Record of Proceedings, Including Reasons for Decision

Transcription

1 Record of Proceedings, Including Reasons for Decision In the Matter of Applicant Hydro-Québec Subject Application for the renewal of the operating licence for the Gentilly-2 Nuclear Generating Station Date December 16, 2002

2 RECORD OF PROCEEDINGS Applicant: Address/Location: Purpose: Hydro-Québec 75 René-Lévesque Blvd. West, Montréal (Quebec) H2Z 1A4 Application for the renewal of the operating licence for the Gentilly-2 Nuclear Generating Station Application received: April 11, 2002 Date(s) of hearing: September 12, 2002 November 14, 2002 Location: Canadian Nuclear Safety Commission (CNSC) Public Hearing Room, 280 Slater St., 14th. Floor, Ottawa, Ontario Members present: L.J. Keen, Chair L.J. MacLachlan* A.R. Graham M.J. McDill Y.M. Giroux J.A. Dosman* C.R. Barnes (*present for day-1 only and therefore did not participate in the decision) Counsel: Secretary: Recording Secretary: I.V. Gendron M.A. Leblanc C.N. Taylor Applicant Represented By M. Doyon, Director, Thermal and Nuclear Power Generation M. Désilets, Chief, Gentilly-2 C. Drouin, Chief, Technical Services G. Ouellet, Vice President, Production Operations R. Boisvert C. Mailhot M. Hamel M. Rivard M. Jean CNSC Staff J. Blyth P. Thompson R. Leblanc R. Ferch D. Newland Intervenors See Appendix A Document Number CMD 02-H18.1 CMD 02-H18.1A Document Number CMD 02-H18 CMD 02-H18.A Document Number Decision and Reasons: Licence/Amendment: Issued: X Date of Decision: November 14, 2002

3 1. Introduction Hydro-Québec has applied to the Canadian Nuclear Safety Commission for renewal of its Nuclear Power Reactor Operating Licence (PERP10.03/2002) for the Gentilly-2 Nuclear Generating Station (NGS). The current licence will expire on December 31, Hydro- Québec has applied for renewal of the licence for a period of five years. The Gentilly-2 NGS is located on the south shore of the St. Lawrence River about 15 kilometres southeast of the City of Trois-Rivières, Québec. The reactor is a CANDU PHW (pressurized heavy water) reactor with a design production capacity of 675 MW(e). The power station went into commercial operation on October 1, The proposed activities to be carried out at the Gentilly-2 NGS under the renewed licence are the same as those currently authorized under the existing licence. No activities related to the possible future refurbishment of the Gentilly-2 NGS were proposed by the applicant, or considered by the Commission, in these proceedings. Issues: In considering the application, the Commission was required to decide, pursuant to subsection 24(4) of the Nuclear Safety and Control Act, if: a) Hydro-Québec is qualified to carry on the activity that the licence would authorize; and b) if, in carrying on that activity, Hydro-Québec would 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. Public Hearing: The Canadian Nuclear Safety Commission (the Commission), in making its decision, considered information presented for a public hearing held on September 12 and November 14, The Commission received written submissions and heard oral presentations from Hydro-Québec (CMD 02-H18.1, CMD 02-H18.1A, CNSC staff (CMD 02-H18 and CMD 02-H18.A) and six intervenors (see Appendix A for a list of intervenors and related hearing documents). The public hearing was conducted in accordance with the Canadian Nuclear Safety Commission Rules of Procedure. 2. Decision Based on its consideration of the matter, as described in more detail in the following sections of this Record of Proceedings, the Commission concluded that Hydro-Québec is qualified to carry on the activity that the licence will authorize. The Commission also determined that Hydro- Québec, in carrying on that activity, will make adequate provision for the protection of the

4 - 2 - 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, the Commission, pursuant to section 24 of the Nuclear Safety and Control Act, issues a Nuclear Power Reactor Operating Licence for the Gentilly-2 Nuclear Generating Station, to Hydro-Québec, Montreal, Québec. The licence, PERP 10.00/2006, is valid from January 1, 2003, to December 31, 2006, unless suspended, amended, revoked or replaced. The Commission includes in the licence the terms and conditions of the former licence with the modifications and additions recommended by CNSC staff in CMD 02-H18 and CMD 02-H18.A. With this decision, the Commission requests that CNSC staff present an interim status report to the Commission on the Gentilly-2 NGS following the first two years of the four-year licence term. To the extent practical, CNSC staff may combine the more detailed station-specific interim report for Gentilly-2 NGS with the Annual Industry Report on Power Reactors to be presented to the Commission in early Issues and Commission Findings In making its decision, the Commission considered a number of issues relating to the proponent s qualification to carry out the proposed operation of Gentilly-2 NGS, and to the adequacy of the proposed measures 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. The Commission s findings on these issues are summarized below. 3.1 Radiation Protection As part of its evaluation of the adequacy of provisions for protecting the health and safety of persons, the Commission considered the past performance of Hydro-Québec in the area of radiation protection. CNSC staff reported that although the results of Hydro-Québec s radiation protection program exceed expectations (i.e., the workers and the public reportedly received doses well below the regulatory limits during the current licence period), Hydro-Québec has not fully met expectations in the implementation of the radiation protection program. Most significantly, during the scheduled outage in 2002, employees were found to be not following proper procedures when dealing with the tritiated heavy water moderator. CNSC staff indicated that corrective actions for this incident are currently under discussion with Hydro-Québec and that improvement is anticipated. CNSC staff also noted that Hydro-Québec has yet to document its radiation protection program in a manner that meets the principles of quality in CSA Standard N Hydro-Québec is currently revising the document to address the comments of CNSC staff and conform to CSA

