Report EMERGENCY PREPAREDNESS SITE EVALUATION FOR OPG NEW NUCLEAR AT DARLINGTON

Transcription

1 Sheet Number: Revision: N/A R001 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. Preparedness Site Evaluation For OPG New Nuclear At Darlington -R Order Number: N/A Other Reference Number: PROJECT ID Prepared by: K. Heinonen Technical Officer Preparedness Date Verified by: S. Forsythe Section Manager Preparedness Date Reviewed by: J. Coles Manager Preparedness Date Approved by: M. Tulett Director Nuclear Protection Programs and Training Date Authorized by: L. Swami Director, Licensing Generation Development Date Associated with document type REP N-TMP R008, Controlled Document or Record (Microsoft XP)

2 N/A R001 2 of 67 Table of Contents Page Revision Summary... 5 Executive Summary INTRODUCTION EVOLUTION OF NUCLEAR EMERGENCY PLANNING IN ONTARIO CONSOLIDATED NUCLEAR EMERGENCY PLAN, N-PROG-RA STATUS OF THE EXISTING NUCLEAR EMERGENCY PREPAREDNESS PROGRAM AT OPG PUBLIC PROTECTIVE ACTIONS, NUCLEAR ACCIDENT SCENARIOS AND DESIGN BASIS ACCIDENTS Public Protective Actions Nuclear Accident Scenarios Design Basis Accidents for Planning (DBA EP ) EMERGENCY PROTECTIVE ZONES Darlington Nuclear Generating Station Exclusion Zone OPG New Nuclear at Darlington Exclusion Zone Protective Zones in the Public Domain Historical Determination of Protective Zones in the Public Domain Planning Within the 3 km Contiguous Zone Planning Within the 10 km Primary Zone Planning Within the 50 km Secondary Zone and Beyond Within the 50 km Secondary Zone Beyond the 50 km Secondary Zone EMERGENCY PLANNING AND COMMUNITY CONSULTATION Nuclear Management Coordination Committee Durham Region Nuclear Management Coordinating Committee Durham Nuclear Health Committee...25

3 N/A R001 3 of POPULATION GROWTH AND LAND USE COMMUNITY COMMITMENT TO NUCLEAR EMERGENCY PLANNING EXTERNAL AND CONVENTIONAL HAZARD MANAGEMENT Fire Protection, Hazardous Material (HAZMAT) and Toxic Gas Transportation Response Plan Security Severe Weather Preparedness NEW NUCLEAR PROJECT (DNNP) EMERGENCY PREPAREDNESS PROGRAM LIFE EXTENSION ACTIVITIES RD-346 EVALUATION RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section 5.0 continued RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section RD-346 Section FURTHER ANALYSIS CONCLUSION...44

4 N/A R001 4 of REFERENCES...45 Appendix A: Integrated Matrix of Nuclear Planning in Ontario...47 Appendix B: Nuclear Preparedness Document Hierarchy...62 Appendix C: Community Commitment to Nuclear Planning...63 Appendix D: Acronyms and Abbreviations...67

5 N/A R001 5 of 67 Revision Summary Revision Number Date Comments R Revised to include information pertaining to the revised PNERP and update reference document information.

6 N/A R001 6 of 67 Executive Summary Ontario Power Generation (OPG) has begun the process of obtaining federal approvals for site preparation, construction, and operation of up to four additional nuclear reactors at the Darlington Nuclear Site. As part of this process, OPG must meet the expectations of the applicable Canadian Nuclear Safety Commission (CNSC) regulatory documents. The primary purpose of this document is to provide the evaluation of the OPG Preparedness (EP) program and show how the current program addresses the expectations outlined in the CNSC Regulatory Document RD-346, Site Evaluation for New Nuclear Power Plants [1] for the New Nuclear at Darlington project. The evaluation was conducted by reviewing: the evolution of nuclear emergency management in Ontario, the current nuclear emergency management program related to OPG and specifically the Darlington Nuclear Generating Station (DNGS) the hierarchy of emergency plans and legislation from the international to the municipal level the local community, specifically community involvement and population growth agreements between OPG and the emergency planning jurisdictions recent reports pertaining to the New Nuclear at Darlington project The results of the evaluation show that the current nuclear emergency preparedness program applicable to the OPG DNGS site is broad, flexible, detailed and robust. The conclusion is that the emergency program is compliant with the expectations of RD-346 [1] and will require only minor modifications to accommodate the New Nuclear at Darlington project. These modifications can be incorporated through the established emergency planning processes.

7 N/A R001 7 of INTRODUCTION Ontario Power Generation (OPG) has begun the process of obtaining federal approvals for site preparation, construction, and operation of up to four additional nuclear reactors at the Darlington Nuclear Site. As part of this process, OPG must meet the expectations of the applicable Canadian Nuclear Safety Commission (CNSC) regulatory documents. The primary purpose of this document is to provide the evaluation of the OPG Preparedness (EP) program and show how the current program addresses the expectations outlined in the CNSC Regulatory Document RD-346, Site Evaluation for New Nuclear Power Plants [1] for the New Nuclear at Darlington project. This document provides: Evidence of a current robust emergency program in order to demonstrate that the emergency plans have the capacity to deal with future hazards and events. Historical information pertaining to the evolution of nuclear emergency planning in Ontario. An integrated matrix of nuclear emergency planning in Ontario (Appendix A), which provides a comprehensive list of official documentation and committees, where they receive authority from, and a general description of the contents or role. A summary of emergency legislation and plans which pertain to the federal, provincial, regional and municipal levels of government. Evidence of commitments pertaining to nuclear emergency planning at the international, federal, provincial, regional and municipal levels. A description of OPG s nuclear emergency program which includes the Consolidated Nuclear Plan (CNEP) [8], an extensive drills and exercise program, a quality assurance program and a managed training and qualification program. Evidence of current procedures and programs that manage both internal and external hazards such that these hazards do not impede the implementation of emergency plans.

