas adjacent to the radiography duration, high-field transients the radiography installation, the Certified Exposure Device evaluated to be within the dose limits, installation Operator (CEDO) should monitor exposures in these areas to ensure that radiation doses are not exceeded." is needed to ensure implementation of radiation controls at radiography installations meets the regulatory requirements. but greater than the dose rate limits. NK21-CORR-00531-13629 / NK29-CORR-00531-14271 / NK37-CORR-00531-02792 Page 2 of 4

Suggested Change (if applicable) 1 The use of the term exposure appears to be intentional, in that it is recognized that as the source transitions from the shielded location to the collimator, the dose rates may be greater than the prescribed limits (0.1 msv/h or 25µSv/h), even if the dose is well below the limits for non-news at those locations. 10. 4.2 The 1 st sentence in the last paragraph of Change to: Restricting use of the section regarding exposure potential "... ensure that radiation dose rate areas adjacent to for areas adjacent to the radiography limits are not exceeded." installation incorrectly refers to " radiation the radiography doses are not exceeded," and should installation refer to dose rate limits. 11. 4.2.1 Workload should be calculated using a Add sentence to end of 2na paragra ph: Adjusting the conservative estimate of the maximum "Other appropriately conservative workload total exposure time, not necessarily the assumptions can also be used. For maximum time per shot x of shots. example, Appendix A provides an Clarify that there are other appropriately conservative assumptions. Note - example of dose calculations using the average time per shot." Appendix A uses the average time per shot (not max). 12. 4.2.2 In 3rd paragraph, CEDOs should only be Add sentence to end of paragraph: Controlling required to verify the occupancy of "If radiography installation has occupancy of adjacent areas that will be impacted by sufficient shielding, adjacent areas will the radiography. If radiography not be impacted and their occupancy surrounding areas installation has sufficient shielding, does not need to be verified." adjacent areas will not be impacted and their occupancy does not need to be verified. 13. 4.3 Please clarify that the last paragraph is for Remove the phrase, " In all cases" from Monitoring for radiography licensees to consult with the paragraph. human presence prior to exposures applicable fire codes, and is not intended to add any additional requirements for a NK21-CORR-00531-13629 I NK2 9-CORR-00531-14271 I NK37-CORR-00531-02792 Page 3 of 4

Suggested Change (if applicable) 1 radiography installation. 14. Glossary The definition of industrial radiography Suggestion is to make the definition currently reads, "The use of certified broader so it matches the NSRDR's exposure devices to conduct the non- definition of an exposure device. destructive examination of the structure of welds, castings and building components. Also called gamma radiography." The definition is too restrictive. What if a radioactive source is used to do radiography of plants, samples or nuclear forensics items? Radiography should be broad enough to mean "taking pictures" and not specify the media with which the pictures are being taken. The rad iographs can also be film or digital. Industrial radiography should only exclude medical purposes and should technically cover neutron radiography (because neutron rad iography is used for industrial but non-med ical purposes). A definition of industrial radiography that would work (for example is): "the use of an exposure device containing a nuclear substance to carry out non-destructive examination of items for industrial purposes; not used for medical diagnostic purposes; also called gamma radiography." 15. Glossary The term "workload " is not defined Add the definition for "workload" as it applies in this document 16. Appendix A Provide consistent wording throughout to Change A.l, Step 4: th correctly define TVL. TVL reduces dose Alter 5 paragraph, last sentence to rate to 1/10 - not by 1/10 read, "TVLl is.... reduce the dose rate to one tenth." Scenario 3 TVL2 definition to read, "is the thickness... dose rate to another one tenth." NK21-CORR-00531-13629 / NK29-CORR-00531-14271 / NK37-CORR-00531-02792 Pa ge 4 of 4