5 - 3 - Standard N Hydro-Québec expressed its commitment to address the above concerns of CNSC staff. Hydro-Québec also noted that worker doses have improved since 2000 as a result of coolant pump modifications. As well, Hydro-Québec described its use, since 2001, of new specialized radiation survey instruments and tools that will improve work planning, thereby further lowering worker exposures in high dose areas. In its intervention, Mouvement Vert Mauricie Inc. stated that Hydro-Québec was not reporting worker doses to the National Dose Registry in Ottawa as required. In response to a question from the Commission on this allegation, CNSC staff stated that, on infrequent occasions, workers have failed to wear their dosimeters. The doses received during those brief periods would not be recorded. CNSC staff, however, does not consider these types of health surveillance errors to be a significant issue at Gentilly-2 NGS and is satisfied with the corrective actions taken. CNSC staff further stated that all over-exposures are reported to the CNSC. Intervenors, including the Canadian Coalition for Nuclear Responsibility and Mouvement Vert Mauricie Inc. also expressed their concerns about what they view as a complacent attitude towards safety at Gentilly-2 NGS. The Commission is concerned that the radiation protection program does not yet meet the expected standards for quality assurance. The Commission also considers that more can be done to conform to the principle of ALARA (as low as reasonably achievable) in implementing the program. The Commission is concerned about the above-noted failure of some individuals to follow proper safety procedures. The Commission is of the view that such behaviour may be indicative of problems with the general safety culture at Gentilly-2 NGS. The issues of quality assurance and safety culture are addressed more fully by the Commission in section 3.5 (Performance Assurance) below. Nevertheless, based on the results of Hydro-Québec s radiation protection program, and the steps being taken by Hydro-Québec to address the issues raised by CNSC staff on the program documentation and its implementation, the Commission is generally satisfied that Hydro-Québec has made, and will continue to make adequate provision to protect persons from the effects of radiation. 3.2 Conventional Health and Safety Hydro-Québec s program and performance in conventional (non-radiological) health and safety at Gentilly-2 NGS is another factor considered by the Commission in its assessment of the proposed provisions for protecting the health and safety of persons. CNSC staff reported that, while the design of the conventional health and safety program meets expectations, Hydro-Québec has experienced problems with its implementation. As noted above for radiation protection, CNSC staff pointed to an apparent lack of sensitivity of some workers to

6 - 4 - the measures available and required for their personal protection. CNSC staff stated that these concerns were raised with Hydro-Québec and that corrective actions are under discussion. Despite this finding, CNSC staff reported that the number of reported accidents remains acceptably low and that none of the reported accidents was attributed to negligence on the part of Hydro-Québec. Hydro-Québec added that there has been a gradual reduction in the number of accidents in recent years, but with a slight increase in In response to a question from the Commission on that trend in 2001, Hydro-Québec confirmed that none of the incidents involved radiation, or were directly related to the operation of the plant. Based on this information, and in particular the low accident rate being consistently realized at the facility, the Commission is satisfied that Hydro-Québec is making adequate provision to protect the health and safety of persons from conventional hazards at the site. Nevertheless, and as noted above with respect to radiation protection (including the related remarks of intervenors), the Commission is concerned that there may be further opportunities to improve the safety culture at Gentilly-2 NGS and thus further reduce the potential for accidents. The Commission expects senior management of Hydro-Québec to personally attend to safety culture issues at the facility. The issue of safety culture is addressed further below in section 3.5 (Performance Assurance). 3.3 Environmental Protection To determine whether Hydro-Québec will, in carrying out the proposed activities, make adequate provisions to protect the environment, the Commission examined Hydro-Québec s environmental protection programs and performance. CNSC staff reported that although the environmental performance of the facility has exceeded expectations, the definition of the program remains deficient. CNSC staff noted that Hydro- Québec is on schedule to correct the remaining deficiencies by June Despite the program deficiencies, CNSC staff reported that Hydro-Québec has successfully maintained all radiological releases to the environment at levels well below the regulatory limits defined by the Derived Release Levels (DRLs); that is, at levels generally below 1% of the DRLs). CNSC staff also noted that Hydro-Québec carried out an Ecological Risk Assessment of the facility operations at the request of the CNSC staff. The study found no significant risk to the environment. The final report is currently under review by CNSC staff.