8 N/A R001 8 of 67 It is then necessary to provide assurance that this emergency program will continue to address future hazards for the life of the new station. This document discusses: The need for Darlington New Nuclear Project (DNNP) to prepare and implement an emergency program which is aligned with Darlington Nuclear Generating Station (DNGS) Response Manual [2] to support site preparation. It will address the possible protective actions that may be required during the site preparation and construction phases of the project in response to a DNGS station emergency. The DNGS Response Manual [2] is a suite of procedures (Series: D-INS xxxxx) which are revised annually, or more frequently if required. Current population growth plans and OPG s involvement monitoring and participating, as required, in how future growth and land use will be managed to minimize the impact on the implementation of applicable nuclear emergency plans. Letters of Commitment between OPG and key stakeholders to confirm a commitment to maintaining emergency plans for the life of the station and to addressing future emergency plan revisions, as required. OPG s commitment to analyze the different radiological release scenarios with respect to emergency preparedness, which will culminate in the development of an emergency preparedness design basis accident based on technology selection for the Operation and Maintenance Phase. This evaluation addresses the expectations of RD-346 [1] relative to the impact of numerous hazards or events on the implementation of emergency plans primarily by highlighting the current response capabilities and well established plans. The hazards mentioned in RD-346 [1] are not new to the Darlington Nuclear Site, and have been managed successfully through the existing program. Evidence is provided of the ongoing cooperation between OPG and the many levels of government and community response organizations, which provides the foundation for future agreements and collaboration. 2.0 EVOLUTION OF NUCLEAR EMERGENCY PLANNING IN ONTARIO Nuclear Planning has been in place since the inception of nuclear technology, as there has always been recognition of the potential hazard. Many jurisdictions in Canada and the US, using the Hazard Identification Risk Analysis (HIRA) processes, rate nuclear power hazards as having a low or extremely low probability of occurring with high consequences. The Ontario Provincial Nuclear Response Plan, Master Plan (PNERP) [3] is the primary basis of nuclear emergency planning for OPG. The Province of Ontario Nuclear Plan, Part I Master Plan (PNEP) [4] (now known as the PNERP [3]) first came into effect in 1983 partly as a response to the events at Three Mile Island, but also to comply with the

9 N/A R001 9 of 67 Plans Act [40] of the same year. Ontario Hydro (predecessor to OPG) implemented its own internal emergency plan (EP Implementation Manual [44]) the same year. In 1984, the report of findings and recommendations from Province of Ontario Working Group #3: Technical Bases of the Provincial Nuclear Plan [5] was published. In 1985 Ontario Hydro produced The Assessment of Radiation Dose to the Public Arising from Postulated Accidents [45] at Pickering NGS as an input to Planning, thus defining the first Design Basis Accident for emergency planning purposes (DBA EP ). The event at Chernobyl in 1986 led to the re-formation of Working Groups at the Provincial level in 1988 to look at nuclear emergency management and public safety. Of particular note was Working Group #8: The Upper Limit for Detailed Nuclear Planning [6]. The Working Groups (both #3 in 1984 and #8 in 1988) were comprised of the Operator (Ontario Hydro), the Regulator (Atomic Energy Control Board), the Stakeholder (Government of Ontario, Ministries of Energy and Health), the Designer (Atomic Energy Canada Limited) and were led by a reputable Canadian academic (Dr. K. G. McNeil, University of Toronto). The Working Group reports were later vetted in a report from the Royal Society of Canada and Canadian Academy of Engineering in November 1996 [7]. This information, along with extensive consultation led to the issuance of the revised PNEP [4] in Ontario Hydro then issued the Consolidated Nuclear Plan (CNEP) [8]. On February 11, 2009, Cabinet, by an Order in Council approved the PNERP [3]. The PNERP [3] was reviewed as part of this assessment. 3.0 CONSOLIDATED NUCLEAR EMERGENCY PLAN, N-PROG-RA-0001 The CNEP [8] is a governing document which establishes the concepts, roles, and resources required by OPG Nuclear to implement and maintain its emergency response capability to protect the public, employees, and the environment in the event of a nuclear emergency. It provides a framework for interaction with external authorities and defines OPG commitments under the PNERP [3]. The CNEP [8] is a condition of the Power Reactor Operating Licence (PROL) for each station and each revision is subject to review and approval by the Canadian Nuclear Safety Commission (CNSC) and review by Management Ontario (EMO) prior to issuance.

