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1 I..t... I ~ C ood;oo """'" Comm;.,;'" ""'';""' ~...,.. ~~-s_a_re_ty_c_o_m_m_is_s_io_n~-de~su_re_te_ n_u_c_lea_i_re~~~~~~~~~~~~~~~~~~-~ ' Directorate of Power Reactor Regulation January 21, 2015 e-doc File Mr. W. M. Elliot Senior Vice-President uclear Engineering and Chief Nuclear Engineer Ontario Power Generation 889 Brock Road Pickering, ON Ll W 3J2 Subject: Darlington and Pickering NGS: CNSC Review of OPG Status Update #6 on Fukushima Action Items Dear Mr. Elliott: Canadian Nuclear Safety Commission (CNSC) staff have reviewed Ontario Power Generation Inc's (OPG) Progress Report No. 6 [l] on the Fukushima Action Items (FAis) [Z]. In Reference [1 ], OPG requested closure of FAI 1.9.l. CNSC staff reviewed the generic guidance on methodology provided in COG report Joint Project (JP) Revision 1, Enclosure 2 of Reference [3]. CNSC staff conclude that this generic guidance is acceptable, provided that additional elements presented in Attachment 1 are also addressed. This COG report JP R 1 should be revised to reflect the additional guidance in Attachment 1 prior to using in future licensing applications. CNSC staff performed a screening review of OPG ' s submission in Reference [1] and confirmed that the additional guidance provided in Attachment 1 was incorporated as part of site specific habitability assessments for Pickering and Darlington Nuclear Generating Stations. FAI is therefore closed for all OPG stations. The site specific habitability reports for Darlington and Pickering, Enclosures 2 and 3 respectively of Reference [1 ], are being reviewed against expectations of COG report JP Rl and Attachment 1, through normal compliance activities. Site-specific action item(s) will be initiated, if required. 280 Slater Street, Post Office Box 1046, Station B, Ottawa, Ontario K1P 5S9 Canada nuclearsafety.gc.ca 280 rue Slater, Case postale 1046, Succursale B, Ottawa (Ontario) K1P 5S9 Canada Canada suretenucleaire.gc.ca

2 Mr. W. M. Elliott e-doc All FAis are now closed for OPG. The status of closure of all FAis for OPG, as well as any related station-specific actions are documented in Attachment 2. CNSC staff conclude that OPG has strengthened reactor defence-in-depth and enhanced its emergency response at Darlington and Pickering stations in response to lessons learned from the Fukushima nuclear accident. If you have any questions related to this matter, please contact Solange Laberge, Senior Regulatory Program Officer, Pickering Regulatory Program Division, at or at solange.laberge@cnsc-ccsn.gc.ca or Ross Richardson, Senior Regulatory Program Officer, Darlington Regulatory Program Division, at or at ross.richardson@cnscccsn.gc.ca. Sincerely, ~s ~ ~ Miguel ant1m Director Pickering Regulatory Program Division Director Darlington Regulatory Program Division c.c.: Darlington Site Office, Pickering Site Office, H. Khouaja, T. Lavrisa, R. Richardson, C. Harwood, A. Viktorov, A. Bouchard, P. Collii:is, P. Phillips, C. Dodkin, H. Mulye, C. Purvis, A. McAllister, Z. C. Zeng, G. Lamarre References: 1. Letter M. W. Elliott to M. Santini and F. Rinfret, OPG Progress Report No. 6 on CNSC Action Plan -Fukushima Action Items, (containing: Darlington habitability report, N-REP ROO.f_, Enclosure 2, and Pickering habitability report, N-REP ROOl, Enclosure 3.), e-doc CNSC Letter, G. Rzentkowski to W.M. Elliott, "Opening of Fukushima Action Items (FAis) on Ontario Power Generation", February 17, CD# N-CORR , e-doc Report, M. Santini and F. Rinfret, OPG Progress Report No. 5 on CNSC Action Plan - Fukushima Action Items, CD#: N-CORR , e-doc