7 - 5 - Fish Mortality: CNSC staff described an earlier problem (initially identified in 1997) involving the death of fish in the cooling water discharge canal. The problem, which occurred at the start of planned maintenance outages, has since been corrected. In response to the Commission questions on the problem, CNSC staff explained that the fish in the canal were killed by the sudden cooling of water in the discharge canal when the reactor was shut down for maintenance in the winter or spring seasons. Fish are attracted, and become adapted to the warm water in the canal during reactor operations. The fish, however, could not sustain the rapid rate of temperature change when the source of the heat was abruptly terminated. CNSC staff noted that the death of the fish was not related to radiation or other contaminant release to the canal. CNSC staff noted, however, that the killing of fish in this manner is a violation of the Fisheries Act and that corrective actions were required. As a result, Hydro- Québec now follows a protocol that involves both a more gradual cooling of the discharge during shutdown operations, and the timing of planned outages to when the ice is off the river. CNSC staff noted that, to date, the protocol appears to be effective in preventing further fish mortality. In response to a question from the Commission about the significance of the past fish kills, CNSC staff stated that carp was the principal species involved and that the number of fish affected, while in the hundreds per incident, is not significant in relation to the populations in the St. Lawrence River. Radiological Releases Effects on Aquatic Life and Humans: Intervenors, including Raphaël Thierrin, Mouvement Vert Mauricie Inc. and the Canadian Coalition for Nuclear Responsibility, expressed concerns about what they believe to be large releases of tritium from Gentilly-2 NGS a substance they identified as having been declared a persistent toxic substance by the International Joint Commission (IJC). Mouvement Vert Mauricie Inc. went on to suggest that the releases of radioactivity from the plant may have been the cause of congenital health effects observed some years ago on rue des Glaïeuls. Mouvement Vert Mauricie Inc. expressed its dissatisfaction with the investigation of those effects by the Québec department of health, noting that the study did not look at Gentilly-2 NGS as a possible cause because it was more than 15 kilometers away. In response to questions from the Commission about these comments of intervenors, Hydro- Québec stated that it monitors for tritium and a variety of other radiological and non-radiological contaminants in all of its effluents, and in the St. Lawrence River down stream of the facility. Hydro-Québec reported that the risks to the environment and people remain negligible. CNSC staff concurred with this conclusion of negligible effect and added that tritium was, in fact, not declared to be a toxic substance by the IJC. CNSC staff further stated that that releases of tritium from Gentilly-2 NGS, and resulting very low concentrations in the St. Lawrence River, are not toxic and thus pose no danger to populations of fish and other organisms. CNSC staff noted that this conclusion was further demonstrated by the above-noted ecological risk assessment that was recently conducted for the Gentilly-2 NGS.

8 - 6 - On the matter of the provincial health study of congenital health effects observed on rue des Glaïeuls several years ago, Hydro-Québec and CNSC staff stated that, while they did not recall the specifics of the study, they confirmed that the incident involved a few cases over a short duration of time, and that there was no link made to the Gentilly-2 NGS. Environmental Monitoring Program: Further with respect to the environmental monitoring program at Gentilly-2 NGS, Hydro-Québec stated that the program addresses all points of release of contaminants from the site, key ecological receptors, and important aspects of the human food-chain pathway. In addition, Hydro-Québec noted that the environmental management program for Gentilly-2 NGS is certified under ISO CNSC staff expressed its satisfaction with the breadth and scope of the environmental monitoring program at Gentilly-2 NGS, subject to Hydro-Québec addressing the deficiencies in the program definition identified above. Conclusion on Environmental Protection: Based on the above information, the Commission concludes that Hydro-Québec has made, and will continue to make, adequate provisions to protect the environment during future facility operations. The Commission is satisfied that the release of contaminants from the facility has not had a significant effect on populations of biota or human health. The Commission is, however, concerned that the definition of the environmental protection program remains below expectations. The Commission requests that the remaining issues be brought to closure as soon as possible. In the meantime, the Commission is satisfied that the environmental monitoring program will continue to detect any adverse effects so that appropriate corrective action could be taken in a timely manner. 3.4 Operating Performance The Commission also considered the operating performance at Gentilly-2 NGS as a further indication of Hydro-Québec s qualifications to continue operating the plant and, in doing so, provide adequate protection for the environment, and the health and safety of persons. With respect to operational performance in general, CNSC staff reported that Hydro-Québec has met, and continues to meet, expectations. In support of this general conclusion, CNSC staff reported on: the low incidence of system malfunctions, unplanned transitory events and temporary design alterations; the appropriately high availability of all special safety systems; the acceptable processes for requesting operational changes; and Hydro-Québec s responsive system for following-up on regulatory concerns and corrective actions. Hydro-Québec added that improvements in operating performance at Gentilly-2 NGS are further evidenced by the recent