10 N/A R of 67 The planning basis for the CNEP [8]: Satisfy requirements of the Provincial Nuclear Response Plan (PNERP) [3] Satisfy regulatory licensing requirements Satisfy response requirements to mitigate a DBA EP Prudent as a community partner to develop and maintain an Plan and Organization. The DBA EP for the CNEP [8], which defines the onsite response and minimum staff complement, is a Loss of Coolant Accident (LOCA) with one contaminated casualty. The augmented OPG Response Organization (ERO) is designed and implemented to meet or exceed the requirements of the PNERP [3] for offsite response. The CNEP [8] defines the Nuclear Preparedness Program and its implementing ERO for the existing facilities. The program is implemented through a detailed document hierarchy, as defined in the CNEP [8] and summarized in Appendix B: Nuclear Preparedness Document Hierarchy of this report, consisting of: 4 Nuclear Standards 6 Nuclear Procedures 19 Nuclear Instructions 31 Darlington Instructions 31 Pickering Instructions 1 Training and Qualification Document Appendices C and D of the CNEP [8] provide a detailed systematic process for prioritizing the risks associated with site characteristics and external events, including the synergy of multiple events and multiple effects of different activities on the site. This set of criteria is defined through direct consultation with and agreement from Management Ontario. 4.0 STATUS OF THE EXISTING NUCLEAR EMERGENCY PREPAREDNESS PROGRAM AT OPG The Preparedness (EP) program at both Darlington and Pickering Nuclear Generating Stations has received A ratings from the CNSC for the last five years, for both its Program and Implementation.

11 N/A R of 67 The EP program and its implementation are regularly audited by the CNSC. OPG conducts its own regular audits through the Nuclear Oversight Division as part of the Quality Assurance program. The EP department also completes self assessments of the program. A total of nine self assessments were completed in The EP program is also assessed during drills and exercises that as a minimum includes the following across the OPG Nuclear Fleet (Darlington, Pickering A, Pickering B): 3 drills per year per shift crew 30 / year Liquid Emission Drills 2 / year Transportation Response Drill 1 / year Site Management Centre activation 6 / year Corporate Operations Facility activation 2 / year Local Media Centre activation 2 / year Site Evacuation Drills 2 / 3 years Offsite Centre Exercises 1 / year Drill and exercise scenarios throughout the year include both nuclear and conventional events which could lead to an activation of the CNEP [8]. Recent scenarios added to the program include Loss of Bulk Electrical System (blackout) and Pandemic. All audit, self assessment, and drill and exercise findings are tracked to completion using OPG s action tracking system. The OPG EP training program, defined in the Nuclear Response Organization Training and Qualification Description [9], maintains 63 distinct qualifications encompassing over 120 program elements or training courses. The general qualification structure is a mixture of classroom, practical and operating experience provided in both an initial and a continuing training format. Currently in the OPG Nuclear Fleet, there are over 1400 emergency qualifications at the approved status held by OPG staff. Qualifications are monitored and the number of expired qualifications is consistently maintained at or near zero. This information resides in the Training Information Management System (TIMS) which is the official record for all training related information. The current OPG quality assurance, training, and drill and exercise programs are extensive and these will be modified and expanded as necessary to meet the needs of the OPG New Nuclear at Darlington (NND) station to support the Operation and Maintenance Phase. Reference Section 11.0 Darlington New Nuclear Project (DNNP) Preparedness Program.

12 N/A R of PUBLIC PROTECTIVE ACTIONS, NUCLEAR ACCIDENT SCENARIOS AND DESIGN BASIS ACCIDENTS 5.1 Public Protective Actions The Province of Ontario is primarily responsible for the off-site response to a nuclear emergency. The Province receives its authority from the Management and Civil Protection Act [41], which stipulates that the Lieutenant Governor in Council shall formulate an emergency plan respecting emergencies arising in connection with nuclear facilities. Nuclear and radiological emergency plans formulated by ministries, municipalities, nuclear installations, nuclear establishments, their operators, and other agencies and organizations conform to the PNERP [3] so as to contribute to a coordinated response which achieves the aim of the PNERP [3]. The four public protective actions that can result from a nuclear emergency are: Sheltering Thyroid blocking (Potassium Iodide (KI) Pills) Evacuation Ingestion control The two main considerations for these actions are distance from the nuclear plant and the timing associated with these measures. The distances are specified in the PNERP [3] as 0-3 km (Contiguous Zone) which would be the first zone to implement exposure control measures (sheltering, evacuation, and/or thyroid blocking), 0-10 km (Primary Zone) which would be the next zone to implement exposure control measures, and 0-50 km (Secondary Zone) where protective actions other than exposure control could be implemented (i.e., ingestion control measures). Timing is also specified in the PNERP [3], looking both at when and how long it will take to implement the protective actions. The Protective Action Levels, which are specified in the PNERP [3], serve as aids in planning and decision-making during an emergency. They are expressed in terms of projected radiation doses or levels of radionuclide concentration, as depicted in Tables 5.1 and 5.2 below.