3 Mr. W. M. Elliott e-doc Attachment 1 Additional Generic Guidance for the CANDU Habitability Assessment OPG submitted as Enclosure 2 of Reference [3] the COG Methodology for CANDU Habitability Assessment Following a Severe Accident, COG-JP Rl. CNSC staff identified two additional elements that require to be considered in addition to those in COG-JP Rev. l ; these are as follows: 1) The list of non-radiological hazard criteria (Sections and of Enclosure 2, Reference [3]) outlined in Table 8 of the COG methodology is limited and should be expanded to include toxicity limits for other potentially hazardous substances, including those outlined in Table 1 of USNRC Reg. Guide These criteria are based on the US NIOSH IDLH Values. It is suggested that the list of non-radiological hazards should be, at least partly, based on the inventory of hazardous substances typically maintained at CANDU NPPs. Hazardous substances commonly used at NPPs include hydrazine, morpholine, and sodium hypochlorite to name a few. 2) The hazard assessment should also take into account chemical interactions that may occur in the event of a spill/release of multiple chemicals, and result in exposures of persons to the transformation product(s) resulting from those interactions. As an example, if sodium hydroxide and sulphuric acid are spilled together, then the resulting chlorine gas could pose an inhalation hazard and potentially affect habitability of the control facility.

4 Mr. W. M. Elliott e-doc Attachment 2 Summary of FAI Status for OPG by Station FAI Darlington Pickering 14 Pickering Closed Closed Closed Closed Closed Closed Closed NA Closed Closed NA Closed Closed NA Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed 1.5. l Closed Closed Closed Closed Closed Closed NA Closed Closed Closed Closed Closed 1.8. l Closed Closed Closed *Closed* *Closed* *Closed* Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed Closed 5.4.l NA NA NA Bolded status reflects changes resu lting from the review of this update.

5 Mr. W. M. Elliott e-doc Attachment 2 Summary of FAI Status, Update #6 FAI Status CNSC Comments Previously closed Related OPG specific action item PG-4163 remains Previously closed Previously closed or not applicable Previously closed or not applicable Previously closed Previously closed Follow-up actions may be raised during CNSC review Previously closed Follow-up action items may be raised during plan execution. I.4.1 Previously closed Previous! y closed Previously closed Prev iously closed OPG has provided the information requested by CNSC regarding IFB level and temperature monitoring and EME implementation. The OPG information is sufficient and no further actions are required Previous! y closed Related OPG specific action item PG-5248 remains Previously closed The site-specific instrument and equipment survivability assessment for identifying gaps and opportunities for improvement is still ongoing. Any issues identified with the site-specific assessment will be communicated to OPG in station specific action items Closed OPG requested closure of FAI for Darlington, PNGSA and PNGSB in Reference [1 ]. CNSC staff have reviewed COG report Joint Project (JP) Revision 1, Enclosure 2 of Reference [3], and found it acceptable, except for additional elements of Attachment 1 not currently incorporated in this COG report Revision 1. CNSC staff acknowledge that OPG addressed these additional elements as part of the habitability assessments provided in Reference [1] and therefore accept the methodology used for these habitability assessments. FAI is therefore closed for all OPG stations. Verification activities will be carried out through normal compliance activities, and any site specific Action Items

6 Mr. W. M. Elliott e-doc FAI Status CNSC Comments (Als) will be initiated, as required. ].10.1 Previously closed Related OPG specific action item PG-4164 is closed Previous! y closed 1.11.l Previously closed Previously closed CNSC staff review is ongoing. A station specific action item will be raised if needed to address any comments that may arise Previously closed CNSC staff review is ongoing. A station specific action item will be raised if needed to address any comments that may arise Previously closed Implementation for OPG stations is tracked under Action Item PG-5461 which remains Previously closed Previously closed Previously closed Previously closed Previously closed Previously closed Related OPG specific action item PG-4286 remains 4.1.l Previously closed Related OPG specific action item PG-4126 remains Previously closed Previously closed Previously closed Related OPG specific action item PG-4127 remains Previously closed 5.2.l Previously closed Previously closed Previously closed Previously closed Not applicable