9 - 7 - increase in the rate of electrical power production, together with the downward trend in the number of minor non-compliances with the licence. CNSC staff described one operating performance incident involving the failure of a temporary inflatable plug in a steam line. The incident was investigated by both CNSC staff and Hydro- Québec and a plan of action to prevent further incidents is now being followed. In response to the Commission s questions on this event, Hydro-Québec stated that inflatable plugs are commonly used for isolating pieces of equipment during maintenance. Hydro-Québec explained that a procedural error caused an overpressure of the system and failure of the plug. Hydro- Québec added that the remaining two recommendations from the investigations of the incident will be implemented by the end of Hydro-Québec s ability to effectively manage maintenance outages was another indicator of operating performance considered by the Commission. In this regard, Hydro-Québec reported its success in safely completing a high percentage of the planned work during recent outages. CNSC staff, while acknowledging Hydro-Québec s general success in completing maintenance outages, rated Hydro-Québec s operating performance in this area as below expectations. This rating is due to the failure of some workers to follow safety procedures during the maintenance of the tritiated heavy water moderator system (see section 3.1 above). Based on this information, the Commission concludes that the operating performance at Gentilly-2 NGS provides a positive indication of Hydro-Québec s ability to carry out the proposed activities with adequate protection of the environment and people. The Commission, however, (as elaborated in section 3.5 below) expects further improvement with respect to adherence to safety procedures. 3.5 Performance Assurance Performance assurance, including aspects of quality assurance, human factors, and training, is another important area the Commission examined in making its decisions on Hydro-Québec s qualifications and protection measures Quality Assurance CNSC staff reported that the quality assurance program at Gentilly-2 NGS is deficient in both the program definition and its implementation. In particular, CNSC staff noted that the program still does not conform to the applicable CSA standards. Although concerned about the long time that Hydro-Québec has taken thus far to address these concerns, CNSC staff expressed its general satisfaction with Hydro-Québec s current level of attention and progress in this area. In responding to the Commission s questions on the quality assurance issues, Hydro-Québec emphasized that quality assurance has existed at Gentilly-2 NGS since it first began operation in 1983, and that approximately 150 documents exist for quality control. Hydro-Québec also pointed to its high level of operating performance as evidence that its quality program is effective. Hydro-Québec stated that the current quality assurance issues relate to the need to

10 - 8 - ensure the existing program conforms to the specific requirements introduced into the licence in Hydro-Québec stated that it is committed to being in conformance with those requirements, including the applicable CSA standards, in Human Factors CNSC staff reported that it continues to have positive discussions with Hydro-Québec on various means of improving human factors at Gentilly-2 NGS. One remaining area of concern to CNSC staff is in regard to the systematic integration of human factors in the design change process. CNSC staff has made specific recommendations in this area and improvement is expected. Hydro-Québec reported that a number of human performance initiatives have been instituted, including the creation of a working group dedicated to improving human performance. All employees are also now required to take specific human performance training. With reference to the worker safety attitude problems identified above (see sections 3.1 (Radiation Protection) and 3.2 (Conventional Health and Safety)), and further referred to in the interventions from the Canadian Coalition for Nuclear Responsibility and Mouvement Vert Mauricie Inc., the Commission questioned Hydro-Québec on how the employees and unions are responding to the above-noted human performance initiatives. Hydro-Québec replied that it is continuing to change worker attitudes towards safety procedures through working level discussions and team-based work planning sessions. Hydro-Québec pointed to the reduced level of non-conformances as evidence of this change. Hydro-Québec has also increased the number of specially trained supervisors on the shop floor and is working with the unions to help modify worker behaviour. Hydro-Québec stressed that the reported problems relate to a few individuals and that it anticipates it will meet all CNSC expectations for worker safety in the near future. A number of representatives from the unions were present on the second day of the hearing. The Commission questioned these union representatives on their reactions to the safety concerns identified by CNSC staff and on the initiatives of Hydro-Québec to address them. In response, the unions expressed a shared concern for the safety issues and support of the improvements being made. The unions expressed the view that one safety incident is too many and that they are moving towards a principle of zero-tolerance. The unions stated that they are taking steps to advise workers on the procedures that cannot be compromised or altered. It was noted that while some disciplinary action is being taken, the main thrust for the unions is to promote behaviours of self-verification on the job, so that everyone is doing their part to protect themselves and likewise assist their co-workers. In response to a follow-up question from the Commission on how safety at Gentilly-2 NGS compares to the other sectors in Hydro-Québec, the union representatives expressed the view that, while Hydro-Québec is achieving a high level of safety in all sectors, the nuclear sector is held to more rigorous expectations. The Hydro-Québec representatives confirmed this observation and remarked that, following a vertical audit of safety in the company, the safety practices in the nuclear sector were found to be a model for the rest to follow. Hydro-Québec