13 N/A R of 67 Protective Action Levels (PALs) PROTECTIVE MEASURE Sheltering Evacuation Thyroid Blocking BANNING FOOD/WATER CONSUMPTION LOWER LEVEL Effective Dose Thyroid Dose Effective Dose 1 msv 10 msv 10 msv (0.1 rem) (1 rem) (1 rem) 10 msv 100 msv 100 msv (1 rem) (10 rem) (10 rem) msv (10 rem) - Table 5.1: Exposure Control Measures Cs-134, Cs-137 Ru-103, Ru-106, Sr-89 UPPER LEVEL RADIONUCLIDE CONCENTRATION LEVEL I-131 Sr-90 Thyroid Dose 100 msv (10 rem) 1 Sv (100 rem) 1 Sv (100 rem) Am-241, Pu-238 Pu-239, Pu-240 Pu-242 Foods for General Consumption Milk, Infant Foods, Drinking Water 1 kbq (27 nci) per kg 1 kbq (27 nci) per kg 100 Bq (2.7 nci) per kg 100 Bq (2.7 nci) per kg Table 5.2: Ingestion Control Measures 10 Bq (270 pci) per kg 1 Bq (27 pci) per kg 5.2 Nuclear Accident Scenarios Several nuclear accident scenarios are discussed in the Site Evaluation for OPG New Nuclear at Darlington Nuclear Safety Considerations [10] and in the Malfunctions, Accidents and Malevolent Acts Technical Support Document, New Nuclear - Darlington Environmental Assessment [15]. The assessments were completed to evaluate scenarios corresponding to the Regulatory Document RD-337 [21] safety goal release thresholds which demonstrated that the reactor designs under consideration meet the intent of the RD-337 [21] safety goals with respect to the impact of protective measures (i.e., temporary evacuation, long term relocation) on the local population. The derived releases by their use in these evaluations are beyond the current DBA EP for DNGS and are significantly beyond the normal requirements of emergency planning. The conclusion, based on the above reports is that no changes will be required to the current PNERP [3] or CNEP [8] with respect to the implementation of public protective actions.

14 N/A R of Design Basis Accidents for Planning (DBA EP ) OPG s current CNEP [8] is based on specific DBA EP s for the Pickering and Darlington Nuclear Generating Stations. The DBA EP, which defines the onsite response and minimum staff complement, is a Loss of Coolant Accident (LOCA) with one contaminated casualty. The development of a DBA EP for OPG NND is addressed under Section Further Analysis. While the specific DBA EP is not designed for the NND, the expectation is that any developed DBA EP will be within the bounds of the currently reviewed Nuclear Accident Scenarios and are thus not expected to require significant changes to the existing nuclear emergency plans. 6.0 EMERGENCY PROTECTIVE ZONES The Protective Zones are defined generally as a radius distance from the nuclear station, with specific potential protective actions defined within the emergency plans. The following sections describe the current emergency plans for the various protective zones along with the analysis of how the emergency preparedness requirements for NND will be met. 6.1 Darlington Nuclear Generating Station Exclusion Zone The current DNGS Exclusion Zone is 914 metres from the reactor building and will extend onto the south-western portion of the OPG NND site. The following is an excerpt from the Exclusion Zone Determination for Darlington New Nuclear Project [11] discussing the historical determination of the DNGS exclusion zone: Historically, the exclusion zone for all nuclear power plants in Canada since Pickering A has been defined as 914 m (3000 feet) from the reactor building. Rather than prescribing a size for the exclusion zone explicitly, the current regulatory documents for new NPPs define the factors that must be considered in establishing an appropriate size. One of the factors to be considered is the dose acceptance criteria at the site boundary. Based on technical safety objectives, RD-337 provides dose acceptance criterion for events within the design basis which have evolved from the dose limits considered in earlier licensing documents. The DNGS Exclusion Zone will not have any permanent dwellings constructed within the zone and the specified area will be under the control of OPG Nuclear Security should an event occur. If required, security staff will ensure the area is evacuated and remains evacuated as long as required.

15 N/A R of 67 To support site preparation, the Engineering, Procurement, and Construction (EPC) Company will require a NND Site Plan which includes an integrated evacuation plan in alignment with the existing DNGS Response Manual [2] and the CNEP [8]. This is addressed further in Section 11.0 Darlington New Nuclear Project (DNNP) Preparedness Program. As the NND site transitions from the Site Preparation and Construction Phase to the Operation and Maintenance Phase, it will necessitate future revisions of both the DNGS Response Manual [2] and the NND Site Plan to accommodate the changing requirements. This transition is illustrated in Figure 11.1, NND Plan Evolution. 6.2 OPG New Nuclear at Darlington Exclusion Zone Requirements for the proposed OPG NND Exclusion Zone are defined in Exclusion Zone Determination for Darlington New Nuclear Project [11]. During the Operation and Maintenance Phase, the DNGS and the proposed NND Exclusion Zones will overlap. This is discussed in more detail in Section Further Analysis. 6.3 Protective Zones in the Public Domain As defined in Section 5.1 Public Protective Actions, the Province of Ontario has the primary responsibility for the safety of the public and therefore has the responsibility of defining the protective zones and protective actions to be taken within those zones. The Public Domain is the area beyond the site boundary wherein the Province of Ontario has the primary responsibility for public safety. There are three protective zones in the public domain that are defined in the PNERP [3], as follows: (a) Contiguous Zone The zone immediately surrounding the nuclear installation. Priority evacuations, if necessary shall be undertaken within this area because of its proximity to the source of the potential hazard. (b) Primary Zone The zone around the nuclear installation within which detailed planning and preparedness shall be carried out for measures against exposure to a radioactive plume. (The Primary Zone includes the Contiguous Zone). (c) Secondary Zone A larger zone within which it is necessary to plan and prepare measures to prevent ingestion of radioactive material. (The Secondary Zone includes both the Primary and Contiguous Zones).

16 N/A R of 67 The approximate or nominal radii of the zones for the designated nuclear installations in Ontario, as measured from the venting or release stacks, are: Contiguous Zone - 3 km Primary Zone - 10 km Secondary Zone - 50 km The NND project will require a review of the current DNGS Contiguous, Primary and Secondary Zone boundaries to determine, from an emergency planning perspective, if an independent set of Zones will be utilized for the new plant with slightly different boundaries from the DNGS Zones, or if a new set of combined zones will be determined and utilized. This review is expected to be conducted with input from OPG and the impacted community partners prior to the Operation and Maintenance Phase. Any determinations and decisions with respect to revising the boundaries will be made by the Province of Ontario Historical Determination of Protective Zones in the Public Domain The technical definition of the protective zones can be traced back across three Province of Ontario commissioned studies: Report of Provincial Working Group #3: Technical Bases of the Provincial Nuclear Plan (1984) [5] Report of Provincial Working Group #8: The Upper Limit for Detailed Nuclear Planning (1988) [6] Royal Society of Canada & Canadian Academy of Engineering Report to the Ministry of Environment and Energy Concerning Two Technical Matters in the Provincial Nuclear Plan (1996) [7] In 1984, the report of findings and recommendations from Working Group #3: Technical Bases of the Provincial Nuclear Plan was published [5]. Recommendation #3 defined the three zones (Contiguous, Primary and Secondary) as having a respective radius of 3, 10 and 50 km respectively. In 1988, the report of findings and recommendations from Working Group #8: The Upper Limit for Detailed Nuclear Planning [6] was issued. Recommendation #5, based on a series of recommendations, was that the size of the Primary Zones for Pickering, Bruce and Darlington nuclear stations should be 13 km. No changes to the defined size of the Primary Zones specified in the PNEP [4] were made as a result of this report.

17 N/A R of 67 In 1996, the findings and recommendations in the Royal Society of Canada & Canadian Academy of Engineering Report to the Ministry of Environment and Energy Concerning Two Technical Matters in the Provincial Nuclear Plan [7] were published. The second technical matter this report was commissioned for was the difference between the Working Group #3 [5] and #8 [6] reports with respect to the definition of the Primary Zone radius (10 km and 13 km respectively). The findings from this report [7] concluded in the executive summary as follows: The choice of 10 or 13 km for the outer boundary of the Primary Zone: In comparison to the wide range of consequences from a severe accident, 10 and 13 km are essentially the same number. Since the designation of zones should be for the purpose of developing and practicing emergency responses, we find that a nominal 10 km is satisfactory. In practice, the Primary Zone sector boundaries, as defined in the PNERP [3], are at a minimum of the specified radii, and are practically defined by the streets and roads that are closest to the outside distance of the radii. In the specific definition of the DNGS Primary Zone shown in Figure 6.1 below, the sector boundaries range from 10 km at the intersection of Sector D8a and D7 to almost 14 km at the outer edge of sector D12. Figure 6.1, Darlington Nuclear Generating Station Primary Zone

18 N/A R of Planning Within the 3 km Contiguous Zone The DNGS Contiguous Zone is based on a 3 km radius from DNGS. It is bounded by Courtice Road, Baseline Road, and Martin Road. Currently the DNGS Contiguous Zone has a low population. This zone is the first priority for provincially directed protective actions which are the same as for the larger Primary Zone and are described in detail in the next section Planning Within the 10 km Primary Zone The Primary Zone (0-10 km), which includes the Contiguous Zone, is the area around a nuclear station within which detailed planning and preparedness is carried out for measures against exposure to a radioactive emission. The DNGS Primary Zone includes an area of Durham Region bounded generally by Taunton Road to the north, Wilmot Creek to the east, and Park Road (RR 54) to the west. The zone extends out into Lake Ontario to a radius of approximately 10 km from DNGS. The DNGS Primary Zone is divided into 17 Response Sectors which fall into the following sector rings around the station (See Figure 6.1): Inner Ring (Contiguous Zone) Middle Ring Outer Ring Sector D1 Sectors D2 to D5, and lake sectors D14 and D15 Sectors D6 to D13, and lake sectors D16 and D17 Supporting the PNERP [3] is PNEP Part IV - Darlington Nuclear Plan [22] which specifies the details pertaining to emergency planning and response to a nuclear emergency originating at DNGS. This plan [22] is being revised and expected to be issued later in OPG and the Province of Ontario, through EMO, work together in the planning and execution of Provincial Exercises, and meet regularly to maintain and improve the nuclear emergency management program. There is a formal letter of agreement between OPG and the Province which dictates the level of support provided by OPG to the Province to maintain EMO s Nuclear Management Program. Locally, Provincial direction would come primarily through the Region of Durham. Emergencies in the Region of Durham are managed using the Durham Region Master Plan, Part I [12] which receives its authority from the Province of Ontario Management and Civil Protection Act [41] and Regional By-law Number The Durham Region Master Plan [12] identifies that nuclear power plant emergencies have such a low probability that they do not pose a risk that would elevate them into one of the top ten risks in Durham Region. However the consequences of such an event are significant and as such, a considerable portion of the emergency plan, while written broadly, is driven by planning for a nuclear emergency. The Durham Region Master Plan [12] delineates the roles,