11 - 9 - reiterated that safety is a very important strategic part of its operations and that it is committed to continuous improvement in this area. While the Commission acknowledges and appreciates the stated commitments of Hydro-Québec and its union representatives, it looks forward to seeing real evidence of an improved safety culture early during the next licence period. The Commission expects all levels of management at Hydro-Québec to be committed to providing the appropriate environment for, and promoting the establishment of, a highly effective safety culture at Gentilly-2 NGS, including the taking of appropriate and prompt corrective or disciplinary action where necessary. The Commission expects that CNSC staff will continue to closely monitor worker safety issues and behaviours at the station and, where significant problems persist, inform the Commission of the circumstances and measures taken. Depending on the significance, that information could be brought to the Commission s attention as part of the routine Annual Industry Report for Power Reactors, the required interim status report on Gentilly-2 NGS (approximately in December 2004), or, where more urgent, a Significant Development Report at any regularly scheduled meeting of the Commission Training With respect to training at Gentilly-2 NGS, CNSC staff reported that Hydro-Québec is making satisfactory progress on a number of issues and actions raised previously by CNSC staff. However, CNSC staff maintains that further action is required before the training program fully meets expectations. Specifically, CNSC staff referred to the work remaining on the training programs for Shift Supervisors and Control Room Operators, Engineers, and Technical Support Technicians. CNSC staff reported Hydro-Québec s satisfactory progress in addressing the new conditions of accreditation of personnel, and on the preparations for the trial written and simulator examinations that will be carried out in accordance with the new Canadian Standard for the Requalification Testing of Certified Shift Personnel at Nuclear Power Plants. Hydro-Québec added that it has recently hired 27 new operators and will be soon adding new training on radiation protection and security. Maintenance and fueling machine operation are also notable areas where training action plans are underway. Based on the above information, the Commission is satisfied with the direction Hydro-Québec is moving in regard to training. The Commission is also generally satisfied that Hydro-Québec understands the CNSC expectations with respect to training, and is committed to meeting those expectations in the near future. Conclusions on Performance Assurance While recognizing that Hydro-Québec does not currently meet all expectations with respect to performance assurance at Gentilly-2 NGS, the Commission is satisfied that Hydro-Québec has a good understanding of what needs to be done and that it is now applying the necessary resources

12 and energy to bring the remaining issues to closure in a timely manner. The Commission is also of the view that the remaining issues are not of a nature or level of significance that would inhibit the Commission from proceeding with the facility licensing at this time. Nevertheless, the Commission wishes to stress the importance of Hydro-Québec addressing the remaining issues without undue delay. The Commission requests CNSC staff to also continue to pay close attention to compliance verification in these matters and to keep the Commission informed of any significant developments. 3.6 Design Adequacy Many of the provisions for protecting the environment and the health and safety of persons relevant to a licensing decision are inherent in the design of a facility. The Commission therefore examined the following factors related to the current status of the Gentilly-2 NGS design: the status and currency of the Safety Analysis; the relevant generic CANDU safety issues; the adequacy of related research and development; the adequacy of fire protection; the environmental qualification of equipment and aging; and the status of emergency core cooling systems. The Commission also considered a concern raised in the intervention by the Canadian Coalition for Nuclear Responsibility concerning the proximity of high-pressure steam pipes to the control room Safety Analysis With respect to the Safety Analysis, CNSC staff noted that constraints on the operation were instituted in 1999 and will remain in effect until uncertainties related to the analysis of large lossof-coolant-accidents are resolved using a new industry tool set of reactor physics codes. This work is currently underway. The safety issues related to the uncertainty will continue to be effectively mitigated by the above-noted operational constraints. Also with respect to the Safety Analysis, CNSC staff reported that a limit on operating power is being used to mitigate a potential risk related to the efficiency of the shutdown system following a failure of a primary coolant pump. Further on the adequacy of the Safety Analysis, CNSC staff reported that earlier concerns relating to sudden loss of Class IV power and sudden loss of electrical power trip have now been resolved with new analytical methods. CNSC staff also reported that, by the end of 2002, the Safety Analysis will have been extended to include an examination of the effect that an automatic shutdown of coolant pumps (resulting in a loss of system pressure) would have on the reactor fuel.

13 Based on this information, the Commission is satisfied that the Safety Analysis is adequate and is being appropriately updated as new issues, information and analytical methods arise Generic Action Items Generic Action Items or GAIs are complex technical issues that affect more than one CANDU nuclear power plant and that resolution of these issues usually requires multi-year research programs at the industry level. With respect to the GAIs, CNSC staff expressed satisfaction with Hydro-Québec s related programs and their implementation. CNSC staff provided the Commission with a brief summary of the status of 12 GAIs that were relevant to the Gentilly-2 NGS. CNSC staff reported that 2 of these GAIs were recently closed for Gentilly-2, and that satisfactory progress continues to be made on the remaining items. The closed items include GAI 95G03 (Compliance with Bundle and Channel Power Limits) and GAI 98G01 (PHT Pump Operation under 2-Phase Flow Conditions). Based on this report, the Commission is satisfied that Hydro-Québec is making adequate progress towards closing the GAIs at Gentilly-2 NGS Reseach and Development CNSC staff stated that, in its opinion, the nuclear industry s past budget cuts to research and development has made some important short and medium term areas vulnerable. As a result, CNSC staff has requested more detailed reporting on research and development programs to facilitate its monitoring. While the Commission does not consider that the reported vulnerabilities are an impediment to licensing Gentilly-2 NGS at this time, the Commission requests that CNSC staff keep the Commission informed of the status of research and development programs. This can be done by way of the Annual Industry Report or, if specific to the licensing of Gentilly-2 NGS, in the requested interim report in 2 years time Fire Protection On the matter of fire protection, CNSC staff reported that it is fully satisfied with Hydro- Québec s response to the results of several fire protection evaluations that have been carried out at Gentilly-2 NGS. Hydro-Québec added that an independent evaluation of its training program for emergency response personnel demonstrated that improvements have been made in fire protection. Based on this positive evaluation, the Commission finds the fire protection program at Gentilly-2 NGS to be acceptable.

14 Environmental Qualification and Component Aging Hydro-Québec acknowledged the need to continually review and verify the environmental qualification of equipment at Gentilly-2 NGS as it ages. In this regard, Hydro-Québec noted that it has submitted an environmental qualification program to the CNSC. The report is currently under CNSC staff review. The proposed program places priority on the special safety systems and steam generators. Another program focuses specifically on the environmental qualification of PVC cabling in containment. PVC cabling is known to degrade with time as a result of exposure to heat and radiation. CNSC staff remarked that Hydro-Québec must still demonstrate the coordination, efficiency and completeness of the various activities aimed at assessing the effects of aging. In that regard, Hydro-Québec stated that it continues to meet regularly with CNSC staff to clarify the requirements. Three intervenors (Sierra Club of Canada, Mouvement Vert Mauricie Inc. and AmiEs de la Terre de Québec) expressed concerns about what they considered to be the high risks associated with the aging of the facility. To address that risk, these intervenors recommend a shorter licence term to allow for better regulatory scrutiny. The Commission s finding on the matter of the licence term, including its consideration of the related intervenors comments, is contained in section 3.13 below. The Commission is satisfied, however, that the continuous compliance verification processes implemented by CNSC staff, both in Ottawa and full-time at the Gentilly-2 NGS, provide a high level of regulatory scrutiny. The Commission is satisfied that Hydro-Québec has recognized, and is taking the appropriate steps to address, the special challenges raised by component aging. The Commission s consideration of the specific issues related to aging, such as maintenance, fitness for service, structural integrity and safety system reliability, are addressed below in section 3.7 (Fitness for Service) Emergency Core Cooling Systems CNSC staff reported the successful resolution of two Emergency Core Cooling System design issues during the current licence period. One issue related to the possible clogging of strainers during an accident. This was mitigated by installing larger-surface strainers during the 2002 outage. The other issue related to the time that would be available for operators to initiate the low-pressure emergency core cooling system. An analysis determined that the operators would have 15 minutes to activate the system under the worst-case conditions. As such, CNSC staff expressed the view that further consideration of automating the system is not an immediate issue and may be deferred to the possible refurbishment of the facility in With this information, the Commission remains satisfied with design of the emergency Core Cooling Systems.

15 Steam Pipes and the Control Room Citing earlier concerns about the proximity of high-pressure steam lines to the control room, an intervenor, the Canadian Coalition for Nuclear Responsibility, expressed its view that the reinforcements and monitoring currently in place are inadequate to protect the control room operators from the impact of a pipe rupture. In response to questions from the Commission on this issue, CNSC staff recounted that this design issue was the subject of considerable attention by the former Atomic Energy Control Board a number of years ago. CNSC staff explained that it remains satisfied that the piping reinforcements and leak detection devices that were added to mitigate the risk are adequate. Based on this advice from CNSC staff, the Commission concludes that, for the purpose of the current licensing action, the risks posed by the steam pipes to the control room have been satisfactorily mitigated Conclusions on Design Adequacy Based on the information summarized above, the Commission concludes that the design of Gentilly-2 NGS is adequate for the purpose of its continued operation in the next licence period. The Commission is also satisfied that Hydro-Québec has continued to modify the facility design in an appropriate and timely manner in response to new issues and as new information becomes available. 3.7 Fitness for Service In addition to considering the adequacy of the design (as discussed in the foregoing section), the Commission also considered whether Hydro-Québec was maintaining fit-for-service the critical components of that design. This includes an examination of Hydro-Québec s maintenance program, the monitoring and maintenance of the structural integrity of key components, and the reliability of special safety systems. Overall, CNSC staff reported that Hydro-Québec s fitness-for-service program meets CNSC expectations Maintenance Hydro-Québec reported that it has been actively engaged in a process for improving maintenance since The program involves a better integration of the Maintenance Unit and Operational Unit. It also concentrates on preventative maintenance of special safety systems and improved work planning. CNSC staff expressed its general satisfaction with the improvements made by Hydro-Québec to the maintenance program, but noted that some issues remain to be addressed in the area of documenting the framework consistent with the CNSC s regulatory guides. CNSC staff anticipates that these remaining issues will be addressed as part of the planned improvements to the Quality Assurance Program, discussed earlier in section