19 N/A R of 67 responsibilities, and interaction between the Province, the Region and the Municipalities in a nuclear emergency. Specific nuclear emergency planning and response information is contained in the Durham Region Nuclear Plan (DRNEP) [13] which receives its authority from the Durham Region Master Plan [12]. The DRNEP [13] includes the Sheltering and Evacuation plan which identifies specific populations and institutions that may require assistance during a nuclear emergency. OPG and the Region of Durham, through the Durham Management Office (DEMO), work together in the planning and execution of the regularly scheduled Offsite Centre Exercises and meet regularly to maintain and improve the nuclear emergency management program. There is a formal letter of agreement between OPG and the Region of Durham which dictates the level of support provided by OPG to Durham Region's nuclear emergency management program. The Municipality of Clarington maintains the Municipality of Clarington Nuclear Plan [46] which receives its authority from the Management and Civil Protection Act [41], the Clarington Plan [47], and Municipal Bylaw Number The Clarington Nuclear Plan [46] prescribes the planning and operational requirements for a response to a nuclear emergency directly or indirectly affecting the municipality. It [46] includes actions by Clarington's emergency organization in response to Provincial and Regional direction during a nuclear emergency at DNGS, and actions to support Durham Region's response to a nuclear emergency affecting other communities. OPG and the Municipality of Clarington meet regularly to maintain the nuclear emergency program. There is a formal letter of agreement between OPG and Clarington which dictates the level of support provided by OPG to the Municipality of Clarington's Fire Protection and Response program. The City of Oshawa maintains the City of Oshawa Master Plan [48] which receives its authority from the Management and Civil Protection Act [41], and conforms to the Durham Region Plan [12]. Oshawa's Nuclear Response Plan is contained in Appendix L(i) of this Master Plan [48]. It prescribes the planning and operational requirements for the strategic management of the response to a nuclear emergency directly or indirectly affecting the Municipality. It includes actions by Oshawa's nuclear emergency response organization in response to Provincial and Regional direction during a nuclear emergency at Darlington or Pickering Nuclear Generating Stations, and actions to support Durham Region's response to a nuclear emergency affecting other communities.

20 N/A R of 67 In support of the DRNEP [13], the local school boards have developed nuclear emergency plans. The Durham District School Board Nuclear Procedures [49], the Durham Catholic District School Board Nuclear Procedures [50] and the Kawartha Pine Ridge District School Board Manual of Nuclear Evacuation Procedures for Kawartha Pine Ridge Schools [51]: outline the procedures necessary to shelter and/or evacuate all applicable schools and associated daycare facilities, establish procedures for each school designated as an Evacuee Centre and/or Temporary Holding Centre, and provide direction and guidance on the administering of potassium iodide (KI) pills, if required. Further detailed descriptions of the associated emergency plans are provided in Appendix A: Integrated Matrix of Nuclear Planning in Ontario, and in the Planning and Preparedness Technical Support Document, New Nuclear Darlington Environmental Assessment [14] Planning Within the 50 km Secondary Zone and Beyond Within the 50 km Secondary Zone The Secondary Zone (0 50 km), which includes both the Contiguous and Primary Zones, is the area within which it is necessary to plan and prepare for implementing ingestion control measures, such as monitoring the food chain for contamination, and banning consumption of contaminated food items. The DNGS Secondary Zone encompasses areas of Durham Region, the City of Toronto, York Region and the counties of Kawartha Lakes, Northumberland, and Peterborough within a 50 km radius of DNGS (reference Figure 6.2, Darlington Secondary Zone). Within the DNGS Secondary Zone there are numerous communities (reference Figure 6.2, Darlington Secondary Zone) which may be required to undertake ingestion control measures and provide support to neighbouring municipalities in the unlikely event of a nuclear emergency at DNGS. The City of Pickering [52] and the Town of Ajax [53] maintain detailed nuclear emergency response plans due to their proximity to Pickering Nuclear. There is a formal letter of agreement between OPG and the City of Pickering which dictates the level of support provided by OPG to their Fire Protection and Community Management programs.

21 N/A R of 67 The City of Toronto is a designated Host Community under the PNERP [3] and maintains a nuclear emergency plan [54] due to its proximity to Pickering Nuclear. For the purposes of the DNGS, it identifies the required response capability to a nuclear emergency. Within the borders of Toronto there are 3 off-site centres available to support a DNGS nuclear emergency (Seneca College Reception Centre, York University Reception Centre, and the Marine Worker/Reception Centre). The following communities within the DNGS Secondary Zone have emergency plans which take their authority from the Province of Ontario Management and Civil Protection Act [41] and local by-laws: Town of Whitby Township of Uxbridge Township of Brock Township of Scugog City of Kawartha Lakes County of Peterborough Municipality of Port Hope Town of Cobourg Township of Hamilton Northumberland County Town of Markham Town of Whitchurch-Stouffville Township of Cavan Monaghan Township of Otonabee-South Monaghan Although most of these emergency plans do not specifically reference a nuclear emergency, they do contain the roles and responsibilities of response organizations that are flexible enough to adapt to a wide range of emergencies. These plans acknowledge the authority of the Province during an emergency and also list any mutual assistance agreements in place with neighbouring communities. Further detailed descriptions of the associated emergency plans are provided in Appendix A: Integrated Matrix of Nuclear Planning in Ontario, and in the Planning and Preparedness Technical Support Document [14].

22 N/A R of 67 Figure 6.2, Darlington Nuclear Generating Station Secondary Zone Beyond the 50 km Secondary Zone Beyond the Secondary Zone, the City of Peterborough is a designated Host Community under the PNERP [3]. The City of Peterborough s Plan [55] receives its authority from the Management and Civil Protection Act [41] and local By-Law Number Section 4 of the Plan [55] outlines the Host Community designation by the Province and the responsibilities and planning requirements needed to fulfill that role. The Fleming College Reception Centre is located in the City of Peterborough. There is a formal letter of agreement between OPG and the City of Peterborough which dictates the level of support provided by OPG to Peterborough's Community Management program. The CNSC responds to nuclear emergencies in accordance with Regulatory Policy 235, Nuclear Management, which receives its authority from the Nuclear Safety and Control Act [37]. This is a broad scope document and is not expected to be impacted by the NND project.

23 N/A R of 67 The Canadian Federal Government responds to Nuclear Emergencies in accordance with the Federal Nuclear Plan [42] which receives its authority from the Management Act [43]. The Federal Nuclear Plan [42] recognizes Health Canada as the lead agency at the federal level. This is a broad scope document and is not expected to be impacted by the NND project. Internationally there is the Agreement between the government of Canada and the government of United States of America on cooperation in comprehensive civil emergency planning and management [23] and the Canada-United States Joint Radiological Response Plan (JRERP)[24]. The JRERP [24] outlines how Canada and the US will interact when a peacetime nuclear incident in one country impacts or potentially impacts the other country. It includes guiding principles, scope and objectives, and requirements for alerting, activation, response, de-activation and public information. The agreement [23] and JRERP [24] are both high level broad scope documents and are not expected to be impacted by the NND project. To ensure coordinated federal and provincial nuclear emergency preparedness activities, the Province of Ontario liaises with Health Canada, Public Safety Canada and the CNSC. In 2009, EMO and the CNSC signed a Memorandum of Understanding [25] which acknowledges their different legislative responsibilities and details the consultation and cooperation which will occur to address their respective mandates with regard to nuclear and public safety and environmental protection. The Province is also a correspondence member on the Canada/United States Working Group on Radiological Preparedness chaired jointly by Health Canada and the United States Department of Health and Human Services. Further detailed descriptions of the associated emergency plans are provided in Appendix A: Integrated Matrix of Nuclear Planning in Ontario, and in the Planning and Preparedness Technical Support Document [14].

24 N/A R of EMERGENCY PLANNING AND COMMUNITY CONSULTATION 7.1 Nuclear Management Coordination Committee The Nuclear Management Coordinating Committee (NEMCC) was established in compliance with the PNERP [3] to ensure that an optimum state of nuclear emergency management is achieved and maintained in Ontario. The committee was originally called the Provincial Nuclear Preparedness Committee. The NEMCC reviews the state of provincial and municipal nuclear emergency management and technical issues, makes recommendations to improve the state of provincial and municipal nuclear emergency management, and reviews the final report on each major exercise conducted in accordance with the PNERP [3] and recommends improvements to plans and procedures where appropriate. The committee is chaired by the Chief of Management Ontario, and includes representatives of OPG, Regional NEMCCs, Atomic Energy of Canada Ltd., Health Canada, CNSC, Public Safety and Preparedness Canada, and the Senior Scientific Officer, EMO. The NEMCC meets at least twice per year. 7.2 Durham Region Nuclear Management Coordinating Committee The Durham Management Coordinating Committee (DEMCC) sits as the Durham Region Nuclear Management Coordinating Committee (DRNEMCC) in compliance with the PNERP [3] to review nuclear emergency management. The committee was originally called the Regional Nuclear Preparedness Committee. The DEMCC is established under the authority of Management By-Law to provide the Region with a higher-level co-ordinating body that will facilitate inter-departmental and municipal level co-operation regarding policy for emergency management and its four components: mitigation, preparedness, response and recovery. The DEMCC is chaired by the Chief Administrative Officer (CAO) of the Region, and includes the CAO of each local municipality in the Region, the Chief of Police, the Regional Fire Co-ordinator, the Medical Officer of Health, the Commissioner of Social Services, the Commissioner of Works, and the Director of Management. When sitting as the DRNEMCC, the following are included as ex officio members of the DEMCC: a representative of the Darlington and Pickering Nuclear Generating Stations and a representative of Management Ontario (EMO). The DRNEMCC meets at least twice per year.

25 N/A R of Durham Nuclear Health Committee The Durham Nuclear Health Committee (DNHC) was formed in 1995 as a result of a recommendation made by Ontario's Environmental Assessment Advisory Committee for the proposed expansion of the Ajax Water Supply Plant. The DNHC is comprised of the Region of Durham's Commissioner & Medical Officer of Health, Director of Environmental Health, and Epidemiologist; 9 public members; 2 OPG representatives; and 1 representative from the Ontario Ministry of the Environment. Individuals and representatives from other bodies are invited to attend and/or participate in the meetings. The purpose of the committee is to act as a forum primarily for discussing and addressing radiological emissions from nuclear facilities in Durham Region to assess the potential environmental human health impacts and may include, from time to time, other related topics of mutual interest. It also has a mandate to review the status of the DRNEP [13] annually. The DNHC continues to meet 5 times per year. 8.0 POPULATION GROWTH AND LAND USE The population within the Primary Zone is identified in Section 4, Overview of Evacuation Time Estimates of the Planning and Preparedness Technical Support Document [14]. The evacuation time estimates show that the current Primary Zone population can be evacuated prior to any public exposure limits being exceeded. The results of the ETE study are discussed in detail in Section 13.2 RD-346 Section From a growth planning perspective, the primary emergency planning issue is evacuation of the public. The first priority is the Contiguous Zone, previously defined as the ring within a radius of 3 km from the station. The current Contiguous Zone for DNGS and the proposed Contiguous Zone for NND overlap to a large extent and have a limited number of existing households clustered in the northeast corner of the new Contiguous Zone only. The second priority is the remainder of the 10 km Primary Zone and the third priority is the 5 km ring beyond the Primary Zone whose population can affect an evacuation (shadow evacuation) as discussed in Sections of the Planning and Preparedness Technical Support Document [14]. The Province is responsible for land use planning in Ontario. The land use planning system in Ontario is led by provincial policy statements issued under the Planning Act [27] and provincial plans. The Province is responsible for managing growth and development in Ontario in a way that supports economic prosperity, protects the environment and helps communities achieve a high quality of life. Municipalities are responsible for making decisions that determine future land use through the preparation of planning documents, including Official Plans. Municipalities are to ensure that planning decisions and planning documents are consistent with provincial policies and do not conflict with provincial plans.