16 Based on this information, the Commission finds the maintenance program at Gentilly-2 NGS to be acceptable Structural Integrity With respect to structural integrity of the pressure tubes in the core of the reactor, the Canadian Coalition for Nuclear Responsibility, in its intervention, expressed concerns about what it considers to be the dangerously brittle condition of those tubes and the consequences in the event one should rupture. On this issue, however, CNSC staff expressed its satisfaction with Hydro- Québec s plans for the continuing evaluation of pressure tube degradation and fuel channel lifecycle management. The Commission questioned Hydro-Québec on the status of concerns raised in earlier licensing actions that related to the migration of pressure tube spacers. Hydro-Québec responded that the program for inspection and adjustment of the spacers has been successful. The strategic repositioning of the spacers appears to have prevented further significant movement of the spacers. Hydro-Québec also stated that the deuterium capture of the pressure tubes has remained within long-term projections. On the matter of feeder pipe integrity, CNSC staff reported that recent inspections have identified degradation at the exit of some feeder pipes as a result of flow assisted erosion. No cracks were found in the feeder exits. CNSC staff is of the view that five affected feeder pipes, while still within specifications, will likely need replacement by 2013; i.e., not before the planned refurbishment of the reactor in To ensure adequate monitoring of the feeders, CNSC staff reported that it has requested Hydro-Québec to consolidate the various elements of the inspection program into a coordinated program for feeder pipe life-cycle management. With respect to the steam generators, CNSC staff indicated its satisfaction with Hydro-Québec s life-cycle management program. CNSC staff considers that the steam generators have functioned well during the licence period and that no unusual mechanisms of degradation have been observed. The integrity of the containment is tested regularly through periodic pressure tests. CNSC staff reported that these tests have shown satisfactory results. CNSC staff proposed that a licence condition be added to require Hydro-Québec to carry out the next pressure test prior to the end of Based on this information, the Commission concludes that the programs for ensuring the structural integrity of safety-important components and systems at Gentilly-2 NGS are acceptable.

17 Reliability The reliability of special safety systems is another factor within the general area of fitness for service. In this regard, CNSC staff reported that Hydro-Québec s reliability program and its implementation meets requirements. CNSC staff noted that, while the high-pressure and high-activity confinement was not available for a number of hours in late 2001 and early 2002, no significant effect on safety resulted and that the requirements for reliability were generally respected. CNSC staff and Hydro-Québec are continuing to examine this event to prevent its recurrence. Based on this information, the Commission is satisfied that the reliability program at Gentilly-2 NGS is acceptable. 3.8 Security CNSC staff reported that, with the exception of some minor issues that were being addressed at the time of the hearing, it considers that Hydro-Québec s security program meets the requirements of the Nuclear Security Regulations and Commission Order A number of intervenors (Raphaël Thierrin, Mouvement Vert Mauricie Inc., AmiEs de la Terre de Québec, and the Canadian Coalition for Nuclear Responsibility) expressed concern about whether the security at the site is adequate to prevent and respond to a terrorist attack, and in particular, an attack using an airliner. In response to these concerns of the intervenors, the Commission notes that following the terrorist events in the United States on September 11, 2001, it considered the need for heightened security at all major nuclear installations in Canada. Those requirements were specified in Commission Order At this time, the Commission is satisfied that Hydro-Québec has complied with those requirements and that the security arrangements at Gentilly-2 NGS are adequate. Based on Hydro-Quebec s compliance and performance on security matters, the Commission concludes that Hydro-Québec has made, and will continue to make, adequate provision for the maintenance of security at the Gentilly-2 NGS. 3.9 Safeguards and Non-proliferation CNSC staff reported that Hydro-Québec s program for the safeguard of material and nonproliferation meets and, in several respects, exceeds expectations. Based on this information, the Commission is satisfied that Hydro-Québec has made, and will continue to make adequate provisions in the area of safeguards and non-proliferation that are

18 necessary for maintaining national security and measures necessary for implementing international agreements to which Canada has agreed Emergency Preparedness and Response As part of its assessment of Hydro-Québec s provisions for protecting the health and safety of persons, the Commission examined the adequacy of the emergency preparedness at Gentilly-2 NGS. CNSC staff reported that it has evaluated the emergency preparedness and response program at Gentilly-2 NGS and finds it to exceed expectations, both in its definition and implementation. Hydro-Québec remarked that a successful exercise of the plan was carried out in June of The exercise involved the local and regional government, and the off-site fire and emergency medical personnel. The next planned exercise was scheduled for the fall of Based on this information, the Commission concludes that Hydro-Quebec s emergency response plan for the Gentilly-2 Nuclear Power Station is satisfactory Decommissioning and Financial Guarantees In order to ensure that adequate resources will be available to meet the same regulatory requirements for safety, environmental protection and security during the future decommissioning of Gentilly-2 NGS, the Commission requires that adequate financial guarantees for decommissioning and long-term management of waste be put in place and maintained acceptable to the CNSC. With respect to the financial guarantee for Gentilly-2 NGS, CNSC staff reported that a Preliminary Decommissioning Plan is in the final stages of review and that a related decommissioning cost study has been accepted by CNSC staff. The arrangement for the guarantee, however, remains to be established. CNSC staff therefore recommended a licence condition that would require Hydro-Québec to provide an acceptable guarantee prior to March 31, In response to the Commission questions on the status of the guarantee, Hydro-Québec explained that the matter is now with the Province of Québec and that a satisfactory arrangement is expected to be in place by the proposed date of March 31, CNSC staff and Hydro-Québec also explained, in response to follow-up questions from the Commission, that the guarantee will likely take the form of a fund to be managed by Hydro-Québec, backed by a formal commitment from the Government of Québec for the balance of the liability. CNSC staff noted that such an arrangement would be consistent with CNSC Regulatory Guide G-206 (Financial Guarantees for the Decommissioning of Licensed Activities). Several intervenors (Sierra Club of Canada, ENvironment JEUnesse, Mouvement Vert Mauricie Inc., and AmiEs de la Terre de Québec) expressed concern about what they consider to be the

19 current lack of detailed decommissioning plans and firm, segregated decommissioning funds. These intervenors generally feel that the licence should not be renewed without these things in place; or at least should be renewed for only a short period of time while suitable financial arrangements for decommissioning are established. Furthermore, Mouvement Vert Mauricie Inc. is of the opinion that the Preliminary Decommissioning Plan, which is now two years old, is incomplete (particularly with respect to the very long-term management of fuel waste) and is not a suitable basis for preparing an acceptable financial guarantee. Mouvement Vert Mauricie Inc. and Raphaël Thierrin also expressed concern that the cost analysis accepted by CNSC staff is not available to the public. The Commission questioned CNSC staff on why the cost study was not a public document. In response, CNSC staff stated that the security status of several reports, particularly those containing design details of major nuclear facilities, was changed to conform to the heightened level of security instituted following the events of September 11, The Commission requests that CNSC staff further investigate the extent to which the cost estimate report could be made public. On the adequacy of the Preliminary Decommissioning Plan (PDP), the Commission accepts the opinion of CNSC staff that the existing plan continues to provide an adequate basis for estimating the cost of dismantling and decontaminating the Gentilly-2 NGS. The Commission notes that the plan will be revised periodically and will be subject to ongoing review by CNSC staff. The Commission further notes that the cost of the long-term management of high-level fuel waste, while required to form a part of the overall financial guarantee required by the CNSC, will be estimated separately from the PDP using conservative scenarios identified in the Nuclear Fuel Waste Act. While the Commission is satisfied with the basis and process for establishing a guarantee, the Commission shares the intervenor s concerns about the current lack of an acceptable decommissioning financial guarantee for Gentilly-2 NGS. The Commission will not accept undue delay in resolving this matter. The Commission is therefore in agreement with CNSC staff s recommendation to add a related licence condition that requires that an acceptable financial guarantee be in place by March 31, The Commission accepts the wording of the proposed licence condition 11.2 and is satisfied that Hydro-Québec and the Government of Québec understand the importance of this issue. The Commission does not accept the above-identified intervenors recommendations that the financial guarantee be used as a prerequisite to the renewal of the licence at this time, or that it be linked directly to the term of the new licence. The Commission is satisfied that legal requirement set out in the proposed licence condition will be sufficient to communicate the Commission s resolve in this matter. A further discussion of the licence term is contained below in section 3.13.

20 Canadian Environmental Assessment Act CNSC staff explained that the renewal of a licence of this nature is not a trigger under the Canadian Environmental Assessment Act (CEAA) and therefore the CEAA does not apply to the proposed continued operation of Gentilly-2 NGS. The Commission accepts CNSC staff s interpretation of the CEAA in this case and therefore concludes that an environmental assessment is not required Licence Term Hydro-Québec has applied for a 5-year licence term. CNSC staff, with specific reference to its guidelines for recommending licence lengths (as documented in CMD 02-M12), recommended that the Commission issue a licence for a shorter term of 4 years. CNSC staff stated that the recommendation for a shorter term is due to the above-noted performance areas that CNSC staff considers remain below CNSC expectations -- particularly with respect to the remaining deficiencies in the quality assurance program. In CNSC staff s opinion, Hydro-Québec, while having shown an improvement in performance over the past licence period, has not yet fully met the criteria for a licence term of longer than 4 years. CNSC staff also noted that in four years, the proposed future refurbishment of Gentilly-2 NGS will be better defined for the consideration of the Commission. Several intervenors strongly objected to either a 4 or 5 year licence term. Mouvement Vert Mauricie Inc., Raphaël Thierrin and AmiEs de la Terre de Québec all recommend that nothing in excess of the past practice of a 2-year licence should be contemplated. Sierra Club of Canada, Environment JEUnesse and the Canadian Coalition for Nuclear Responsibility recommended a licence of less than one year. In general, these intervenors, referring to the number of below expectation ratings assigned by CNSC staff, are of the view that Hydro-Québec has not earned consideration of a longer licence. Furthermore, these intervenors expressed concern about the need for more frequent and formal evaluations of the operation as the facility approaches the end of its design life. Mouvement Vert Mauricie Inc. and AmiEs de la Terre de Quebec expressed particular concern about what they consider would be the effect of a longer licence on the Commission s future consideration of an application to refurbish the reactor. These intervenors are of the view that, in 4 or 5 years, the amount of commitment to, and investment in, the refurbishment project may be so advanced that the Commission would be compelled to approve the application. The Canadian Coalition for Nuclear Responsibility is of the view that a 6 month licence would provide the incentive necessary to get a detailed decommissioning and waste management plan in place together with a related financial guarantee. Similarly, Sierra Club of Canada felt it necessary that the people of Québec should have an opportunity to express their views on the future of the facility, including by way of the next provincial election, before a longer licence is considered.