26 N/A R of 67 In 2005, Ontario passed the Places to Grow Act [26] (S.O. 2005, CHAPTER 13), which provides a framework for the government to coordinate planning and decision-making for long-term growth and infrastructure renewal in Ontario. It gives the Province the power to designate geographical growth areas and to develop growth plans in collaboration with local officials and stakeholders to meet specific needs across the province. Population projections and allocations, and policies, goals and criteria relating to issues such as intensification and density, land supply, expansions and amendments to urban boundaries, location of industry and commerce, protection of sensitive and significant lands (including agricultural lands and water resources), infrastructure development, affordable housing and community design are to be addressed through Growth Plans. Municipalities will be required to bring their Official Plans into conformity with the growth plan for their area. Decisions taken under the Planning Act [27] (R.S.O. 1990, CHAPTER P.13) and Condominium Act [28] (S.O. 1998, CHAPTER 19) will also be required to conform to applicable growth plans. In June 2006, the Province released the Growth Plan for the Greater Golden Horseshoe (the Growth Plan) [29] under the Places to Grow Act [26] to address future demands for urban growth. The Growth Plan [29] provides a framework for managing growth in the Greater Golden Horseshoe (GGH) to 2031 (GGH - stretches around Lake Ontario from Northumberland to Niagara and north to Simcoe County), including key policy initiatives in transportation, infrastructure planning, land use planning, urban form, housing, natural heritage and resource protection and economic prosperity. All upper-tier municipalities, including Durham Region, in the GGH are required to implement amendments to their respective Official Plans to bring them into conformity with the Growth Plan [29] by June, In 2007, Durham Region initiated the Growing Durham Study [30] to allocate the population and employment forecasts to 2031 and to develop strategies and policies to phase in and achieve intensification targets and densities from the Provincial Growth Plan [29]. Through its study, the Region considered alternatives for future urban growth to accommodate the population and employment targets through expansions to existing urban area boundaries. The Region consulted with area municipalities, the Ministries of Municipal Affairs and Housing and Public Infrastructure Renewal (now Energy and Infrastructure), and the public as input into the Growing Durham Study [30]. In September, 2008, the Region released its Recommended Growth Scenario [16] for public review. This report [16] was part of the final phase of the Growing Durham Study [30] for consideration by Regional Planning Committee and the public. In November, 2008, the Region of Durham Planning Committee endorsed the Recommended Growth Scenario [16] and directed Regional Planning staff to initiate the Regional Official Plan Amendment process to implement the study s recommendations.

27 N/A R of 67 The Recommended Growth Scenario [16] identifies the majority of lands in the Contiguous Zone north of the Darlington Nuclear site to remain as open space to 2031 and identified these lands to be used for future employment (industrial) uses between 2031 and The majority of planned residential growth in Clarington is expected to be within the current urban areas of Courtice and Bowmanville through greater intensification of existing built-up areas to The Recommended Growth Scenario [16] identifies lands generally north of the Canadian Pacific Railway corridor and east of Holt Road in the vicinity of the Darlington Nuclear site for future residential growth between 2031 and The Region s proposed Official Plan Amendment to implement the recommendations of the Growing Durham Study [30] and the requirements of the Provincial Growth Plan [29] was adopted by Regional Council in June, The amendment (Amendment No. 128) has been forwarded to the Minister of Municipal Affairs and Housing for approval. The Municipality of Clarington has initiated its Official Plan Review process. As part of this process, Clarington is required to amend its Official Plan [32] to conform to the Provincial Growth Plan [29] and the Regional Official Plan [31]. The Official Plans for Durham Region [31] and Clarington [32] recognize the existence of the nuclear power facility at the Darlington site in Clarington. OPG monitors planning developments near its facilities, and participates in provincial, regional and municipal planning exercises if a proposal is likely to have an adverse effect on the safe operation of its facilities. For example, OPG has monitored the Growing Durham Study [30] and has provided input at appropriate times. In addition, OPG has provided the Municipality of Clarington, City of Pickering, and Durham Region, which host nuclear facilities, with copies of RD-346 [1]. As such, the Province of Ontario, Durham Region and the Municipality of Clarington are aware of the regulatory guidance associated with the New Nuclear at Darlington Project and the potential implications for population and land use activities near nuclear power plants. OPG will continue to participate in municipal planning initiatives and will monitor planning development activity near its facilities, and participate as required throughout all phases of the project. 9.0 COMMUNITY COMMITMENT TO NUCLEAR EMERGENCY PLANNING Nuclear emergency planning for OPG s Nuclear Stations has been demonstrated in this submission to be extensive, detailed and tested. The plans are both legislated and recognized as required and have the full commitment of all parties involved, ranging from international agreements, through all levels of government to OPG and into the community (reference Appendix A: Integrated Matrix of Nuclear Planning in Ontario). OPG regularly interacts with stakeholders at all levels. However formal interactions are documented with the following authorities in this hierarchy: