Performance Review for Bruce A and Bruce B - Bruce Power

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N288.4-10 and its companion standards, CSA N288.5-11 and CSA N288.6-12. ...... must ensure conformance to the requirements of CSA N286-05, ...
BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B

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EXECUTIVE SUMMARY The revitalization of the Bruce site reached another major milestone in 2012 when, with the return to service of Unit 1 and 2, the site returned to full eight unit operation. Over the past 10 years, Bruce Power has invested $7 billion into site improvements and Ontario’s economy. As part of its 2040 vision, Bruce Power plans to continue its site revitalization work and will invest $1 billion a year over the next 15 to ensure its remaining units provide safe, clean and reliable electricity for generations to come. The renewal of Bruce A that began with the return of Units 3 and 4 in 2003 and the continued modernization of Bruce B have proven that Bruce Power’s nuclear fleet can be revitalized. With the revitalization effort, operating performance has steadily improved across the site: 

Over the past 10 years, Unit 4 has consistently been one of the top CANDU units in the world.



Units 5–8 set a continuous-run record in 2012-13 when all four units operated reliably for 125 straight days.



Unit 7 set a new standard for itself by operating for 460 consecutive days.



Unit 6 set a record run of 556 continuous days of operation. Unit 6 was the top performing CANDU reactor in the world for 2012 with a perfect 100 score on the World Association of Nuclear Operators’ Nuclear Performance Index (NPI).



Units 5-8 finished 2012 with a capacity factor of 95 per cent.

As Bruce Power moves forward to renew and modernize its nuclear fleet we will build on the lessons learned and the experience gained over the last decade to ensure greater certainty and predictability in future projects. Safety performance is an area of continual focus and improvement across the site. We constantly strive to achieve world-class performance levels by embracing a philosophy of continuous improvement. In 2013 the Bruce site reached over 14 million hours without a lost time injury. Likewise, diligent application of Bruce Power’s Radiation Protection (RP) Program has been effective at identifying and controlling radiological hazards. During the current licensing period Bruce Power has consistently maintained worker radiological exposures below regulatory limits and many enhancements to the RP Program have been implemented and are yielding positive results as discussed further in the Performance Report. Environmental performance remains strong with no major events. The 2012 dose to public demonstrates that the maximum dose received by a member of public due to Bruce Power site operations continues to be very small percentage of the annual legal limit of 1000 μSv/Year; less than 0.12% for 2012. Bruce Power will continue to adopt best industry standards as a framework for achieving continuous improvement and sustainable performance excellence, while minimizing our environmental impact and preventing pollution. Over the next licence period Bruce Power will implement Canadian Standards Association N288.4-10 and its companion standards, CSA N288.5-11 and CSA N288.6-12.

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Bruce Power has also invested considerable resources in several research and development projects related to measurement of potential impacts on Lake Huron including: 

The Bruce A Environmental Assessment follow-up activities committed as part of the Bruce A return to service. The follow-up program includes monitoring lake temperatures as well as monitoring source water fish densities and entrainment effects on Lake Whitefish, Spottail Shiner, and Deepwater Sculpin.



A major study, Effects of Thermal, Chemical and Radiological Emissions on Whitefish, supported by NSERC examining impacts of stressors on Lake and Round Whitefish populations. This study will examine how developing fish adapt to varying levels of external stress and whether stressors alone or in combination during embryogenesis can impact juvenile fish (after hatch).



Participation in CANDU Owners Group studies on fluctuating temperature effects on hatching success and timing for Lake and Round Whitefish.



A collaboration project with the Saugeen Ojibway Nation examining Lake Whitefish population structure in Lake Huron, as well as entrainment effects on Lake Whitefish.

More broadly, completion of the new Bruce-to-Milton transmission line in combination with the successful revitalization of Bruce A and continued strong Bruce B operating performance delivers 6300 megawatts of carbon-free energy to the people of Ontario from the Bruce site which has assisted the province in its plan to shut down coal plants and improve the health of Ontario residents. Bruce Power continued to support excellence in security and emergency response/planning through the creation of a combined organization, Emergency and Protective Services. Exercises and drills in both areas have demonstrated strong performance, including conduct of a large regional emergency exercise in the fall of 2012 as a proof of concept of the post-Fukushima improvements. Over 70 agencies and government organizations were involved in the four day long exercise which successfully tested interconnectivity and coordination of the multiple agencies. Bruce Power’s public information program has been expanded throughout the licence period including: Community & Government Relations, Community Investment & Sponsorship, Aboriginal Relations, Investor & Media Relations, and Employee Communications. Specific improvements since 2009 include enhancements to the corporate website, the addition of social media accounts (Twitter, FaceBook and YouTube), and Visitors’ Centre exhibit upgrades with extended hours of operation to include Saturdays in July and August. In addition, a Bruce Power “App” (application) was added to the list of communications vehicles in 2013 to enhance communications for iPad and iPhone users. In addition, recognizing that employees have a strong voice in the community and serve as ambassadors for the company and the nuclear industry, Bruce Power has increased efforts to keep employees informed and engaged through employee communications vehicles that include newsletters, an Intranet website, electronic information screens, monthly ‘Safety and Business Performance’ videos, and quarterly ‘Team Talks’.

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As part of Bruce Power’s external outreach efforts, the company completed a province wide public opinion poll to scientifically measure public support in a number of key areas. There is some very positive news in the results that demonstrate the company has made progress with outreach efforts. Provincially, support for nuclear refurbishment generally has surged to 74%. In terms of the Bruce Power refurbishments support is at 73%, up significantly (+10%) from 63% in 2012. In central Ontario, support is up 21% from 63% to 84% and in Toronto support is up 10% from 68% to 78%. The site revitalization has, of course, not been without its challenges. The additional operating units have necessitated an increase in staff levels, which was further challenged by higher than normal retirements due to the demographics on site. Over the period from 2001 to 2013 Bruce Power staff numbers have increased from about 3300 to 4100. Approximately 3,600 of these staff are assigned within the Chief Nuclear Officer’s organization. Bruce Power has taken several initiatives to ensure that staffing and training is able to keep pace with the need. In particular three staff pipelines in the key areas of: operations, maintenance, and engineering have been established and are being successful in integrating new staff and ensuring staff have the required competence to perform assigned work. Review and response to the 2011 Fukushima natural disaster has been at the forefront of industry discussion including Bruce Power and the Canadian industry. We are proud of Bruce Power’s industry leading achievements in response to this event: 

Emergency water pumping and electrical power equipment has been procured and stored near the site.



Emergency response crews have been trained and exercised multiple times in the deployment of the emergency equipment.



Changes to the power plants that allow hook up of water and emergency power to allow cooling of the fuel by alternate means have been completed and are available for use.



New emergency response command and control facilities and procedures have been put in place and tested.



A large general disaster coordinating exercise was held in the fall of 2012 demonstrate proof of concept for the new equipment, procedures and crews.

Bruce Power will continue to aggressively pursue the remaining objectives in the Fukushima follow up. Bruce Power also began the process of preparing for renewal of the remaining six units. The Periodic Application of Integrated Safety Review (PAISR) process will be used to support long term operation of Units 1 through 8, with the first full PAISR submission planned for no later than 2019. The PAISR is based on a Periodic Safety Review methodology described in IAEA Safety Guide SSG-25, “Periodic Safety Review of Nuclear Power Plants”. As part of an Asset Management initiative under way since 2009 we completed the plant condition assessments necessary to support this work and assure Fitness For Service throughout the proposed licence period. Fitness For Service is an ongoing process that confirms that plant operations remain within design and operational parameters. As part of the aging management program, Life Cycle Management Plans have been developed based on the completed condition assessments ensuring that that the current condition of Systems, Structures and Components is understood. The Life Cycle Management Plans are maintained current by

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monitoring aging effects and proactive action is taken where appropriate to ensure fitness for service on an ongoing basis. Safety significant elements of a full IAEA based Periodic Safety Review are being assessed and compiled, along with a Safety Basis Report covering a minimum five year time period. The Safety Basis Report will provide supplemental information to demonstrate the continuing safety case for operation of Units 1 to 8 until 2019 while the comprehensive PAISR methodology is developed and the full set of safety factor assessments completed. The set of deliverables and schedule were submitted earlier this year and include a Safety Basis Report (SBR) and Integrated Implementation Plan (IIP) to 2019.

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Table of Contents Page 1.0

INTRODUCTION .......................................................................................................................1

1.1 1.2 1.3

Background................................................................................................................................1 Highlights 2009 - 2014 ...............................................................................................................4 Summary of the Applications .....................................................................................................5

2.0

BUSINESS PLAN ......................................................................................................................6

3.0

CNSC SAFETY AND CONTROL AREAS.................................................................................8

3.1 3.1.1 3.1.2 3.1.3 3.1.4 3.1.5 3.1.6 3.2 3.2.1 3.2.2 3.2.3 3.2.4 3.2.5 3.2.6 3.3 3.3.1 3.3.2 3.3.3 3.3.4 3.3.5 3.3.6 3.4 3.4.1 3.4.2 3.4.3 3.4.4 3.4.5 3.4.5.1 3.4.5.2 3.4.5.3 3.4.5.4 3.4.5.5 3.4.5.6 3.5 3.6 3.7 3.7.1 3.7.2 3.7.3

SCA 01 - Management System..................................................................................................8 Management System, Organization and Change Management ................................................8 Safety Culture ............................................................................................................................9 Configuration Management......................................................................................................11 Records Management..............................................................................................................11 Management of Contractors ....................................................................................................12 Business Continuity .................................................................................................................13 SCA 02 - Human Performance Management ..........................................................................15 Human Performance Program .................................................................................................16 Personnel Training...................................................................................................................20 Personnel Certification.............................................................................................................24 Initial Certification Examination and Requalification Tests.......................................................26 Work Organization and Job Design .........................................................................................28 Fitness for Duty ........................................................................................................................34 SCA 03 - Operating Performance ............................................................................................36 Conduct of Licensed Activities .................................................................................................37 Trending and Reporting ...........................................................................................................48 Outage Management Performance..........................................................................................52 Safe Operating Envelope.........................................................................................................57 Accident Management and Recovery ......................................................................................58 Severe Accident Management and Recovery..........................................................................60 SCA 04 - Safety Analysis .........................................................................................................65 Deterministic Safety Analysis...................................................................................................65 Probabilistic Safety Analysis ....................................................................................................68 Criticality Safety .......................................................................................................................69 Severe Accident Analysis ........................................................................................................70 Management of Safety Issues .................................................................................................71 Heat Transport System Ageing ................................................................................................72 Large Loss of Coolant Margin Restoration...............................................................................73 Enhanced Neutron Over-power (NOP) Analysis for Aged Conditions .....................................75 Hydrogen Behaviour in Containment .......................................................................................76 Modified 37-element Fuel Bundle Project ................................................................................77 Generic Action Items and CANDU Safety Issues ....................................................................78 SCA 05 - Physical Design ........................................................................................................81 SCA 06 - Fitness for Service....................................................................................................94 SCA 07 - Core Controls and Processes - Radiation Protection .............................................102 Application of ALARA, Worker Dose Control, Radiological Hazard Control ..........................102 Radiation Protection Program Performance ..........................................................................105 Estimated Dose to Public .......................................................................................................111

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3.8 3.9 3.10 3.11 3.11.1 3.11.2 3.12 3.12.1 3.12.2 3.12.3 3.12.4 3.12.5 3.13 3.14

SCA 08 - Core Controls and Processes - Conventional Health and Safety...........................113 SCA 09 - Core Controls and Processes - Environmental Protection .....................................115 SCA 10 - Core Controls and Processes - Emergency Management and Fire Protection......121 SCA 11 - Core Controls and Processes - Waste Management .............................................125 Waste Management, Characterization, Minimization and Management Practices ................125 Decommissioning Plans.........................................................................................................127 SCA 12 - Core Controls and Processes - Security ................................................................127 Security (General)..................................................................................................................128 Security - Facilities & Equipment ...........................................................................................129 Security – Response Arrangements ......................................................................................131 Security Practices ..................................................................................................................131 Drills & Exercises ...................................................................................................................132 SCA 13 - Core Controls and Processes - Safeguards ...........................................................133 SCA 14 - Core Controls and Processes - Packaging and Transport .....................................134

4.0

OTHER MATTERS OF REGULATORY INTEREST .............................................................135

4.1 4.2 4.3 4.4

Environmental Assessment ...................................................................................................135 Aboriginal Consultation ..........................................................................................................135 Other Consultation .................................................................................................................138 Long Term Operation .............................................................................................................139

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INTRODUCTION The Performance Review of Bruce A and Bruce B has been prepared as a supplemental submission in support of the Power Reactor Operating Licence renewal applications for the two facilities. This performance review report was prepared using the guidance found in CNSC Guidance Document GD-379, Guide for Applicants and Interveners Writing CNSC Commission Member Document and INFO-0715 Canadian Nuclear Safety Commission Public Hearings on Licensing Matters.

1.1

Background Bruce Power is Canada’s only private sector nuclear generator and operates the world’s largest operating nuclear generating facility, located in rural southwestern Ontario. The company is a Canadian-owned partnership of Borealis Infrastructure Inc. (Ontario Municipal Employees Retirement System (OMERS)), TransCanada Corporation, Cameco Corporation, the Power Workers’ Union and The Society of Energy Professionals. The site is capable of producing 6,300 MW, which is more than a quarter of Ontario’s electricity. The company employs approximately 4,100 people on a permanent basis. As a result of investment activities, the site has been the single largest source of Building Trades work in Ontario over the last 10 years. The company is also the single largest private investor in Ontario’s electricity infrastructure with a total injection of $7 billion into the Bruce Power site since 2001. As Canada’s largest public-private partnership, the site is leased from the Province of Ontario under a long-term arrangement where all of the assets remain publicly owned, while the company makes annual rent payments and funds the cost of waste management and eventual decommissioning of the facilities. Bruce Power’s shareholders are also the owners of Ontario’s first commercial wind farm, Huron Wind, which produces enough electricity for 3,000 local homes annually. Bruce Power’s 2,300-acre site on the shores of Lake Huron houses the Bruce A and B generating stations, which each hold four CANDU pressurized heavy water reactors. The Bruce A nuclear facility is located on the shore of Lake Huron on parts of lots 28, 29, and 30, and the Bruce B nuclear facility is located on the shore of Lake Huron on parts of lots 12, 13, 14 and 15, Lake Range, Municipality of Kincardine, County of Bruce, Province of Ontario. The Bruce A and Bruce B facilities are commercial nuclear generating stations that, in accordance with their licences, produce electricity for sale into the Ontario and other North American electricity markets. Bruce Power is applying for renewal of the Power Reactor Operating Licences for Bruce A and Bruce B for a period of 5 years; beginning November 1, 2014 to October 31, 2019.

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Figure A Bruce A Nuclear Generating Station

Bruce A

Net Output (MWe)

Original in Service Date

Layup Date

Return to Service Date

Unit 1

750

1977/09/01

1997/10/16

2012/09/19

Unit 2

750

1977/09/01

1995/10/08

2012/10/16

Unit 3

750

1978/02/01

1998/04/09

2004/01/09

Unit 4

750

1979/01/18

1998/03/16

2003/10/07

Figure B Bruce A Historical Information

Since the return to service of Units 1 and 2 in 2012, these units have demonstrated strong operational performance, much better than predicted for units that had been out of service for two decades. In October 2013, Units 3 and 4 will mark 10 years since they were returned to operation in 2003 and their performance over the past decade has been very strong. Through investments and focus on excellence in operations, additional life added to Units 3 and 4 has been significant, providing additional flexibility related to the timing of major component replacements for these units. These units have also demonstrated strong operational runs. In 2012, before Unit 4 was taken offline for a planned outage, the unit ran 569 days straight – which was a new record run for the unit.

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Figure C Bruce B Nuclear Generating Station (in foreground)

Bruce B

Net Output (MWe)

Original in Service Date

Unit 5

822

1985/03/01

Unit 6

822

1984/09/14

Unit 7

822

1986/04/10

Unit 8

822

1987/05/22

Figure D Bruce B Historical Information Bruce B, which provides about 15 per cent of Ontario’s electricity needs on an annual basis, has also demonstrated strong operations. The plants units compete with the best performing CANDU nuclear units in the world. In fact, before a planned outage began at Bruce B in January, 2013, all four Bruce B units achieved a record run of 125 days. Unit 6 ended 2012 as one the world’s top rated CANDU reactors, while Unit 5 was the top performing CANDU in the world in 2011. Through continued investments and focus on excellence in operations, the additional life added from the Bruce B units has also been significant, providing additional flexibility related to the major component replacement timing for these units.

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Over the last 12 years, Bruce Power has worked to be a responsible neighbour in the small communities we operate in. Community support for Bruce Power and the long-term ambitions for the company are strongly supported by the local community and is something the company has not and will never take for granted. Through open communications, an active community outreach program and our extensive community investment and sponsorship program we have created a strong foundation to build on in the years to come, which is an important consideration for any large energy infrastructure projects. Another important component to Bruce Power’s business is meaningful and effective engagement with Aboriginal communities. Given the location of our site, there are three Aboriginal groups we engage with on a regular basis including the Saugeen Ojibway Nation (SON), Historic Saugeen Métis (HSM) and the Métis Nation of Ontario (MNO). The company has protocol agreements in place with all three of these Aboriginal groups that enable active collaboration on issues, such as regulatory approvals, employment, training, education, community investment, business development and open communications. 1.2

Highlights 2009 - 2014 Since it took over the site in 2001, innovation has been a central component to Bruce Power’s success. The $7 billion in private investment in Bruce A has allowed the company to double the number of its operational units from four to eight, resulting in an additional 3,000 megawatts of low-cost, safe, reliable and clean electricity for Ontario ratepayers. 

Restart of Units 1 and 2: After being shut down by the former Ontario Hydro in 1995 and 1997, Bruce Power announced its plan to restart these reactors in 2005. A refurbishment of this scale had never been attempted in the history of CANDU reactors. At its peak, 3,000 contractors worked on the project and completed numerous innovative, first-of-a-kind programs that have set the stage for refurbishment projects across Canada and the world. Units 1 and 2 were returned to service in 2012 and provide Ontario with 1,500 megawatts.



Emergency response upgrades: Following a tsunami, which caused a nuclear event at the Fukushima Daiichi nuclear facility, the world’s nuclear operators took lessons learned and implemented them at their own plants. Bruce Power, as well as other CANDU operators, already feature a multi-layered defense system, which work independently of each other should a loss of power occur. The company found some areas for improvement, specifically in its emergency response function, and made significant upgrades to its fleet of fire trucks, which can now provide 24-hour cooling water to plant systems. Bruce Power also purchased numerous back-up generators, which will be stored off-site and on high ground.

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Figure E Trial Test of emergency response equipment at Bruce B

1.3



Increasing the output from Bruce B: Through a process known as ‘core re-ordering,’ which involves changing the direction in which fuel is inserted into the reactor, all Bruce B units have been increased from 90 to 93 per cent reactor power. Combining all four Bruce B units, this is a 100 megawatt increase in generation, enough electricity to power 100,000 Ontario homes. In 2010, Bruce Power completed this process in Unit 8, the last of the Bruce B units to be completed.



West Shift program: West Shift, a six-month outage in Unit 3, allowed crews to move fuel channels back to their original positions after they elongated after years of high temperatures, radiation and pressure. Each channel was cut free from the reactor and rewelded into place to ensure the safe operation of the reactor through at least the end of the decade.



Industrial Safety Performance: At time of submission the Bruce site had reached over 14 million hours without a lost time injury. Over the licence period Bruce Power also achieved a run of over 22 million hours without a lost time injury and there has not been a lost time injury at the Bruce A facility since December 2002, a period of over 10 years.

Summary of the Applications Bruce Power took over operational control of the Bruce Power site in May 2001 under 2 year operating licences for Bruce A and Bruce B. Those licences were renewed for a period of 5 years in 2003 and again in 2009 (after a short extension was granted by the Commission in 2008 to sort out issues related to financial guarantees). Bruce Power is once again applying for renewal of the Power Reactor Operating Licences for Bruce A and Bruce B for a period of 5 years; beginning November 1, 2014 to October 31, 2019. The licence applications for Bruce A and Bruce B, which were submitted under separate cover, demonstrate how Bruce Power meets the requirements of the Nuclear Safety and Control Act, the General Nuclear Safety and Control Regulations, the Class I Facilities Regulations and the Nuclear Security Regulations. These applications are supported by supplementary information in the Bruce A and B Performance Review report and the Safety Basis Report which will provide supplemental information to demonstrate the continuing safety case for operation of Units 1 to 8 until 2019 developed using the safety significant elements of a full IAEA SSG-25 based Periodic Safety Review.

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BUSINESS PLAN The Bruce Power business plan is built upon the understanding that every employee, regardless of their job, maintains a profound respect for nuclear safety and plays a role in operating our units to the world’s highest standards. In our pursuit of operational excellence, safety lies behind every decision we make and every initiative we pursue. In the short-term, our continued focus as an organization will be the further integration of site operations and best practice between Bruce A and B and to continue with the ongoing operational investment program to ensure the delivery of safe, reliable performance from our units. Bruce Power has committed to the implementation of a Periodic Approach to Integrated Safety Review (PAISR) process in support of long term operation of Units 1 through 8, with the first full PAISR submission planned for no later than 2019. The scope of the PAISR will be based on IAEA Specific Safety Guide SSG-25, “Periodic Safety Review for Nuclear Power Plants”, taking the Integrated Safety Review process as described in CNSC Regulatory Document RD-360 “Life Extension of Nuclear Power Plants” into consideration. As part of an Asset Management Initiative under way since 2009 we have been completing the plant condition assessments necessary to support this work. Efforts to build on an industry leading emergency response capability will also continue as we work to not only maintain and build our strength in this area, but in parallel, continue to implement post-Fukushima improvements based on lessons-learned. Bruce Power also appreciates the interest in our business from the public generally and understands that effective communications is an important component to earning our 'social licence' to operate. Bruce Power will continue to implement a comprehensive outreach effort building on our previous successes in this area. In the long-term, Ontario's Long Term Energy Plan (LTEP) is based on a foundation of eight units or 6,300 MW from the Bruce Power site for decades to come. Bruce Power continues to be actively engaged with the Ontario Power Authority (OPA) on this matter to ensure major component replacement unit outages can be effectively sequenced and managed from a resource and supply stability point of view. Work is continuing to determine what options may be available to advance certain elements of these important activities during periods of lower demand expected in the coming years as a proactive measure. It is estimated that to secure our future in the Ontario electricity market, an additional $12 to $16 billion of investment will be required on the Bruce Power site over the next 10 years. This will require both investor support and the appropriate commercial arrangements with the province. Going forward Bruce Power will continue to: 

Focus on site integration activities that will allow us to maximize the potential of the eight units on the site.



Make investments to support improved execution of outages with particular emphasis on reactor inspection tooling.



Respond to the post-Fukushima requirements in an effective and timely manner.

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Improve our strategic spares inventory.



Create a ‘performance culture’ through the introduction of an Operating Efficiency organization.



Make investments that maximize the operational life of Units 3 to 8.



Make infrastructure investments in critical areas of our facility.



Creating an integrated talent management program to effectively manage the resource pipeline.



Make enhancements to our Radiation Protection Program.

BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B 3.0

CNSC SAFETY AND CONTROL AREAS

3.1

SCA 01 - Management System

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The management system SCA covers the framework that establishes the processes and programs required to ensure an organization achieves its safety objectives, continuously monitors its performance against these objectives, and fosters a healthy safety culture. The specific areas covered include:         3.1.1

Management System Organization Change Management Safety Culture Configuration Management Records Management Management of Contractors Business continuity

Management System, Organization and Change Management Relevance and Management The objective of the Bruce Power Management System (BPMS) is to coordinate the business framework needed to satisfy corporate governance and regulatory requirements at a level and to an extent that will ensure commitment to nuclear safety (i.e. reactor safety, radiological safety, industrial safety and environmental safety) as the first priority. It implements the management system and it controls changes to the interdependent processes, organization and document structures that are essential to managing business. The BPMS which is documented in a Management System Manual and a supporting hierarchy of governance serves as Bruce Power’s quality assurance program and, as such, must ensure conformance to the requirements of CSA N286-05, Management System Requirements for Nuclear Power Plants specified in Bruce A/Bruce B Power Reactor Operating Licences. Bruce Power’s Management System Manual, the Organizational Authority Register and the Organization Manuals define the authorities and responsibilities unique to each leadership position at section manager level and above. The clear definition of roles, authorities and responsibilities is critical to achieving excellence in nuclear safety and achieving Bruce Power’s business goals. An Approved Reference Chart of the organization structure is maintained. It is derived from information contained in the SAP database (the official system of record) and defines the organizational names, positional/role titles, and reporting structure. An annual report on changes to the Nuclear Organization (titled “Annual Summary of Bruce Powers Organizational Changes”) is submitted to the CNSC as required by Licence Conditions Handbook for both Bruce A and B in the first quarter of each calendar year.

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Bruce Power‘s Change Management procedure and the associated governance establish a framework such that changes to organization, processes, designs, systems, equipment, materials and documents shall be identified, justified, reviewed by stakeholders, approved and implemented. Past Performance Throughout the licence period, improvements have been made to assure the quality of submissions of organizational change management proposals. This has enabled more effective configuration management of the various systems and structures impacted by any organizational change, while facilitating communication about organizational changes to those impacted, including impacts on authorities and process responsibilities. A continuing area of focus is to ensure accurate verification of initial change proposals, to ensure they capture the significant impacts for consideration prior to endorsement to proceed with the change. Future Plans The process for organizational change management will continue to be strengthened and streamlined as the integrated management system and this process further mature. It is Bruce Power’s intention to move to the updated version of the Canadian Standards Association Standard N286-12, Management Systems Requirements for Nuclear Facilities, to reduce duplication within the management system. A transition plan will be developed in the near future. Challenges Some areas, such as Pressure Boundary Quality Assurance, still operate as a small managed system within the larger managed system. This creates significant duplication of effort and makes it more likely that processes will get out of step. Oversight of work processes to ensure complete alignment with requirements continues to evolve and will be further strengthened over the next licence period. Requests None 3.1.2

Safety Culture Relevance and Management Bruce Power's number one value is Safety First. Ensuring a healthy Nuclear Safety Culture is essential in the nuclear industry and is part of the Bruce Power Management System (BPMS), as an objective and a means to high standards of excellence. Past Performance In 2011 Bruce Power recognized an opportunity to introduce a monitoring process to identify subtle changes in Nuclear Safety Culture between formal assessments. Bruce Power considers this approach a leading practice and has implemented Nuclear Safety Culture Monitoring Panels (NSCMP) at Bruce A since May 2012 and Bruce B since September 2012.

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The objectives of the NSCMP is to review the material from various managed processes against the INPO/WANO Traits of a Healthy Nuclear Safety Culture, which are broadly equivalent to IAEA Safety Culture Characteristics, to identify themes for further reflection and action, as well as to foster a common understanding across the organization of Safety Culture. The pilots included Nuclear Safety Culture awareness and refresher session for leaders and each subsequent NSCMP has included a learning component through the participation of a safety culture expert who acts as a coach to facilitate deeper awareness of safety culture OPEX. Another goal of the NSCMP process is to enable an ongoing holistic, objective, transparent and safety-focused process, which uses a broad spectrum of the information available within the company (e.g., the corrective action program, performance trends, CNSC inspections, industry evaluations, self-assessments, audits, operating experience, workforce issues, etc) to provide an early indication of potential Safety Culture issues, develop leadership responses to these and monitor the effectiveness of any actions. This process is intended supplement more formal periodic Nuclear Safety Culture Assessments that are required by WANO and the CNSC. The NSCMPs will continue to meet periodically (two to four times per year) to assess Nuclear Safety Culture trends or potential issues and provide a report to the Bruce Power Site Leadership Team. Bruce Power is using the Nuclear Energy Institute document NEI 09-07 “Fostering a Strong Nuclear Safety Culture”, as a guide for this process Bruce Power has also conducted Nuclear Safety Culture Assessments during the licence period, most recently a comprehensive site wide self-assessment in May-June 2013. The Assessment used the INPO/WANO Traits of a Healthy Nuclear Safety Culture Framework and included a survey, interviews and focus groups as part of the methodology. Results from the Assessment are being considered and action plans developed to address findings. On a regular basis, leaders at Bruce A and Bruce B are provided structured opportunities to review Nuclear Safety Culture operating experience as part of an industry wide WANO requirement. The INPO/WANO Traits of a Healthy Nuclear Safety Culture are being rolled out to all staff through special focus segments during Bruce Power’s monthly safety video. Future Plans Development of standardized governance around nuclear safety assessment activities (NSCMP and regular assessments) is planned over the next 12 months. Actions arising from the 2013 Nuclear Safety Culture Assessment will be developed, approved and implemented. Development of methodologies and sharing of good practice to more quickly assess and respond to potential changes in nuclear safety culture will continue to be a focus. There is an opportunity to undertake more narrow but more frequent assessments and to extend the time between full assessments to every 3-5 years. Nuclear Safety Culture is being integrated as a topic in our Leadership Development training.

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Challenges Nuclear Safety Culture is difficult to measure and relies of the ability of leaders or nuclear safety culture experts to draw insights from the data which typically emerges from nuclear safety culture assessments. To date, Bruce Power has relied upon external support to help discern underlying issues in the data and develop insights. Going forward, Bruce Power will enhance our leadership capability around nuclear safety culture assessment methodology and reporting. Requests CNSC is proposing a new Regulatory Document related to Safety Culture assessment. This field has evolved considerably since the early 2000s and will continue this evolution at least through the next licence periods. Any Regulatory Document must recognize the nature of this area and not act to stymie the ongoing development of tools and methodology. 3.1.3

Configuration Management Refer to SCA 05, Section 3.5, Physical Design

3.1.4

Records Management Relevance and Management The objective of records and document management is to manage the life cycle of records and documents in a manner that provides accurate, legible and readily accessible information, regardless of media, while satisfying applicable legal and regulatory requirements. This includes the effective acquisition, control and safekeeping of documents and records. This program is intended to satisfy relevant statutory, regulatory and licensing requirements, such as CSA N286-05, Management System Requirements for Nuclear Power Plants and CSA N285.0, Requirements for Pressure Retaining Systems and Components in CANDU Nuclear Power Plants and the associated ASME Boiler and Pressure Vessel Code, Section III, Division 1, Article NCA4000. Program plans and processes are developed to take into consideration the impacts of Nuclear Safety as they apply to decision making and risk management of Industrial Safety, Environmental Safety, and Radiological Safety in support of overall Reactor Safety. Past Performance Overall, Bruce Power’s document management program has had strong performance in support of licensed and non-licensed activities including Pressure Boundary and other regulatory, legal and business requirements. Bruce Power continues to monitor Pressure Boundary and other programs to sustain alignment and ensure compliance to Bruce Power processes. Monthly quality checks show a high self-identification ratio with a healthy, mature organization and no significant adverse conditions.

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Future Plans Bruce Power will be focusing on reducing paper in the Records storage facilities, and streamlining processes resulting from increased automation versus manual tasks with the future implementation of electronic medium for Bruce Power. Technology is available to take the programs with Records Management to the next phase. Currently Bruce Power is looking at all of the associated safeguards required to implement an electronic format for record keeping. Challenges None Requests None 3.1.5

Management of Contractors Relevance and Management The purpose of Bruce Power’s Contractor Management Program is to provide guidance to Bruce Power employees with respect to managing contractors who are performing work for Bruce Power. It is to ensure work is managed and executed per contractual documents and in accordance with safety requirements, applicable procedures, budgets, schedules and quality standards. This program, through its implementing procedures, defines oversight processes and the roles and responsibilities of Bruce Power and its contactors Past Performance In order to assess the effectiveness of Contractor Management at Bruce Power, two Focus Area Self Assessments were conducted during the current licensing period and Station Condition Records, which are reports associated with Bruce Power’s corrective action program, were reviewed. Strengths of the existing program and implementing procedures were identified as follows:  

Checklist tools are available and provide guidance for users. A complete reference for users managing contractors is provided.

Areas for improvement or factors identified as contributing to issues involving management of contractors are summarized as follows:     

Responsibilities for some aspects should be clarified. Inconsistent definition of verification requirements. Inconsistent supervisory oversight / procedural adherence. Insufficient application of training / experience in contractor management. Inconsistent communication or understanding of Bruce Power procedures.

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Since licence renewal in 2009, Bruce Power has made modifications to its Contractor Management Program in response to identified issues. The following improvements have been realized: 

Clarification of roles and responsibilities for those involved with contract and contractor management and elimination of some duplicative content.



Emphasis on on-boarding and training of contractor personnel.



Training developed and implemented to support contractor supervision in the field.



Implementation of work verification plans where inspection and test plans are not required.

Future Plans The following improvement initiatives are planned for the Contractor Management Program: 

Improve integration with Contract Management, Human Resource Management, Outage Management and Safety programs to ensure clarity of requirements and governance responsibilities.



Consider the variety of contract types for which execution oversight must be conducted and include more specific guidance in the program and implementing procedures to address the growing specialization in the nature of contracted work and types of contracts being implemented.

Challenges A growing number of stakeholder requirements must be met during processes to hire, on-board, oversee and off-board supplemental employees making it a challenge to consistently ensure the requirements of all stakeholders are met. The trend towards increased specialization in the nature of contracted work and types of contracts being implemented means the Contractor Management Program are regularly reviewed and assessed to ensure tools and techniques are included to supervise and oversee the variety of contracted work conducted on site (i.e. one size does not fit all). The “future plans” discussed above include the improvement initiatives. Requests None 3.1.6

Business Continuity Relevance and Management The Business Continuity Program at Bruce Power consists of 18 line organizations that have been identified to provide critical services to supporting operating the stations and the completion of outages. Each of these line organizations has a business continuity procedure that provides instructions to continue and/or restore their identified critical services to support station operations and outages.

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These procedures outline the resources that the line organization would require from Information Technology (critical software applications that a line organization needs to provide critical services); Property Management (work space requirements e.g. desks, computers, phones that a line organization needs to provide critical services) and Business Services (vital hard copy record requirements that a line organization needs to provide critical services). As a result, these three line organizations are responsible for implementing business continuity activities. Therefore, each of these line organizations are required to sign and approve other line organization business continuity procedures to ensure that they are aware of the resources required and the timelines for providing those resources. Each line organization also has a confidential contact list document which they use to contact their line organization in the event that their business continuity procedure is implemented. Bruce Power maintains business continuity procedures within the following organizations.                  

Law Training Division Information Technology Simulator Information Technology Site Service Operations Human Resources Supply Chain Finance Power Marketing Radiation Protection Outage Management Work Management Waste Management Reactor Safety & Engineering Performance Engineering Nuclear Safety Analysis & Support Equipment Life Cycle Engineering Plant Design Engineering

Past Performance All the 18 line organizations mentioned above complete business continuity assignments on an annual basis. These are as follows:   

Review of line organization Business Continuity Procedure Review line organization Confidential Contact list Conduct a business continuity drill

These assignments are tracked under a business continuity report that provides a “snap shot” of the status. Corrective actions are initiated at the end of the year as required. All completed Business Continuity Drills are documented in a drill report.

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A Corporate Business Continuity Exercise is conducted by the Emergency Management Department once every two years. This exercise tests the implementation of business continuity activities. Guidance on how to conduct a corporate exercise is documented in the Business Continuity Drills & Exercises procedure. In addition, business continuity administration/coordination roles and responsibilities are included in the Business Continuity Plan document. This document is referenced by the individual in the Emergency Management Department that is responsible for coordinating the business continuity program at Bruce Power. Future Plans In response to lessons learned, the Business Continuity implementation process is being re-structured to include an Oversight/Support Manager that would oversee/manage business continuity activities during an incident. Additionally Business Continuity Guidelines are being developed regarding how to oversee/manage business continuity activities and a Business Continuity Incident Action Plan to document/communicate business continuity activities being carried out within a certain timeframe. In addition, Business Continuity has been separate from the Bruce Power Emergency Response Organization (ERO). As a result, future plans are being develop to incorporate business continuity into the ERO. This is being achieved through the development of a business continuity activation guideline to be used by the ERO’s Emergency Management Center’s Commander when determining if business continuity actions should be activated. Also, a five year business continuity exercise plan has been developed to validate the effectiveness of these future plans. As a result, Business Continuity Corporate Exercises will be completed on an annual basis rather than once every two years. Challenges It was a challenge to determine an effective oversight capability for business continuity due to the broad scope of the requirement. Emergency Management Centre Commanders will be rotated through this role on an annual or biannual basis since they are already involved in the Emergency Response Organization. The Emergency Management Department will ensure appropriate training is in place to manage/oversee business continuity activities. Requests None 3.2

SCA 02 - Human Performance Management The human performance management SCA covers activities that enable effective human performance through the development and implementation of processes that ensure that licensees have sufficient staff in all relevant job areas with the necessary knowledge, skills, procedures and tools in place to safely carry out their duties. Topics reviewed include:      

Human Performance Program Personnel Training Personnel Certification Initial Certification Examination and Requalification Tests Work Organization and Job Design Fitness for Duty

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Human Performance Program Relevance and Management The purpose of the Bruce Power Human Performance (HU) Program is to achieve excellence in Human Performance at the individual and organizational levels. At the individual level, human performance represents the correct deployment or demonstration of behaviours aimed at accomplishing specific results. At the organizational level, human performance reflects a system of processes, influences, behaviours, and results. When aggregated or taken together, these are manifested in the behaviours of individuals and the organization as a whole. Bruce Power's Human Performance principles are: 

We strive for Human Performance excellence in all our activities.



Continuous Human Performance improvement is foundational to improving Nuclear Safety (Reactor Safety, Industrial Safety, Radiological Safety, Environmental Safety) and plant reliability.



Human Performance improvement is systematic and systemic.

Bruce Power's HU Program has been designed to reduce the likelihood of human error in all aspects of work activities. This applies to knowledge-related work activities (e.g. the design of systems or in the planning of work activities) as well as behaviour-related work activities (e.g. actions or activities undertaken by workers which reflect both defined behavioural performance specifications and environmental conditions.) The fundamental goals for Bruce Power have been to strengthen the monitoring of human performance and to reduce human performance-related events and errors. Bruce Power has made significant progress to date in their implementation of Human Performance program plan elements that will help them achieve these goals. Over the past few years, for example, Bruce Power has achieved significant improvement in the monitoring of human performance behaviours. This has been achieved through the management and implementation of a new Observation and Coaching tool and corresponding use of a worker behaviour checklist database. The new Observation and Coaching tool has proven to be highly effective over the past two years in identifying work areas and activities that require additional focus in regards to human performance. Additionally, the system has proven effective in identifying behaviour-related work activities that are linked to nuclear safety adverse events. Implementation of the new system with the checklist database has enabled Bruce Power management to effectively identify areas for improvement (e.g. plant work areas, activities, and worker behaviours) and subsequently reduce the incidence and prevalence of nuclear safety events. By strengthening the organization's ability to focus on high risk areas and areas requiring improvement, Bruce Power management has also been able to define improved corrective actions (e.g. adjusting job qualifications, amending system requirements, adjusting environmental work conditions, developing new training programs, etc).

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The actions and activities undertaken over the past several years have resulted in reducing errors, reducing the incidence and prevalence of nuclear safety events and strengthened the overall corporate outlook related to nuclear safety. In short, these actions have strengthened Bruce Power's culture of safety. Past Performance Bruce Power has made tremendous strides in developing and implementing the Human Performance Program over the past licence period. These strides are reflected in the numerous revisions of the HU Program document and the creation of five human performance procedural documents in support of the program goals and objectives. These five human performance procedure documents address human performance tools for workers, human performance event monitoring and classification, observation and coaching, and the process for obtaining procedural alterations. In the past licensing period, Bruce Power has also developed and implemented a new observation and coaching tool, which has been supported by a suite of processes and procedures. The observation and coaching tool has enabled improved supervision and coaching of staff throughout all phases of work planning, preparation, execution, and tear down (including post-job debriefs and lessons learned). The observation and coaching tool has also strengthened the engagement of Supervisors (including senior management) with front line staff. This has been achieved through the increased deployment of observations and coaching in the field (see Figure 1) which has also has greatly improved worker compliance (see Figure 2) with expected behavioural standards and best practices. Improved emphasis on observation and coaching has both reduced the human error rate and has resulted in the strengthening of defensive barriers leading to a reduction in consequential human performance related events. Two additional Human Performance Managers were also hired within the past licensing period. As a result, a dedicated Human Performance Manager was integrated into each of the three main work areas at the Bruce Power site namely: Bruce A, Bruce B and Centre of Site. The integration of a dedicated Human Performance Manager has served to better implement Human Performance monitoring, reporting, and coordination of improvement activities within each of the three main areas. In addition, Human Performance Dynamic Learning Activities (DLAs) developed under the oversight of the Human Performance Managers has resulted in improved staff adherence to HU tools and other best practices behaviours that are in support of event free operation. Progress with respect to worker knowledge and proper use of human performance tools is made evident based on the decrease in Station and Department HU clock resets - particularly since January 2013 (see Figure 3).

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7000

Good

5000 4000 3000 2000 1000 0 Q4 2010

Q1 2011

Q2

Q3

Q4

Q1 2012

Q2

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Quarter Bruce 'A'

Bruce 'B'

Centre of Site

Total

Figure 1 Human Performance Observation and Coaching Events 100%

Good

95%

Percent Compliant

Number of Observations Performed

6000

90%

85%

80%

75%

70% Q2

Q3

Q4

2012

Q1

Q2 2013

Quarter Effective Communication

Questioning Attitude and Stop when Unsure

Procedure Use and Adherence

Figure 2 Worker Compliance to HU Tool Behaviour Expectations

Pre-Job Brief

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20

Number of Station Level Clock Resets

18

Good

16 14 12 10 8 6 4 2 0 2007

2008

2009

2010

2011

2012

2013

Year Target for Total Clock Resets

Bruce 'A' Clock Resets

Bruce 'B' Clock Resets

Total Station Clock Resets

Figure 3 Human Performance Clock Resets Future Plans In 2013, Human Performance Advocate positions were established as support within certain department areas to further the development and implementation of HU related Dynamic Learning Activities (DLAs). Future DLAs to be developed will include those specific to Operational, Maintenance and Outage activities to promote greater levels of realism and as a result worker appreciation with respect to how human performance tools may be applied to their work area. Development of the DLAs will also be based on a review of significant 2012 Human Performance related events that have highlighted the various types of work activities and the key set of HU tools which, had they been effectively applied, would have prevented event occurrence. Bruce Power will also continue to develop and maintain fiscal year excellence plans that incorporate HU improvement activities at each of the stations. In addition to this, Department HU Advocate roles and responsibilities will include their support towards the development of Department specific HU Performance Improvement plans and performance reporting. These new efforts along with Bruce Power's continued development of their Human Performance Program in line with INPO/WANO guidelines and best practice benchmarking with industry standards will maintain an effective HU program in line with maintaining Bruce Power's continued pursuit of zero events with consequence. Challenges None

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Requests None 3.2.2

Personnel Training Relevance and Management Personnel Training is managed by Bruce Power through our Worker Learning and Qualification program whose purpose is to enable personnel to competently and safely operate, maintain, and improve the performance of our Stations. Learning includes both the training elements for Worker Qualifications that grant working rights and the training elements that support Professional Development. Worker Qualifications Bruce Power recognizes the substantial role played by training in ensuring staff have the required competence to perform assigned work. Providing high quality initial training to qualify newly hired or newly assigned staff and then maintaining and improving their knowledge and skills via continuing training is a key element in the Bruce Power strategy to ensure quality in operations. Bruce Power has approximately 4,100 staff. Approximately 3,600 of these staff are assigned within the Chief Nuclear Officer’s organization. Approximately 2,850 of these staff hold positions or roles for which Bruce Power applies the most rigorous systematic approach to determining the competence required to safely and competently perform their job. These staff hold what are referred to as “Key Qualifications”. Key Qualifications equate closely with “Accredited Positions” regulated by the United States Nuclear Regulatory Commission (NRC). In fact, Bruce Power’s list of Key Qualifications is larger than the USNRC list. These staff are the people that directly operate and maintain the plant. It is staff in these positions that Bruce Power deems to be staff whose qualifications form an important part of our defence-in-depth with regard to safety. Therefore, these staff all hold qualifications that rigorously train and test them to ensure they have and maintain the knowledge and skills required of the job. Other staff (staff that do not directly operate the plant) are qualified for their jobs by ensuring they meet the education, experience, and knowledge requirements of the role via the hiring process combined with a variety of training and qualification requirements. Professional Development Professional Development includes Bruce Power financial support for attendance at a single professional development course, or participation in a program which results in a degree or recognized diploma, or a professional certification not required by an approved Initial or Continuing Qualification. Bruce Power uses professional development to enable staff to add knowledge and skills beyond those required to be qualified for their current position. The intent is to foster an environment of life long learning to add breadth and depth to a current knowledge and skills base in order to improve performance, or to prepare staff for a future role.

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Governance & Oversight A Learning Governance & Oversight Committee Structure has been put in place to implement the Governance & Oversight functions within the GOSP Model of accountabilities prescribed in the Bruce Power Management System Manual. Learning Governance Committee – This Committee is chaired by the Chief Nuclear Officer and is responsible for the Governance accountabilities for the Learning Functional Area including the ongoing assurance that programs and processes are “leading practices” compliant with government regulations, aligned with Bruce Power Policy and that they are implemented consistently throughout Bruce Power. Reporting to this committee are the Cross Functional Qualifications Oversight Committee and the Key Qualifications Oversight Committee. These committees are established under a Vice President appointed by Learning Governance Committee. Reporting to these Oversight Committees are Training Program Owners that maintain documentation of assigned programs inside of a Training Qualification Description (TQD). The Training Information and Management System (TIMS) is the system of record to show that staff hold the qualifications required by the TQD document associated with their work assignment. Past Performance Bruce Power’s Worker Learning & Qualification Program has several significant aspects, they are: 1.

There are 1290 unique qualifications contained within 42 major TQDs that have been created to ensure that staff hold the required competence to perform assigned work.

2.

The chart in Figure 4 below shows the total number of qualifications held by staff on a representative day each quarter for the past eleven quarters. An individual may hold many qualification and on average over the last eleven quarters approximately 4,100 staff together hold an average of 24 qualifications each and a total of 103,259 qualifications.

3.

The chart in Figure 5 below shows the total number of qualifications held by supplemental staff (supplemental staff are temporary employees of Bruce Power or employees of other companies holding contracts to provide services to Bruce Power. The average of 20,392 qualifications being held by supplemental staff over the last eleven quarters illustrates the volume and thoroughness of our program to ensure these staff are qualified for work assignments at Bruce Power.

4.

Bruce Power also carefully tracks the subset of the above graphed qualifications that must be available at our stations 24 hours a day 7 days a week. These are known as Minimum Complement Qualifications. This tracking ensures significant numbers of qualified staff are available to fill required roles and helps to ensure sufficient staff onsite at all times holding currently valid qualifications.

5.

Bruce Power also carefully tracks the subset of the above graphed qualifications that we deem important to efficiently and safely operate or Stations. This subset is known as Business Capability Qualifications.

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For all qualifications Bruce Power maintains a rigorous program containing several checks and balances to ensure staff that have not completed qualifications or have expired qualifications are not assigned to perform associated work independently.

110000 108000 106000 104000 102000 100000 98000 96000 94000 92000 90000 88000 Q1 2011

Q2

Q3

Q4

Q1 2012

Q2

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Figure 4 Number of Qualifications Held by Regular Staff over 11 Quarters

30000

25000

20000

15000

10000

5000

0 Q1 2011

Q2

Q3

Q4

Q1 2012

Q2

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Figure 5 Number of Qualifications Held by Supplemental Staff over 11 Quarters

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Future Plans Over the next licence period the Personnel Training area will systematically improve in the following five areas. Together these improvements will further enhance our current methods to ensure staff have the required competence to perform assigned work. 1.

Outage Worker Supplemental Staff Journeypersons Task Qualifications Supplemental staff tradesmen in the Province that support maintenance outages at the stations are increasingly new to the nuclear industry. Province-wide there is expected to be a shortage of Journeypersons. The change planned is that Outage Maintenance Workers will be expected to be “Task Qualified” in addition to being Journeypersons. Competence will be evaluated using an international standard for the Task Knowledge & Skills recognized jointly by Ontario Power Generation (OPG), Bruce Power and the Unions. This will further ensure qualified Journeypersons are prepared to perform specific tasks at Bruce Power.

2.

Entry Level Staff Knowledge Upgrades Consistent predictable entry level Knowledge & Skills better supports efficient quality instructional design. The change planned is that Bruce Power will establish formal relationships with selected colleges in the Province with programs that prepare our entry level Operators and Technicians (Instrumentation & Control, Chemistry, Radiation Protection, Electricians, Mechanics, Non-Destructive Examination). Relationships will include: Co-op Programs, College Curriculum Committee Participation, & some funding. Graduates of programs once they are established will be given the opportunity to receive a Nuclear Worker Certificate from the Nuclear Energy Institute in addition to whatever diploma the College grants them when the school meets the required Nuclear Curriculum Standard. Bruce Power expects Graduates will be given the opportunity to work as supplemental workers before hiring; possible all the way to Journeyperson status in some areas.

3.

Just-In-Time Training built into processes for Low Frequency Tasks Maintaining competency of large numbers of staff in low frequency tasks is problematic. The change planned is that for low frequency tasks that can be planned in advance (no immediate response tasks). Just-In-Time Training will be available on-demand and recent completion requirements built directly into the procedure for performing the task. This better ensures current knowledge than the practice of routinely scheduled refresher training.

4.

Systematic Training Program Improvements In accordance with best industry practice Bruce Power systematically identifies opportunities to improve its training programs. The two key changes planned across all key qualifications during the upcoming licence period are to move to electronic test banks and exam creation and to revisit all key qualifications job analysis. The move to electronic test banks and exam creation will improve consistency and validity of our evaluation processes as well as add efficiency to our processes. Revisiting all key qualifications job analysis will help ensure all programs meet our constantly improving quality gates and that qualifications have kept pace with changing trainee demographics.

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Facility & Instructional Aid Refurbishment & Expansion Bruce Power is currently engaged in a process to refurbish and expand the existing training facilities and instructional aids to support a forty year site plan.

Challenges The challenges to Bruce Power associated with Personnel Training are all based on demographics; not programmatic. Meaning, Bruce Power expects the majority of the remaining staff that commissioned our Stations to retire during the next licence period. Therefore, our challenges are all associated with the volume issues associated with the loss of these knowledgeable and experienced staff. In each case risks are identified, tracked and managed with appropriate plans and all plans are fully funded and achievable. Requests None 3.2.3

Personnel Certification Relevance and Management Personnel Certification is managed by Bruce Power as a subset of the Worker Learning and Qualification program. This program’s purpose is to enable personnel to competently and safely operate, maintain, and improve the performance of the Stations. Bruce Power has a team of five managers with required staff assigned to the Personnel Certification Program. The Operations Training Manager has a Manager of Initial Certification Training of Authorized Nuclear Operators; a Manager of Initial Certification Training of Control Room Supervisors and Unit 0 Operators; a Manager of Refresher Training; and a Manager of Certification Test Development assigned to this program. These managers oversee 49 Certification Candidates at Bruce A and 69 Certification Candidates at Bruce B at this writing; these numbers are typical of the past five years. The training and Certification of these staff is supported by full scale simulators of Bruce A Unit 0, Unit 2 and Unit 3 and by Bruce B Unit 0 and Unit 6. The programs begin each year in the fall and take about 2.5 to 3.5 years to complete depending on which position a candidate is seeking Certification for. All candidates have at least two years experience working in the Station for which they are seeking Certification. Past Performance Bruce Power currently has 76 Certified Operations staff at Bruce A and 79 Certified Operations staff at Bruce B. During the current licence period 51 Certifications have been granted to Bruce A staff and 48 to Bruce B staff. During the current licence period all Re-Certification requests of Operations staff made by Bruce Power to the CNSC have been approved. Bruce Power has a robust process of identifying any performance gaps in staff and addressing them or not requesting Re-Certification.

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Future Plans Over the next license period our Personnel Certification area will systematically improve in the four areas outlined below. Together these improvements will further enhance our current methods to ensure staff have the required competence to perform assigned work. 1.

Control Room Shift Supervisor Refresher Training Bruce Power will provide annual refresher training targeted specifically at Control Room Shift Supervisors. This is in addition to the training they receive along with their crews.

2.

Simulator Fidelity Bruce Power will complete station simulator model upgrades to allow for the simulation of a wider range of plant conditions during training.

3.

Statistically Non-Credible Event training Bruce Power has always trained Certified staff to respond to all statistically credible events. Over the next licence period, work to identify, design and conduct training in events that may not be statistically credible will take place. Fukushima has taught us to better prepare for statistically non-credible events.

4.

Facility & Instructional Aid Refurbishment & Expansion Bruce Power is currently engaged in a process to refurbish and expand the existing training facilities and instructional aids to support a 40 year site plan.

Challenges As is the case with other training, Personnel Certification has challenges based on demographics. Bruce Power expects the majority of the remaining Certified staff that commissioned our Stations or Restarted Bruce A to retire during the next license period. Therefore, there are challenges associated with the volume issues that arise from the loss of these knowledgeable and experienced staff. In each case risks are identified, tracked and managed with appropriate plans and all plans are fully funded and achievable. Additionally the current regulatory program for certified staff as described in Regulatory Document RD-204 is in our view longer than necessary and carries a substantial administrative overhead that could be improved. Bruce Power will formally request CNSC to undertake a review of this program including industry input on opportunities for improvement. Requests An in-depth review of the efficiency and effectiveness of the overall regulatory certification program and processes should be undertaken. Additionally, the regulatory framework regarding maintenance of proficiency for Certified staff is open to different interpretations and should be revised to ensure consistency of application. Bruce Power will request related changes to the Licence Conditions Handbook.

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Initial Certification Examination and Requalification Tests Relevance and Management Initial Certification Examination and Requalification Tests are managed by Bruce Power as a subset of our Worker Learning and Qualification program. This program’s purpose is to enable personnel to competently and safely operate, maintain, and improve the performance of our Stations. Bruce Power has a dedicated team of thirteen current or previously Certified staff managed by a Manager of Certification Test Development assigned to this program. This team designs, prepares, administers, grades, and processes all Certification Exams. There are four groups of examinations:    

Initial Certification Written Knowledge Exams Initial Certification Performance Exams on the Simulator Re-Certification Written Knowledge Exams Re-Certification Performance Exams on the Simulator.

Past Performance Bruce Power has conducted 926 Certification Examinations since 2009. All examination results have been accepted by the CNSC. The number of examinations by group and the pass rate for the period since 2009 is shown below. 

Initial Certification Written Knowledge Exams: 261 examinations administered with a 97.7% Success Rate.



Initial Certification Performance Exams on the Simulator: 101 examinations administered with an 80.2% Success Rate.



When a Candidate is not successful on an Initial Certification Examination, he or she is either removed from the Certification program (and assigned alternative work) or repeats the required training and takes a new examination.



Re-Certification Written Knowledge Exams: 135 examinations administered with a 95.6% Success Rate.



Re-Certification Performance Exams on the Simulator: 429 examinations administered with a 95.6% Success Rate.

When a Candidate is not successful on a Re-Certification Examination he or she is removed from role until they have completed a formal remediation training program and passes a new examination.

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Future Plans Over the next licence period our Initial Certification Examination and Requalification Tests area will systematically improve in the three areas discussed below. These improvements will further enhance the current methods to ensure staff have the required competence to perform assigned work. 1.

Testing Methodology Bruce Power will move from a short answer/essay examination methodology for certain written examinations to a rigorous multiple choice examination methodology. This change will allow for a more valid examination process as four times as many items will be sampled and any subjectivity will be removed from the grading process. It also creates heightened engagement of candidates during exam reviews, which leads to improved learning and retention.

2.

Test Facilities Bruce Power will complete a refurbishment of the training facility to create an improved testing environment as part of our 40 year site plan.

3.

Testing Scope Bruce Power will expand the scope of the testing of Certification Candidates to include knowledge and skills associated with response to low probability events. This is part of the lessons learned from Fukushima. Bruce Power is working to better prepare for the statistically non-credible event.

Challenges An important challenge to Bruce Power associated with Initial Certification Examination and Requalification Tests is improving simulation modeling to allow more station and reactor conditions to be simulated during training and testing scenarios. Bruce Power has committed substantial resources to become the first in Canada to model upgrades and will complete this work during the next licence period. Requests A transition plan to a single plant supervisor Certification to replace the current separate certifications of Control Room Supervisor and Shift Manager is being prepared in consultation with OPG and CNSC staff. Bruce Power will request that the resulting changes be included within the Licence Conditions Handbook.

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Work Organization and Job Design Relevance and Management In 2004, several work programs across the Bruce Power site were analyzed to identify the number of tasks, time to complete tasks, and specific skills required. This complemented the work already compiled by Bruce Power’s training organization in conjunction with line organizations, which identified specific qualifications required to perform certain tasks, as well as the capability levels of employees assigned to these duty areas. This provided Bruce Power with an analysis of how many employees were required to manage current programs. Additional analysis has been completed since that time, with the assistance of external consultants that give Bruce Power a comprehensive view of the potential improvements that can be implemented to optimize its workforce. This information was used to develop a workforce planning process at Bruce Power that is used in conjunction with business planning to ensure optimal staffing levels are achieved. The workforce planning process, which is reviewed annually as part of the business planning cycle, leverages this information in a talent segmentation exercise, and identifies the specific criticality levels of all jobs across the company, as well as the normal complement (e.g. requirements) for those positions. This information is then applied as business assumptions for future staffing level planning activities. Past Performance Several business assumptions are also applied against actual headcount and job level targets to mitigate risks to critical positions. An attrition model forecasts future retirements and staff movements across the site, based on historical retirement and staff movement trends, retirement surveys, available skills within and outside the organization, and risk assessment/environmental scan of internal and external factors. In addition, the lead time (e.g., recruitment and training) has been identified for all critical positions (including certified staff) and serves as a basis for ‘pre-hiring’ before an incumbent actually leaves his/her position. This ensures that mission-critical knowledge can be captured and transferred to a new hire, and that Bruce Power maintains an adequate level of employees in positions required to safely manage the NPP.

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4200 4100 4000 3900 3800 3700 3600 3500 3400 2008

2009

2010

2011

2012

2013*

Figure 6 Total Regular Staff 2008-2013 Bruce Power’s workforce planning process allows for continuous adjustments to the workforce plan, as it is considered a living document that must meet business requirements. Senior managers also review the status of Bruce Power’s planned staffing efforts and other critical reports semi-monthly. This experience, knowledge and continual review are now applied to execute a gap analysis between the current staffing levels and the optimal future state. During yearly business planning sessions, executives and senior managers reconcile current work program requirements and Bruce Power’s long-term workforce model, to develop the appropriate staffing levels across site for each year of the planning horizon. Consequently, Bruce Power has pipelines and plans in place to ensure that current programs are managed, while implementing improvement strategies to reach Bruce Power’s future workforce model and staffing levels.

350 300 250 200 150 100 50 0 2008

2009

2010

2011

2012

Figure 7 Past Terminations and Retirements by Major Job Category 2008-2012

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250 200 150 100 50 0 2013

2014

2015

2016

2017

Figure 8 Projected Terminations and Retirements by Major Job Category 2013-2017 On Average Bruce Power has 1% Non-Retirement Attrition Annually.

3% 14%

17%

66%

Voluntary

With/Without Cause

Deceased

Reduction of Staff

Figure 9 Categories of Non-Retirement Attrition (Total Since 2001)

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Year

Beginning of Year Actual

New Hires

Terminations

Retirements

End of Year Total Headcount

2009

3664

384

43

206

3799

2010

3799

344

45

137

3961

2011

3961

338

46

138

4115

2012

4115

161

55

152

4069

2013*

4069

201

36

128

4106

* As of Aug 15, 2013 Figure 10 End of Year Headcount 2009 to 2013 Recruiting Techniques Step 1: Posting: The recruiter meets with the Hiring Manager and/or selection team to review the job requirements as per the approved job document, to create the job posting, determine sourcing techniques and discuss any applicable collective agreement language. If the position will be filled by an internal applicant, the opportunity will be posted on the company intranet for internal applicants to apply. If there are no qualified internal candidates or it is determined for this particular position based on the skill set required that an external search is required, the opportunity will be posted on Bruce Power’s external website as well as other websites. Examples of other posting avenues include: social media sites such as Facebook, Twitter, LinkedIn, Workopolis, professional designation websites and alumni job boards. Step 2: Screening The recruiter screens the applicants based on the education, experience and certification as outlined in the approved job document. Once the recruiter screens and shortlists based on these requirements they meet with the Hiring Manager to confirm the shortlist. Potential candidates who have been short listed go through a pre-screen interview to confirm the skills and knowledge they have outlined in their application. The pre-screen interview consists of both relevant technical and competency interview questions. Depending on the vacancy, the applicants successful at this stage of the selection process will go through assessments in order to confirm the skills and knowledge required for the job. Assessments may include the following: aptitude assessment, technical writing assessment, administrative assessment, math and science assessment, and leadership assessments.

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Step 3: Interview Candidates who are successful through the screening stage of the selection process move forward to a panel interview. Prior to interview, the Human Resources representative and the Hiring Manager have discussed the essential competencies for the role and have agreed upon the questions for the interview. The panel interview consists of the Hiring Manager, a Human Resources representative and other subject matter experts as required. The panel interview includes both technical and behavioural based questions to assess both technical skills and competencies required for the role. Candidates are assessed using BARS (Behaviourally Anchored Rating Scale) for each competency. Step 4: Selection The most suitable candidate is selected based on the data collected and any corresponding collective agreements are taken into consideration. At this time, reference checks, education and employment verification and security clearances are processed. Once these checks are verified and deemed acceptable the candidate is recommended for hire. Step 5: Recommendation/Offer The recommendation to hire is submitted, it includes information on the individuals education and experience and their success through the selection process. The recommendation is submitted for determination of appropriate compensation for the role. The recommendation is then approved by the Hiring Manager and the line VP. Once the VP has approved the recommendation, Human Resources create the offer of employment and contact the successful candidate to notify the individual of their offer and other corresponding details. Established Talent Pipelines

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Operations Job Titles

Staff Level targets 2013

1-Jan-13 Actual

15-Aug-13 Actual

Retirements (Jan-Aug)

ANOIT - Nuclear Operator

77

51

46

0

Authorized Nuclear Operator

87

92

85

6

1

10

Certified Unit “0” Control Room Operator

36

41

40

2

1

3

Certified Unit “0” Control Room - OIT

32

21

16

Fuel Handling Control Room Operator (inc OITs)

70

67

73

Supervising Nuclear Operator

107

111

101

7

4

Nuclear Operator

296

293

354

5

1

Nuclear Operator in Training - NOIT

80

124

100

Shift Manager

12

9

12

Control Room Shift Manager

23

24

23

Shift Supervisor in Training

51

47

48

871

880

898

Grand Total

Confirmed Retirements (Sept-Dec)

Pull Throughs (Jan-Aug)

2014-2017 Proj Retirements

2013 New Hires

17

17

5 1

5

11

5

11

8 3

7 69

9 11 20

8

45

33

113

As of Aug. 15, 2013 * pull throughs from other classifications

Figure 11 2013 Operations Staffing

2010 Plan

2011 Plan

2012 Plan

2013 Plan

Pipeline Position Increase

Operations

393

447

442

448

55

Maintenance

343

370

369

400

57

Bruce A Total

736

817

811

848

112

Operations

392

460

491

498

0106

Maintenance

366

370

362

400

34

Bruce B Total

758

830

853

898

140

390

397

421

31

4,261

4,228

4,258

283

Staffing Bruce A

Bruce B

Engineering Year End Workforce Plan

4,007

Figure 12 Change in Workforce Plans Resulting from Pipeline Development

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Future Plans There are several programs which directly support retention efforts. Examples include the Succession Planning Process, the Management Incentive Plan (MIP) and the Executive Long Term Incentive Plan (LTIP). The Succession Planning process is designed to pro-actively identify high potential employees within the organization and develop strategies for ensuring appropriate career progression for these individuals and replacement for key positions. There is also a list of mission critical roles reviewed annually. Challenges If an area of concern is identified as it relates to retention, Bruce Power works cooperatively to perform assessments and prepares and implements recommendations with approval from the necessary parties. This may include, but is not limited to: salary design, job evaluation assessment, incentive plan design review, project or retention bonus consideration. Requests None 3.2.6

Fitness for Duty Relevance and Management Fitness for Duty, particularly in terms of the element of fatigue is a very important part of the work that the Human Resources Wellness and Disability Management Section conducts on behalf of Bruce Power. It is important in relation to CNSC certified staff positions but is equally important in other areas. While nuclear safety may be less of an issue outside of the station accidents are possible any where and therefore fitness for duty is always a concern. Safety is the Number One Value of Bruce Power. The Wellness role in ensuring our employees are fit and ready to work safely is taken extremely seriously and is managed under Bruce Power’s Fitness for Duty procedure which is also linked to the Limits to Hours of Work procedure. Our Health Surveillance guidelines help us ensure that employees who may require restrictions from their normal duties and therefore may not be able to do certain tasks are appropriately documented and the accommodations or restrictions required are communicated to the manager to ensure that we do not ask an employee to do work that they medically should not be doing. The essence of this process is to ensure that employees are fit for duty and able to work safely and within their limits. The Manager has the primary role in assessing whether the employee is fit for duty during the course of the workday, and particularly when we face those times when an employee might be required to work past their normal workday. When this occurs, the manager is required to complete and document an fitness for duty assessment for each employee to ascertain if there are any signs of fatigue that would indicate that the employee is fatigued and should either be given a rest period prior to continuation of work.

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Past Performance Overall, the indication is that the process is working in terms of ensuring that certified staff required to remain at work are fit for duty. There have been no instances over the licence period where fatigue has played a role in an incident which demonstrates that managers are engaged in ensuring their employees are fit for duty and not fatigued when extended hours of work are required. As per Bruce Power procedure, reporting to work fit for duty is everyone's responsibility. From time-to-time, personal health and life events may impact on the fitness for duty of workers either prior to work, or while on the job. The worker may or may not be aware of these impacts. Early identification and appropriate intervention can speed resolution and recovery. Bruce Power is committed to assisting workers achieve optimum functioning by providing support and resources. Bruce Power continues to maintain sufficient numbers of qualified staff to meet the minimum complement requirements however, issues such as short notice absences or sick calls present challenges to the minimum complement. Bruce Powers’ response to an unplanned challenge to the minimum complement when a replacement cannot be located in a timely manner is to hold over to the next shift appropriately qualified staff. This may result in an hours of work non-compliance but from a safety perspective, is clearly the right decision. Bruce Power recognizes that anyone working past 13 hours is potentially fatigued, both physically and mentally. As such, Bruce Power has implemented several programs to ensure staff remains fit for duty at all times. Bruce Power engaged Deloitte Canada LLP (“Deloitte”) to review existing documentation and data related to Bruce Power’s exposure to fatigue risk based on shift work schedules and key activities performed by its staff in operator and security guard roles. The Deloitte Fatigue Study is intended to form the basis of a broader fatigue risk assessment at a later date. The immediate objective was to provide Bruce Power with a basis for commenting on the proposed CNSC regulatory document (REGDOC 2.2.1) and to inform further assessment of Bruce Power’s overall fatigue risk exposure and fatigue management programs. Deloitte conducted on-site interviews and reviewed and analyzed documentation and data. Fatigue Science was engaged, as a sub-contractor, to model the fatigue risk associated with shift work schedules and the extent to which fatigue risk contributed to specific human performance events. Fatigue Science completed the data modeling using their proprietary Fatigue Avoidance Scheduling Tool (FAST) – a data-analytics based software application. FAST software is a desktop version of the Sleep, Activity, Fatigue and Task Effectiveness Model (SAFTE). SAFTE is a bio-mathematical model that predicts levels of fatigue, and the associated levels of performance effectiveness, under various real-world conditions.

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The FAST software tool was used to assess the regular shift schedules and scenarios where staff was held over for an additional shift (24 hour shift) to maintain minimum shift complement. The results showed that fatigue is not a safety factor for the regular shift schedules, although as expected there was some impact on performance due to fatigue on night shifts. The assessment of the case where a staff member was held for an additional shift after a day shift, the FAST software showed that the fatigue factor was essentially the same as if the person was working a regular night shift. In the case where a person was held over for a day shift after a night shift, the FAST software showed that there was no fatigue factor. However, the FAST software did indicate an impact on fatigue during the next set of night shifts. Bruce Power is currently reviewing the Deliotte report to take the findings into account in its fatigue management processes. Bruce Power released a new procedure in April 2013 outlining the steps to be taken to manage fatigue when a worker is held over for more than 13 hours. The procedure provides detailed rest period requirements for individual workers and crews held over for varying durations including completion of an assessment for fitness for duty. Future Plans Bruce Power plans to continue to improve its management of fitness for duty. Over the remaining duration of the current licence period and the next licence period Bruce Power will do the following: 

Implement recommendations from the Deliotte Fatigue Study.



Improve emergency sleep areas.



Revise the fitness for duty checklist to better account for fatigue monitoring.



Investigate the development of a predictive tool for identifying worker fatigue risks when selecting workers for overtime or extra shifts that accounts for worker fatigue.



Revise the event investigation/analysis process to better capture fatigue related issues.

Challenges Bruce Power, like any other employer, cannot control employee’s actions during off hours to ensure that staff show up for work well rested. This emphasizes the importance of fitness for duty observations by supervisors. Requests None 3.3

SCA 03 - Operating Performance The operating performance SCA includes an overall review of the conduct of the licensed activities and the activities that enable effective performance. Specific areas assessed by CNSC staff comprise:  

Conduct of Licensed Activity (includes: Operating Experience [OPEX]) Reporting and Trending

BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B     3.3.1

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Outage Management Performance Safe Operating Envelope Severe Accident Management and Recovery Accident Management and Recovery

Conduct of Licensed Activities Operating Policies and Principles Bruce Power maintains Operating Policies and Principles (OP&Ps) for Bruce A and Bruce B. OP&Ps define the operating requirements and parameters, consistent with the stations safety analyses and other licensing documentation, within which each station will be operated, maintained and modified, in order to ensure nuclear safety is maintained. They also specify the authorities of station staff, in particular the Senior Operation Authority, the Shift Manager and the Chief Engineer, to make decisions within defined boundaries and serve to identify and differentiate between actions where discretion may be applied and where jurisdictional authorization is required. The Operating Policies and Principles (OP&Ps) achieve these objectives by specifying a combination of principle statement, policies, and operating limits and conditions which reflect the Safe Operating Envelope (SOE). The principles provide context for the more detailed requirements; the policies provide direction for establishing maintaining, and restoring safe operation; and the limits and conditions define the specific terms which must be met in order to determine if a station is in an accepted safe state. The OP&Ps further establish the boundaries which must be reflected in the operating documentation used by station staff on a routine basis and by the Shift Management staff when exercising their authority to deviate from that documentation within the SOE. The OP&Ps clearly outline operating boundaries within which the stations may be safely operated. Within these boundaries, detailed operating procedures are written for clearly defined operating requirements for normal, abnormal and emergency conditions. As operating experience accumulates, these detailed procedures are occasionally revised to improve the quality, simplicity, and efficiency of station operation. Revision of the detailed operating procedures may be carried out quickly within the boundaries established in the OP&Ps. Unexpected situations may also be handled, again within the defined boundaries, so as to minimize adverse effects. Conduct of Operations The Conduct of Plant Operations program establishes functional requirements, constituent elements and key responsibilities associated with the conduct of operations at Bruce A and Bruce B. The overall objective of the program is to safely and reliably operate the station systems within the design basis for which the stations are licensed. Operations conducted in accordance with the standards and expectations defined in this program provide strong support for the four pillars of nuclear safety:    

Reactor Conventional Radiation protection Environmental

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The Conduct of Operations program is implemented by both governing procedures and operating documents/procedures. Operation of the plants is performed by operations staff using the following operating documents. These documents provide a defence in depth approach, all to ensure safe operations. 

Abnormal Incident Manual (AIM): Operations response/direction to address unit upsets within design basis. AIMs are developed to address or prevent any OP&P limits from being exceeded.



Emergency Mitigating Equipment (EME): Procedures developed to provide operations staff direction for events beyond design basis.



Alarm Response Manual (ARM): This manual provides operational direction to the operations staff when the main control room receives an alarm.



Operating Manual (OM): Operating manuals are designed to provide operations staff with “normal operations” direction. The operating manuals are designed to provide operations staff with specific direction to keep the operating unit within normal parameters.



Operating Memo (OPM): These are “temporary” operating procedures used by the operations staff to address a specific unit condition that is not addressed by the operating manual such as temporary equipment configurations. These are not used for long term issues, rather to address or provide mitigating strategies for equipment.



Safety System Tests (SSTs): SSTs are designed to provide operations staff with operational direction to test various systems and ensure no impairments to operations exist.

Nuclear Safety Review Board (NSRB) The Bruce Power Board of Directors has established a Nuclear Safety Review Board (NSRB), consisting of up to five Board-appointed voting members and a Chair. The NSRB has the responsibility for considering and advising the Board of Directors the extent to which Bruce Power affairs are being conducted in a manner that promotes reactor, radiological, industrial and environmental safety and for continuing to emphasize the long-term effort required to improve safety culture permanently, including changing management behaviours and demonstrating leadership. The Chair is a member of the Board of Directors and at least three appointed members of the NSRB are required to be an expert in matters of nuclear operations and safety. Each of the members is also required to be experienced in matters of operational safety including: industrial safety and/or nuclear safety and/or environmental compliance.

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The NSRB may have up to 10 ex-officio members being defined as non-voting members. The President and CEO, Chief Nuclear Officer and Executive Vice President - Nuclear Operations, Executive Vice President - Human Resources, Executive Vice president - Corporate Services, Vice President - Nuclear Oversight and Regulatory Affairs, the Chair of the BPI Board and one representative nominated by each of Bruce Power’s Shareholders (the “Shareholder Nominee(s)”) shall be ex-officio members. In addition, each Shareholder has the right to nominate an alternate representative who has the right to attend all meetings of the NSRB. A majority of the voting members of the NSRB, at least one of which must be a director, shall constitute a quorum. No business shall be transacted by the NSRB except at a meeting of its members at which a quorum of the NSRB is present. The NSRB may invite any officer or employee of Bruce Power, external experts and others to attend meetings for certain agenda items and/or to assist in the discussion and consideration of the business and its affairs. The NSRB is responsible for: 1.

2.

Advising the Board of Directors on: a)

The extent to which plant operations are within Operating License and Safety Analysis.

b)

Significant reactor, radiological, industrial and environmental safety issues.

c)

The effectiveness of reactor, radiological, industrial and environmental safety policies.

d)

The effectiveness of the management oversight process given to significant events, event trends and use of operating experience (“OPEX”).

e)

The effectiveness of policies, systems, and monitoring processes in place to manage reactor, radiological, industrial and environmental safety.

f)

The effectiveness of the policies, systems, and monitoring processes in place to manage the health and safety of staff, contractors, visitors and the general public.

g)

The effectiveness of policies and systems to ensure compliance with reactor, radiological, environmental and worker health and safety policies and law, with specific direction to bring the incidents of material non-compliance with the policies and the laws to the attention of the Board in a timely fashion.

h)

The terms of reference of the NSRB and their incorporation in the Management System Manual.

Monitoring and Reporting to the Board of Director on: a)

Reactor, radiological, industrial and environmental safety performance and culture.

b)

The benchmarking of policies, systems, and monitoring processes against industry best practices.

c)

Significant events, event trends and use of OPEX.

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Monitoring: a)

Management processes for identifying and correcting performance issues.

b)

Safety culture from a holistic approach, including specific safety culture performance measures and targets.

c)

Regular reports from management on compliance with applicable laws and regulations in respect of reactor, radiological, industrial and environmental safety, licences, codes of practice, and processes in place for monitoring compliance.

d)

Regular reports from management on reactor, radiological, industrial and environmental safety performance including the results of investigations into significant events and determining the appropriate root cause.

e)

The NSRB’s performance (self-assessment).

f)

Health and safety policy, by reviewing annually or upon a material change being made.

To fulfill its responsibilities, the NSRB holds regular meetings. 1.

Written reports are provided by management to the NSRB for review in advance of each meeting.

2.

Each meeting consists of:

3.

a)

Plant tours as designated by the NSRB after review of the written reports.

b)

Review of significant events as designated by the NSRB.

c)

Review of management reports related to reactor, radiological, industrial and environmental safety, and regulatory and nuclear oversight.

d)

Review of regulatory inspection reports and internal audit reports related to reactor, radiological, industrial and environmental safety.

e)

Investigations or reviews if designated by the NSRB.

The NSRB reviews site nuclear safety-related activities, programs, and events, including maintenance, engineering, operations, regulatory and nuclear oversight, by: a) b) c) d) e)

4.

Reviewing documents and reports. Receiving briefings by staff and management. Reviewing industry reports. Plant tours, observations, investigations, interviews, and discussions. Other appropriate means.

The NSRB submits the minutes of each meeting to the Board of Directors as part of the Committee’s report to the Board.

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Operating Experience (OPEX) Relevance and Management Bruce Power's Operating Experience (OPEX) program is intended to satisfy Operating Experience aspects of a number of regulatory and licence requirements as well as other standards adopted by Bruce Power. These include CSA N286-05, Management System Requirements For Nuclear Power Plants, CAN/CSA-ISO 14000, Environmental Management and OSHAS 18000, Occupational Health and Safety Management Systems Specification A fundamental reason for an effective OPEX program is that serious accidents are almost always preceded by less serious precursor events. The OPEX program gathers and disseminates operational experience at all stations to help prevent accidents. It requires Bruce Power to identify safety significant internal events as well as applicable lessons learned from events shared by other nuclear-electric licensees, to analyze them, and to develop corrective actions to prevent recurrence and/or improve Bruce Power processes, equipment, or training. The CANDU Owner’s Group (COG) is the main external interface used to input Bruce Power events into, and also to obtain external OPEX information. Event information from facilities all over the world are contained in the COG OPEX database. This external information is screened by Bruce Power staff for significance and relevance to their operations and acted upon as required. All the internal and external OPEX information including related evaluations are available to Bruce Power staff to be used when planning and performing their tasks. Staff at all levels have full access to internal and external OPEX information at any time. Two Senior Advisors - OPEX, hired in 2008, were assigned to Bruce A and Bruce B Plant Integration Departments. The Advisors physical relocation to each station, reporting to station managers allows for more effective station leadership oversight of all OPEX processes. Three Senior Advisors - OPEX now exist at Bruce Power; one at each station, and one in the corporate office assigned to OPEX programs. However, the three advisors continue to work together as peers where applicable, including; consultation, teamwork, independent verification and peer checking, and brainstorming for continual improvement. Past Performance Improvements to the OPEX processes have been implanted, based on benchmarking the industry, through attendance at conferences and workshops and while performing self assessments in each year of the current licensing period. Improvements to the following were implemented: 

Screening and evaluating of external OPEX.



Increased process rigour, and management oversight requirements of WANO Significant Operating Experience Reports (SOERs).



Increased rigour and management oversight requirements of ongoing effectiveness of responses to WANO SOERs.



Increased rigour and management oversight of evaluating and applying lessons learned from WANO Significant Event Reports (SERs).

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Improvements to OPEX resources available to all staff including.



Addition of an “Industry Case Studies” resource on the Bruce Power OPEX web page.



Addition of a “Counterfeit Fraudulent Suspect Item” (CFSI) resource page to the Bruce Power OPEX web pages.



Performance Indicators for station leadership to use in providing oversight of OPEX program requirements and also to use to reinforce their expectations for OPEX program requirements (see example of effective use of these indicators in the included OPEX Action Rate chart below [Figure 13]).



Creation of an "On This Day At The Bruce Site" calendar-based OPEX database containing OPEX items starting from the early operational days of Bruce A (~1974), and updated annually with new event lessons, published on the Bruce Power OPEX web pages. Records from each day are included in Management Leadership Meeting agendas as well as being published on all Visual Management Boards on site for review during start of day briefings.

12.0% Site Average

10.0% 8.0% 6.0% 4.0%

0.0%

Jul‐2012 Aug‐2012 Sep‐2012 Oct‐2012 Nov‐2012 Dec‐2012 Jan‐2013 Feb‐2013 Mar‐2013 Apr‐2013 May‐2013 Jun‐2013 Jul‐2013 Aug‐2013

2.0%

Figure 13 Percentage of Actions Assigned from External OPEX Future Plans Further improvement in OPEX Program Performance is expected to take place through the use of improved OPEX performance indicators, an OPEX "Dashboard", which includes performance of each OPEX sub-process, contributing to an overall OPEX Index. This will enable leadership to more effectively provide oversight of all OPEX processes and reinforce expectations regarding these processes.

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Challenges None Requests None Chemistry Relevance and Management The objective of the Bruce Power Chemistry Management Program is to establish the optimum conditions for system chemistry and to mitigate conditions that could lead to an adverse effect on nuclear safety, radiological safety, personnel safety, environmental safety or plant condition during all unit and system operating states. The requirements of this program are designed to meet the requirements of CSA N286-05 for Chemistry Control. The program consists of governing documents in the areas of preparation and revision of chemistry specifications, control of system chemistry, analytical capability and chemical risk management. The Chemistry program governance is aligned with regulatory and license requirements as well as industry guidelines and best practices and undergoes regular review and improvement based on inputs from industry OPEX and research and development programs. Proper chemistry control will maximize equipment life, reliability and long term economic performance whilst contributing to safe and environmentally friendly operation. To promote proper chemistry control, Bruce Power prepares and maintains Chemistry Specification (CYS) documents. Compliance to these specifications and prescribed actions is mandatory. Bruce Power has adopted the Action Level (AL) concept from EPRl chemistry guideline documentation. ALs are values of control parameters at which system reliability may be jeopardized or increased radiation field build-up may occur and action must be taken. Chemistry Control processes are followed during all plant states to minimize corrosion and performance degradation. Proper chemistry control will maximize equipment life, reliability, and long-term economic performance. Chemistry Control processes include the following: chemistry control documentation, the outage chemistry program, chemical risk management (i.e. control of chemicals), product procurement specification (i.e. control of process chemicals), monitoring of system chemistry, data evaluation and trending including performance monitoring, and program effectiveness monitoring. Bruce Power ensures analytical capability using processes designed which establish the quality elements necessary to ensure test methods and associated instrumentation are properly established, maintained and controlled as well as to evaluate the performance of the analytical procedures used in the laboratory, and to verify the performance of individual chemical technicians.

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The Chemical Risk Management procedure describe Bruce Power’s processes for managing the use of chemical products on the site to control potential hazards associated with their chemical composition and intended use. The processes include the assessment of Environment, Conventional and Fire Safety risks as well as an evaluation of chemical or corrosion risks to plant systems and equipment. The outcome of this process is the application of Chemical Risk labels to products to denote the level of risk associated with their use and to prompt a review by workers of the risk assessment information along with the product Material Safety Data Sheet (MSDS). Past Performance Overall, chemistry performance has been strong with gradual improvements made in a number of areas including Primary Heat Transport System chemistry control and Steam Generator Sulphates. Figures 14 and 15 below provide a summary of Chemistry Control performance data for Bruce A and B for the period Q1/2011 to Q2/2013. A discussion of the performance data is provided with an emphasis on common as well as some specific challenges at each plant. Data for the CNSC Chemistry Index and Chemistry Compliance Index for Bruce A and B for the period Q1/2011 to Q2/2013 are provided in the figures below. The Chemistry Index (CI) is a summary indicator for each plant that reflects the percentage of time in specification in all applicable units/systems for a number of control parameters in critical systems including the Primary Heat Transport System, the Steam Generators, the Annulus Gas System and the Condensate and Feedwater systems. 102 100 98 96

Chemistry Index

94 Chemistry Compliance Index

92 90 88 2011 2011 2011 2011 2012 2012 2012 2012 2013 2013 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2

Figure 14 Bruce A CNSC Quarterly Chemistry Performance

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100 98 96 94 92

Chemistry Index

90 Chemistry Compliance Index

88 86 84 82 2011 2011 2011 2011 2012 2012 2012 2012 2013 2013 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2

Figure 15 Bruce B CNSC Quarterly Chemistry Performance At Bruce A, CI performance for the period has been maintained at greater than 95% on average. Recurrent contributors to lower performance in all units include Steam Generator (SG) sulphates, Condensate dissolved oxygen and Feedwater iron (Fe) transport. Progress has been made and efforts are continuing to improve the quality of demineralized water from the Bruce A Water Treatment Plant (WTP) to minimize SG sulphates. Completed improvement activities to reduce boiler sulphates include implementation of improved Ion Exchange (IX) resin use/replacement strategies, and trial and use of macroporous anion resin in the mixed bed polishing vessels. An additional WTP focus area is the trial of new pretreatment coagulants to improve the removal of Organically Bound Sulphates (OBS) that can otherwise pass through the WTP and lead to elevated sulphates in the steam generators. At Bruce B, CI performance has been maintained greater than 96% on average and has been challenged by many of the same factors as Bruce A. Gradual improvements in SG sulphate levels have been observed at Bruce B while using polishing trailers with the existing WTP. A step improvement in demineralized water quality and SG sulphates is anticipated following the start-up and operation of the new Bruce B Water Demineralization Plant (WDP) in 2014. The new plant will employ leading edge technology, including Ultra-Filtration (UF), two-stage Reverse Osmosis (RO), UV-oxidation, Continuous Electrodionization (CEDI) and non-regenerable polishing mixed bed IX resins to generate ultrapure water. Elevated condenser air in-leakage rates and hence elevated condensate dissolved oxygen levels generally correlate with seasonal lake temperatures and present a common challenge at both Bruce A and B. Efforts are ongoing to improve control of Condensate dissolved oxygen levels by ensuring better coordination of condenser leak search activities performed by an external contractor with plant maintenance staff planning and efforts. The goal of the improvements is to correct the deficiencies and reduce or eliminate leaks that can be readily addressed as they are identified during the leak search process.

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Performance gaps with respect to iron (Fe) Corrosion Product Transport (CPT) also present challenges at both A and B plants and are commonly related to start-up chemistry conditions following outages. Performance gaps also correlate with the number and duration of outages. A Chemistry Peer Team sub-team has been established to review industry OPEX and best practices to identify possible options to minimize Fe transport during start-ups. Improvement initiatives will be developed for both short and long term strategies and will focus on chemistry improvements during outages as well as during the start-up period. Longer term strategies will review the need for physical changes to the plant or changes to chemistry additives to reduce CPT. The Chemistry Compliance Index is an indicator that summarizes chemistry control performance with respect to safety related chemical and radiochemical parameters that are monitored to meet regulatory and license requirements. The CCI is defined as the percentage of time that the selected chemical parameters are within specification during the quarter. Performance for this index was maintained at values of > 95% and > 96 for Bruce A and B, respectively, for the period of Q1/2011 to Q2/2013. Apart from a few individual specific contributors to reduced performance, this indicator was affected most by chronically low moderator Heavy Water isotopic values at both plants. Improvements in moderator isotopic to meet the license requirements have been achieved in the Bruce B units in 2013 through a combination of feed and bleed and on-line heavy water upgrading. A similar recovery strategy is being developed at Bruce A. The Bruce B CCI was also adversely affected by a condition from Q3/2012 to Q2/2013 whereby the Dewpoint measurement in the AGS system in all units was considered to be out of specification due to the temporary unavailability of a portable dewpoint meter used for weekly verification of the on-line dewpoint meters accuracy. The portable dewpointer has since been returned to service. The WANO Chemistry Performance Indicator (CPI) is a standard industry metric that provides an indication of operational chemistry control effectiveness against industry limiting values with respect to selected impurities and corrosion products in the SGs and the feedwater system. The indicator focuses on SG sodium, chloride and sulphate impurity levels as well as on feedwater iron, copper and dissolved oxygen levels. A CPI score of 1.00 indicates that the operational levels are at or better than the WANO limiting values used in the calculation. The CPI data for Bruce A and B for the period Q1/2003 to Q3/2013 is summarized graphs below (Figures 16 and 17).

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1.6 1.4 1.2 1 0.8 WANO CPI

0.6 0.4 0.2 0 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 (Q3)

Figure 16 Bruce A WANO Quarterly Chemistry Performance Indicator

1.15 1.1 1.05 1

WANO CPI

0.95 0.9 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 (Q3)

Figure 17 Bruce B WANO Quarterly Chemistry Performance Indicator The six parameters included in the CPI are a subset of the 15 parameters included in the CNSC Chemistry Indicator such that both indicators often point to the same focus areas for reduced chemistry control performance. The largest contributors to losses in CPI (i.e. CPI > 1.00) are SG sulphates and feedwater Fe CPT. As discussed above, improvement initiatives are underway at both Bruce A and B to improve the quality of demineralized water being made up to the units in order to minimize sulphate impurities. Losses in CPI performance associated with Fe CPT during unit start-ups are typically related to both the number of and duration of outages during the quarter. As discussed above, additional initiatives are being developed by the Chemistry Peer Team in 2013 to address gaps in chemistry control with respect to feedwater Fe transport. Historically, the bulk of Fe transport occurs in the 1-2 week period following start-up from an outage. Therefore, the focus of the improvement initiatives will be on chemistry and corrosion control during outages as well as during the start-up period.

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Future Plans Chemistry improvement focus areas are reviewed and selected by the Chemistry Peer Team on an annual basis to address gaps in performance. As described above, the three primary focus areas going forward from 2013 are identified as Iron Corrosion Product Transport minimization during start-ups, Steam Generator sulphate control, and improvements to Condensate Dissolved Oxygen control. Performance targets for both stations are developed and reviewed on an annual basis and agreed to by the Chemistry Peer Team. Challenges None Requests None 3.3.2

Trending and Reporting Relevance and Management The purpose of the Corrective Action Program is to identify and eliminate or mitigate adverse conditions that have resulted in or could result in loss. Trending Analysis is a vital part of the Corrective Action Program, which involves reviewing and analyzing the data in Station Condition Records (SCRs) in order to identify adverse trends and determine corrective actions or further investigations to mitigate the adverse trends. SCR data inputs for trending can include audits, self-assessment results, observation data, planned inspections, corrective action management effectiveness oversight and benchmarking. The Trending Program is still maturing and has undergone revisions with the introduction of the station Quarterly Assessment Reports in 2012. Past Performance During the current licensing period a number of improvements have been implemented to strengthen the Corrective Action Program. 1.

In 2011, the Performance Improvement Department, which includes the Corrective Action Program, decentralized from the corporate office to provide dedicated support into the stations. This included realignment of Corrective Action Program Coordinators (CAPCOs) under the station CAP groups. The realignment allows for a more effective and consistent implementation of the Corrective Action Program within the station while still being flexible to support each station's initiatives.

2.

Overdue Corrective Actions continue to stay minimal. There have been a total of seven from January to August 2013, as compared to a total of 1277 in 2007. See Graph 1 below (Figure 18).

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3.

Bruce Power completed an upgrade of the software from PASSPORT Version 6 to Version 10 in August 2008 to consolidate corrective action program data into one common repository. A new simplified front end user interface to the SCR program was rolled out to staff across site June 2009 making it simpler to initiate and process an SCR. The interface also enables CAPCOs to easily screen Station Condition Records (SCRs) both individually and collegially as a group in their daily review meetings. All users can input additional trend codes and any required corrective actions identified as a result of an investigation or evaluation. 2010 CAP Survey results indicate that 97% of employees using the new interface found it easy to enter an SCR.

4.

In 2010, a site wide CAP survey was issued garnering over 1600 responses. 91% of respondents replied that they want to find out what happens to the SCRs they generate. In response, the SCR system was updated to send each Initiator an auto-email after their SCR had been through the Management Review Meeting and the disposition had been approved explaining the resolution category. Initiators could then follow the link on the email to monitor their SCR if further actions had been applied.

5.

Completed a "Lean" review of the Corrective Action Program which resulted in several improvements. The First Line Manager (FLM) review of all low significance level SCRs was extended to allow FLMs additional time to address and correct the adverse condition or work with the line organization responsible. Revised trending reports were developed along with the new Common Cause Analysis process to simplify and streamline the trend evaluation process. Also introduced was the "Fix" evaluation for low significant adverse conditions to allow the responsible group to come up with their own resolution to the adverse condition.

6.

Dedicated Root Cause Investigation Subject Matter Experts (Functional Area Coordinators) have been put into role at both stations to assist the investigators for each Root Cause Investigation.

7.

Bruce Power hosted the 2011 Corrective Action Program Owner's Group annual conference targeted at Managers in charge of Corrective Action Programs across the nuclear industry. Trending and Effectiveness was a key theme where it was recognized that the industry as a whole is learning and in mid-development of trending programs at the various utilities.

8.

Early in 2012 a new CAP Index with dashboard was developed to provide an overview of CAP health at the station level. The Index was identified as an industry leading measure of the performance of the Corrective Action Program. It tracks key indicators including SCR generation, adverse trend SCRs, investigation quality and timeliness, corrective action extensions and effectiveness.

9.

The Effectiveness Review process has been revised to include specific requirements for Root Cause Investigations, Apparent Cause Evaluations and Common Cause Analysis.

10.

All Corrective Action Program procedures are being reviewed for standardization and streamlining. By Q3 2013, eight have been revised and the remaining four, are in progress or planned.

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11.

Adverse condition identification rates at the stations continue to be above target demonstrating a workforce that embraces learning and takes initiative to identify and correct adverse conditions on an ongoing basis. By trending the lower level events, we are able to identify the trends before they develop into a larger issue. Adverse trend identification continues on a positive trend. See graph 2 (Figure 19).

12.

CAP training has been a focus with the revision of the SCR process computer based training course in 2011, and a new Causal Analysis Techniques course and Apparent Cause classroom training course in 2013. Developing SMART Action workshops were also rolled out to CAP staff and CAPCOs with the intention to transition it into a course for further rollout.

# of Overdue Assignments

1400 1200 1000 800 600 400 200 0 2007

2008

2009

2010

2011

Year Figure 18 Overdue SCR Assignments (2007 - 2013)

2012

2013

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70

59

60

51 43

40

32

29

30

23

20

20 10

20 13

Q

1

Q 2

Q 4 20 12

20 12

Q

Q

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3 Q 20 11

3

Q 2

Q 4

Q 2 1 20 11

Q

3 Q 20 10

Q

1

Q 4

Q 2

0

20 10

Quarter

50

Trends Identified

Figure 19 Adverse Trend Identification Future Plans 1.

Improvements and adverse conditions corrected are not always visible to the shop floor therefore; communicating CAP successes will continue to be a focus.

2.

The entire Performance Improvement suite of Training is under review and a plan is being put into place for training revision and new development to ensure compliance with Bruce Power's Systematic Approach to Training.

3.

Common Cause Process maturation and training development. The current bridging strategy is that Performance Improvement Subject Matter Experts are available to mentor new users of the process.

4.

Incorporating CAP including organizational trending into the Visual Management Boards across site to encourage conversations surrounding ownership and resolution of issues.

Challenges Until recently Bruce Power had each organizational department complete their own trending, which did not result in a product that was available for all staff to view. So in Q4 2012 a new Performance Assessment was piloted by the Performance Improvement Department at both stations to provide on a quarterly basis an integrated view of performance including CAP Health. The report is provided to senior management and provides a summary of initiatives and action plans that have been developed to either correct adverse trends or to proactively prevent declining performance. The process is still in the pilot stage and the scope and content is being adjusted as the organization matures with the process. This transition will continue over the next licence period. Requests None

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Outage Management Performance Relevance and Management Bruce Power establishes nuclear safety as a top outage priority. Shutdown safety is a key outage success factor and an outage goal. Performance indicators have been established for events resulting from; a loss of decay heat removal, challenges to shutdown safety function or result in unplanned increased risk conditions. These indicators are monitored throughout the outage with particular focus on control, cool, contain and off site power availability. Policies and procedures are in place to address conservative decision making to maintain sufficient safety margins. Senior Management: 

Participates in outage preparations and defense in depth reviews.



Provides oversight during outages on key work activities presenting increased risk.



Reviews changes to approved outage schedules to ensure the effect on nuclear safety risk is understood.

The Outage Work Management program document defines the fundamental business need and, constituent elements, functional requirements, and implementing approach. The program is designed to satisfy and exceed the intent of CSA Standards N286-05, Management System Requirements for Nuclear Power Plants as they pertain to managing outage work and Regulatory Document RD/GD-210 Maintenance Programs for Nuclear Power Plants. The purpose of the program is to identify the controls associated with planning, implementation, and control of work performed on a reactor unit when the unit is shutdown such that maintenance, inspections, and modifications are performed safely and on the basis of value to maintaining safe, reliable and lowest cost operation. This includes selecting and controlling the scope of work, planning, scheduling, coordinating work execution, and closing-out the outage, whether it be a planned or an unplanned outage. Past Performance In 2009 the management team at Bruce Power recognized that in order to make improvements in outage performance a detailed assessment of past and present performance must be conducted in order to properly focus resources and finances on the improvements that would provide the greatest return on investment. To this end, a team from WSC International were contracted to perform an assessment. The team was made up of experienced ex- Senior Vice Presidents and Senior Managers from the nuclear industry. Over 200 Bruce Power staff were involved on a number of teams to identify areas from improvement. This produced over 500 ideas where employees believed that if implemented would improve Bruce Powers performance in outage execution. A summary of the assessment and subsequent improvement plan follows.

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Outage Durations Routine planned outages at Bruce Power (Units 3 thru 8) have exceeded their scheduled durations by approximately 20% on average since 2003 (Refer to Figure 20). Prior to 2003 the average outage duration was exceeded by approximately 15%. This indicates that performance continues to degrade over time. Each day of unit downtime results in lost generation revenues and incremental cost for overtime and supplemental staff during unit outages. This trend continued through 2012. With the implementation of many outage improvements as outlined in the Master Outage Improvement Implementation Plan, which is further described in future plans below, Bruce Power is working toward reversing this trend. Performance indicators in 2013 for the three planned outages at Bruce B had an aggregate result better than plan. This is seen as a very positive result of management’s efforts to improve performance. Scope Stability Bruce Power’s internal target to set outage scope 12 months prior to the start of an outage. Outage scope has not met this target and scope stability continues to fluctuate from initial scope identification, through scope freeze, and outage execution. Station personnel and management have identified scope stability as one of the top issues that impacts outage planning and execution performance, and is a significant threat to achieving the outage improvement goals. With greater focus and with the implementation of a number of outage improvements, scope stability has increased to an aggregate average of 81% in 2013. Reliability Forced outages have been more frequent than industry good performers. This may be due to not identifying and completing the most effective work scope during outages to ensure high levels of equipment reliability. Ensuring that the right work is scoped into the outage and then effectively completed will be a significant contributor to reducing Forced Loss Rate and improving overall generation planning.

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Station Subindicator values are average of generating units values and unit zero value where applicable.

10.00 9.00

7.00 6.00 5.00 4.00

BA BB

3.00 2.00 1.00 0.00

Jan-10 Feb-10 Mar-10 Apr-10 May-10 Jun-10 Jul-10 Aug-10 Sep-10 Oct-10 Nov-10 Dec-10 Jan-11 Feb-11 Mar-11 Apr-11 May-11 Jun-11 Jul-11 Aug-11 Sep-11 Oct-11 Nov-11 Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 Jan-13 Feb-13 Mar-13 Apr-13 May-13 Jun-13 Jul-13 Aug-13

Forced Loss Rate

8.00

Note: Unit 3 removed from Bruce A station ERI subindicator calculations Dec 2011 to May 2012 Inclusive (A1133 outage). Unit 4 removed from Bruce A Station ERI subindicator calculations Sep 2012 (A1241 outage).

Figure 20 Forced Loss Rate Note: The spike in Bruce A data in 2012 reflects Bruce A Units 1 and 2 coming on line. As a result of many improvements and with a focus on scoping the correct work on an outage, equipment reliability improvements have had a positive effect on FLR, which has been improving. Radiation Exposure Radiological exposure at Bruce Station has typically been near or slightly above the fourth quartile of performance relative to other Pressurized Heavy Water Reactors (PHWR’s) world-wide; however as part of the Radiation Protection Improvement Initiative (RPIP) many opportunities were identified to improve performance during outages. Refer to Section 3.7 below for information related to radiation protection performance. Supply Chain Costs Changes in outage scope in the later stages of planning and into the execution phase have resulted in increased costs, delays in outage execution and additional expenses to return and stock unused parts resulting from canceled work.

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Supply Chain identified opportunities for improvement and initiated two projects to improve efficiencies through the Outage Improvement Initiative. An “E-Procurement” project was initiated and is currently being implemented to utilize a technology solution for enhanced order management, vendor communications, and vendor performance management to gain efficiencies. New metrics have been implemented to monitor performance and continuously improve efficiencies. Future Plans Based on the result of the assessment described above, Bruce Power developed a “white paper” that identified focus areas for improvement that will be key drivers to achieve consistent and predictable performance of outages at Bruce A and Bruce B; thereby reducing outage costs and radiation exposure, while maximizing the revenue stream from safe, reliable generation. Four key focus areas for outage improvement were identified as follows: 1. 2. 3. 4.

Organizational Engagement Outage Scope Resources Critical Outage Execution

To identify, plan and implement improvements associated with these four key focus areas, a three phased approach is being undertaken: 

Phase I: Engage “Lean Teams” to identify Improvement opportunities and potential benefits.



Phase II: Develop outage improvement project and initiative Implementation & Change Management Plans.



Phase III: Implement and monitor effectiveness of Implementation & Change Management.

The “Outage Improvement Master Implementation & Change Management Plan” and 13 individual project and initiative implementation and change management plans provide the guidance for the implementation (phase III) of improvements. The Outage Improvement Projects are:            

Boiler Work Execution Valve Work Execution Delivery Machines (BRIMS) Feeders The Outage Improvement Initiatives are: Generation Planning Process Outage Scope Identification Outage Scope Review Process/Panel Milestone Adherence/Metrics Supply Chain Vault Access Outage Work Execution Processes

BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B  

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Resources & Organizational Structure Leadership Skills/Behaviours

Fully engaged line organizations are implementing changes according to the change management plans and early indications are favourable for outage durations, dropping from an average of 20% over to just under the 2013 target of 8% for planned outages. A number of performance indicators are being used to monitor future performance to ensure continued outage performance improvements. Challenges The challenge to implementing the improvements needed to bring the outage program to meet or exceed good industry practices is the number of outages that are not planned. This challenges resources to plan for future outages and to identify and implement improvements. The outage Integration Solution (IOS) which is in the process of being developed and implemented as part of a program improvement will significantly reduce the manual effort required to develop and report on metrics. It will also have a module that will better define outage scope and in return provide better equipment reliability. Maintenance continues to focus on plant equipment material conditions and deficiencies aimed at increasing safety, reliability and the longevity of the plant. Bruce Power continues to strive to reduce the maintenance backlog and recently has adopted INPO AP-928 ‘Work Management Process Description’ industry standards. This standard re-categorizes CM (corrective maintenance) and EM (elective maintenance) to CC (critical components) and DC (deficient components). Maintenance provides positive outage support in order to reduce maintenance backlogs, increase equipment availability and reliability: 

Provide personnel to the OCC (Outage Control Centre) to fulfill the role of MOM (Maintenance Outage Manager).



Provide resources for outage maintenance activities as specialist skills are required with a backfill of supplementary staff to maintain the on-line units.

Operations support outages in a number of ways including:       

Quorum member for scope review and scope approval Quorum member for scope addition and scope deletion Ensure forced outage plan is complete with all operational issues Staffs the OCC with Operations Outage Manager 24/7 during outages Operations maintains all Controlling Authority responsibilities Operations has milestones for the outage readiness plan Operations supports critical work activities during outages

Requests None

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Safe Operating Envelope Relevance and Management The Bruce A and Bruce B nuclear power plants must be designed, analyzed, operated and maintained within the defined Safe Operating Envelope (SOE). The CSA standard N290.15, “Requirements for the safe operating envelope for nuclear power plants” provides requirements for the definition, implementation and maintenance of the SOE at nuclear power plants. The responsibility for management of the SOE resides within the Engineering organization, who are responsible to define and document the SOE and its basis, to ensure compliance to the SOE requirements as addressed in station safety analysis, design, operations and maintenance activities and to ensure the definition and compliance to the SOE is sustained in any changes made in the station. The safe operating limits, conditions and surveillance requirements as well as their bases as defined by the current licensing safety analyses are documented in station and system specific Operational Safety Requirements controlled documents along with any associated Instrumentation Uncertainty calculations. The limits and conditions defined in the Operational Safety Requirements, including any requirements for corrective or mitigating actions and action times, are specified in the applicable Operations and Maintenance tests, procedures and processes to ensure compliance with the SOE. The framework for the definition of the SOE and for the maintenance of this documentation as part of the design and safety analysis change processes is addressed in procedures under Bruce Power’s Design Basis Management and Engineering Change Control programs. Past Performance and Future Plans During the current licensing period, the Bruce Power’s SOE project has been completed and communicated to the CNSC (in December 2012). Although the project objectives were based on compliance to CANDU Owners Group document COG-02-901 Principles and Guidelines for Safe Operating Envelope, which predates CSA N290.15, the project completed the definition and baseline implementation of the SOE for the Priority 1 and 2 systems. The few outstanding implementation actions are being transferred to the ongoing SOE compliance sustainability processes for tracking and completion. The completion of changes to Bruce Power documentation to ensure sustainability of the SOE definition and compliance, including the changes required to specifically address and reference the CSA N290.15 standard, are currently in progress. The framework for managing compliance to the SOE requirements in station Operations and Maintenance, including the requirement to ensure SOE compliance is sustained in changes to station operations and maintenance tests, procedures and processes, will be covered in the procedures governed by Bruce Power’s Equipment Reliability program and Performance Monitoring procedures. The completion of the required changes to these procedures will also be in place by the end of 2014. Formalization of any SOE training requirements is ongoing and will continue to progress as the documentation changes for CSA compliance are completed. Implementation of training requirements into the appropriate processes will also be complete by the end of 2014.

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Challenges None Requests None 3.3.5

Accident Management and Recovery Measures to ensure that the operation of the reactor can be returned to a safe and controlled state by control room personnel should operation deviate from normal during non-routine and emergency conditions (within the design basis accident DBA). Review topics include:      

Abnormal incidents procedures (AIMs) Emergency operating procedures (EOPs) Recovery procedures Sufficient Number of Qualified Staff during accidents Emergency response team (ERT) Design basis accidents (DBAs)

Bruce Power has an adequate operations program that ensures safety of the public, environment, plant personnel and plant equipment under normal operations and accident conditions. The program consists of governing documents in the area of operations program, operating limits, reporting requirements, and operational safety requirements. Bruce Power operations programs establish safe, uniform and efficient operating practices under all operating conditions (routine and non-routine) and provide the ability to ensure that the station is operated in such a manner that:   

Applicable regulations, license conditions, and standards are followed. The requirements of the OP&Ps are implemented. Limits are established in accordance with a Safe Operating Envelope.

Bruce Power’s operation activities are established by the Operating Policies and Principles (OP&Ps) which specify how Bruce Power will operate, maintain and modify station systems to maximize nuclear safety and minimize risk to the public. The OP&Ps also define boundaries, rules and authorities. Compliance to the OP&Ps at all times is a license requirement and if operating outside of OP&Ps is discovered, Bruce Power is to report the CNSC and take immediate action to return to within the boundaries, in a safe manner. Bruce Power has implemented Abnormal Incident Manuals and Emergency Field Operating Procedures, and Severe Accident Management Guidelines which are based on the analyzed Design Basis, to ensure that the operation of the facility can be returned to a safe and controlled state should operation deviate from normal operation. At all times, Bruce Power staffs Bruce A and Bruce B with the required number of complement staff who are qualified, and competent to stand watch in their respective disciplines.

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Past Performance On an annual frequency, the Emergency Field Operations and applicable Abnormal Incident Manuals are re-qualified for each Nuclear Operator and Authorized Nuclear Operator who holds a minimum complement position. This is tracked in a Training Information Management System (TIMS). Please see PROL Renewal Application C14(2)(e) – Training Records for more information. Over the licensing period, Bruce Power entered into the AIMs procedures 10 times (3 on Bruce A and 7 times on Bruce B) to address plant conditions. All of these events were safely addressed using the applicable procedures, including AIMs. For example, on Feb 3, 2013, unit 8 experienced a total loss of Class IV power. All the AIMs and procedures were used to address the event and successfully shutdown the unit to a safe state. As part of ongoing efforts to enhance emergency response capabilities, Bruce Power has constructed a new Emergency Management Centre (EMC) and implemented a new response organization that follows the Incident Management System (IMS) doctrine. Using IMS supports and enhances capability to implement an “All Hazards” approach to emergency response. The use of the new facility and IMS was successfully tested as a proof of concept during Huron Challenge “Trillium Resolve” in October 2012, which tested the new approach in response to an external severe weather hazard. During this exercise, Emergency Mitigating Equipment was successfully deployed that provided back-up power and cooling water to the station. In addition, the Emergency Management Centre proved to be an effective approach in consolidating two Emergency Centres, the Site Management Centre (SMC) and Corporate Emergency Support Centre (CESC), into one. Currently, work is being finalized to put in place full redundancy with communications and back-up power. Refer to Section 3.10 for additional information on the Huron Challenge exercise. In October 2013 Bruce Power conducted a Site Exercise to further test, as a proof of concept, the use of the new Emergency Management Centre (EMC) and the Incident Management System in response to a common mode station event. During this exercise Bruce Power successfully tested the linkages between the new EMC and the station Emergency Operation Centre (EOC) and confirmed linkages between the station EOC and field procedure execution. During this exercise Emergency Mitigating Equipment was also deployed to provide back-up power and cooling water to the Bruce A Station. The exercise was a success and work is being completed implement enhancement identified during the exercise. Future Plans Bruce Power is progressing on completion of the Canadian Nuclear Safety Commission post Fukushima Action Items (FAIs). All AFIs have now been closed and are currently being tracked through Station Specific Actions. Many actions have been completed and remaining actions are being tracked to completion as planned. A complete status update on Fukushima action items is included in Bruce Power’s licence renewal applications which were submitted under separate cover.

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EMC/IMS Implementation - With the site exercises conducted in 2012 and 2013 (discussed above) both confirming the effectiveness of using the new Emergency Management Centre and Incident Management System, Bruce Power is working towards implementing the new response approach by December 2013. To support this effort, the following activities are being completed: 

Development of a new 5-crew Emergency Response Organization based on IMS.



Implementing a new fully redundant Emergency Management Centre.



Development and delivery of a new fully SAT compliant emergency response training program.



Revision of the full suite of document changes to support the new emergency response approach.



Training completed on EME deployment and supporting field activities.

Off-site Monitoring - Bruce Power is implementing remote gamma monitoring at on-site and off-site locations. Plans include 15 gamma detectors to be installed at intervals on the site boundary and the remaining 38 detectors to be installed along our far boundary and various other locations within the Primary Zone. This system is designed to augment our current TLD gamma monitoring system. The new system is designed to monitor, assess and dispatch real-time monitoring data to support a more efficient timely receipt of data reducing the need for human transfer and risk of error. The project is moving forward and gamma monitors are scheduled for full installation by Q3 of 2014. Plans are also in place to test aerosol monitors for installation at current existing air inflow monitor locations by the end of 2014. Challenges None Requests None 3.3.6

Severe Accident Management and Recovery Relevance and Management A severe accident is a beyond design basis event that results in widespread physical damage to fuel and core structures and which has potential for a release of fission products outside containment. Severe Accident Management Guidance (SAMG) is specifically intended to provide a framework for identifying appropriate mitigating actions for events that fall into the severe accident category. To the maximum extent practicable, Bruce Power has adopted the COG industry recommendations for the development of SAMG.

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Bruce Power’s Severe Accident Management procedure, defines the requirements of Bruce Power's Severe Accident Management (SAM) program by establishing the actions to be taken to:    

Terminate core damage progression. Maintain the capability of containment. Minimize on site and off site releases. Achieve a safe, stable state of the reactor and plant over the long term.

The SAM Process in use at Bruce Power includes the following elements, each of which is discussed in more detail below. 1. 2. 3. 4. 5. 6. 7.

Control room Guides and Diagnostic Flowcharts Severe Accident Guides and their associated Basis Documents Severe Challenge Guides and their associated Basis Documents Computational Aids and their Basis Documents Responsibilities of Persons and Organization Involved in SAMG Requirements for Personnel Training Results of SAMG Validation and Reviews

1.

Control room Guides and Diagnostic Flowcharts The key underlying philosophy of Severe Accident Management Guides (SAMG) is that the plant has entered or is going to enter a state outside its design and analysis base, assumptions used to develop Abnormal Incidents Manual (AIM) procedures may no longer be valid and actions contained in AIM may no longer be appropriate. Under these circumstances, possible mitigating actions require careful evaluation prior to implementation to determine whether they are likely to be beneficial or detrimental. SAMG provides a structured process to identify, evaluate and prioritize these actions. BP-SAM-10001, Bruce A - Severe Accident Control Room Guide 1 (SACRG-1) BP-SAM-20001, Bruce B - Severe Accident Control Room Guide 1 (SACRG-1) and – Initial Response, is intended for use in the cases when the conditions for entry to SAMG are met before the Technical Support Group (TSG) of the Site Management Centre (SMC) is operational. The primary focus of SACRG-1 is on short-term actions as needed to reduce releases, protect containment and take manual control of specified equipment that has not auto initiated. The strategy is to maintain the current plant state and to implement mitigating actions that do not have negative impacts. This, together with continuing any AIM strategies already started, is the objective of SACRG-1. BP-SAM-10002, Bruce A - Severe Accident Control Room Guide 2 (SACRG-2) – Technical Support Group Functional and BP-SAM-20002, Bruce B - Severe Accident Control Room Guide 2 (SACRG-2) – Technical Support Group Functional is used by the Main Control Room (MCR) staff when the Technical Support Group (TSG) of the Site Management Centre (SMC) is operational and ready to begin directing response to the event. The Shift Manager would normally be instructed to enter SACRG-2 from BP-SAM-10001, Bruce A, Severe Accident Control Room Guide 1 (SACRG-1) - Initial Response.

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BP-SAM-10003, BRUCE A - DIAGNOSTIC FLOW CHART (DFC) and BP-SAM-20003, BRUCE B - DIAGNOSTIC FLOW CHART (DFC) – The purpose of the diagnostic tools is to provide a pre-planned, systematic approach to guide the plant response in what is likely to be a complex situation where most or all of the available preventative measures have failed. Inherent in the approach is the assumption that a transfer from plant Abnormal Incidents Manual to SAMG is triggered by actual or impending severe damage to the fuel and release of excessive amounts of fission products to containment. The scope of the diagnostic tools is limited to mitigation of the threats posed by the severe accident progression and returning the plant to a long-term stable state, but not on prevention of fuel damage. When all parameters in the DFC are within the setpoint values and stable or trending in the safe direction, the plant is considered to be in a controlled stable state and SAMG can be exited via a transfer to BP-SAM-10025, Bruce A - Severe Accident Exit Guide 2 (SAEG-2): SAMG Termination. 2.

Severe Accident Guides and their associated Basis Documents Severe Accident Guides (SAGs) are entered from the DFC when the applicable set-point is exceeded, based on the priority order in which set-points are checked in the DFC (e.g., if more than one set-point is exceeded, the SAG associated with the highest ranking set-point should be used first). Each SAG has an associated background document that explain the bases and rationale upon which the content of the materials in the SAG have been developed. The list of SAGs are as follows:      

3.

SAG-1 Inject into Heat Transport System SAG-2 Control Moderator Conditions SAG-3 Control Shield Tank Conditions SAG-4 Reduce Fission Product Releases SAG-5 Control Containment Conditions SAG-6 Reduce Containment Hydrogen

Severe Challenge Guides and their associated Basis Documents Severe Challenge Guides (SCGs) are entered from the Severe Challenge Status Tree (SCST) when the applicable set-point is exceeded, based on the priority order in which set-points are checked in the SCST (e.g., if more than one set-point is exceeded, the SCG associated with the highest ranking set-point should be used first). Each SCG has an associated background document that explain the bases and rationale upon which the content of the materials in the SCG have been developed. The list of SCGs are as follows:    

SCG-1 Mitigate Fission Product Release SCG-2 Reduce Containment Pressure SCG-3 Control Containment Atmosphere Flammability SCG-4 Control Containment Vacuum

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Computational Aids and their Basis Documents The Computational Aids (CAs) are provided to allow the estimation of certain conditions or capabilities when direct instrumentation is not available or adequate. CA use is called directly from individual SAGs and SCGs, at the point where the CA is required. CAs are, therefore, used to fulfill specific identified information needs. When CA use is required to complete an SAG or SCG step, this need is identified in the step, and reference is made to the CA to determine the required information, after which the SAG or SCG is resumed from the same point. The list of Computational Aids are as follow:       

5.

CA No. Parameter Calculated CA-1 Individual Dose to a Member of the Public from a Containment Vent CA-2 Rate of Water Addition for Decay Heat Removal by Vaporization CA-3 Rate of Water Addition to Maintain or Increase Moderator Level CA-4 Hydrogen Flammability in Containment CA-5 Containment Water Level CA-6 Determination of Magnitude of Core Damage from Measured Dose Rates

Requirements for Personnel Training SAMG training requirements are documented in TQD-00005, Emergency Response Organization Training and Qualifications Description. Response to severe accidents is expected to follow Severe Accident Management Guidance (SAMG), which outlines various strategies for mitigating core damage and fission product releases during a severe accident (SA). The following training has been delivered: a)

Certification Training - Severe Accident Management Guidelines (CRSS Supp). This training course is designed to provide candidates with the necessary knowledge and understanding of the key principles and application of SAMG documentation and tools, such that they can confidently respond to such an event within their assigned role. This training has been developed from the CANDU Owner's Group (COG) SAMG approach and the course includes information on Severe Accident phenomena, the SAMG documentation package, and how it is intended to be used as part of Severe Accident Management (SAM). Candidates taking this course include : Certified/Authorized staff (e.g. Shift Managers, Control Room Supervisors, Authorized Nuclear Operators, Unit 0 CRO), members of the Site Management Centre, and other staff who are likely to be called upon in technical support roles as part of the emergency response to a severe accident.

b)

Severe Accident Management Guidelines (SAMG) - Site Management Centre and CESC. This training is designed to train candidates on how to effectively respond to the condition of a Nuclear Accident, and support the shift crew in the restoration of a safe and stable state, while minimizing the adverse impact on the public and the environment.

BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B c)

6.

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Severe Accident Management Guidelines (SAMG) - Technical Support Group. This course is designed to provide the knowledge of the SAMG to the level required to understand the structure of the response guideline hierarchy and specific SAGs used for specific parameter perturbations. In specific, it provides the knowledge requirements for those staff members who are required to respond to their emergency response role as members of the Severe Accident Management Guidance (SAMG) Technical Support Group (TSG), specifically as it pertains to a severe accident.

Results of SAMG Validation and Reviews. All changes to SAM Guidelines require preparation, review, validation and approval according to the standards set out for operating documentation in BP-PROC-00250. The initial SAM validation drills for both Bruce A and B where completed along with the implementation of the key elements of SAMG. The key elements included:        

A SAMG User’s Guide Two Control Room Guidelines A Diagnostic Flow Chart A Severe Challenge Status Tree Seven Severe Accident Guidelines Four Severe Challenge guidelines Six Computational Aids Two Severe Accident Exit Guides

Past Performance The SAMG Program currently in place at Bruce Power was developed specifically to deal with the possibility of a severe accident occurring on a single reactor unit operating initially at high power. Although SAMG was not specifically developed to address events on a shutdown unit or events on multiple units the fundamental strategies developed for one unit are also applicable to a shutdown unit or to multiple units. Internationally, in the past, the term severe accident in the context of SAMG is understood to apply only to reactor accidents. Hence, other accidents involving large releases of radioactivity (tritium) to local bodies of water or prolonged loss of water covering fuel in the irradiated fuel bay was not part of original SAMG Program. Future Plans Subsequent to the events that occurred at the Fukushima Daiichi Nuclear Power Plant and the resultant lessons learned, the CANDU Owners Group (COG) SAMG Task Team established an industry joint project, JP4226 Severe Accident Support to Industry – Post Fukushima, to review the original SAMG used at Canadian NPPs for gap or improvements. The COG review identified several gaps in the pre-Fukushima SAMG. Examples of these gaps include: 

Insufficient guidance to specifically address shutdown units or low power operation.



Insufficient guidance for multi-unit events.



Insufficient guidance for Irradiated Fuel Bay severe accidents.

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A methodology for evaluating instrumentation and equipment survivability during exposure to severe accident conditions.



A process to determine plant habitability during severe accidents.

The gaps identified above are being assessed and the SAMG Technical Basis Document (TBD) is being revised by the industry joint project (JP4426) to address the identified gaps. Following revision of the SAMG TBD, the station specific guidelines will be revised as appropriate. Challenges The challenges to the current SAMG in place have resulted from addressing the lessons learned from the events that occurred at the Fukushima Daiichi Nuclear Power Plant. Assessment of the lessons learned has identified the gaps in the current SAMG framework listed above. Resolution of these gaps will require revision to the currently in place SAMG framework and is currently being tracked as part of the CNSC Staff Action Plan (INFO-0828) in the form of Fukushima Action Items (FAIs). Requests None 3.4

SCA 04 - Safety Analysis The safety analysis SCA includes maintenance of the safety analysis that supports the overall safety case for the facility. Safety analysis is a systematic evaluation of the potential hazards associated with the conduct of a proposed activity or facility and considers the effectiveness of preventive measures and strategies in reducing the effects of such hazards. Specific areas covered include:      

3.4.1

Deterministic Safety Analysis Probabilistic Safety Analysis Criticality Safety Severe Accident Analysis Management of Safety Issues (including R&D Programs) Environmental Risk Assessment

Deterministic Safety Analysis Relevance and Management Bruce Power has a dedicated organization and programs and processes in place to ensure that safety analysis issues are understood, prioritized and addressed in order to safely operate and maintain the facilities.

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Key among these processes is the Plant Design Basis Management Program, the purpose of which is to define, document, and control changes to the Design Basis to maintain it within approved safety margins and regulatory requirements, and to perform such Safety Analysis as is required to ensure that plant operation conforms to the Design Basis and licensing assumptions, and remains within the bounds of analyzed conditions and the Safe Operating Envelope (SOE). This program is supported by the Environmental Qualification (EQ) process, which establishes an integrated and comprehensive set of requirements that provide assurance that credited essential equipment and components can perform their safety-related functions if exposed to harsh environmental conditions resulting from Design Basis Accidents, in accordance with the plant design and licensing basis and that this capability is preserved over the life of the plant. Safety Analyses are performed to: 

Verify that regulatory requirements, such as dose limits, are met.



Assist in defining the safe operating envelope.



Verify that Special Safety Systems and Safety-Related Systems can perform their mitigating role for Design Basis Accidents.

Bruce Safety Report Update Bruce Power uses the Safety Report Update (SRU) Process to evaluate, prioritize and resolve safety analysis issues, and consequently update the Safety Report. This process was developed as an integral part of the Quality Assurance of Safety Analysis established for the closure of Generic Action Item 99G01 “Quality Assurance of Safety Analysis”. The SRU Process, which is documented as a series of procedures DPT-NSAS-00002 and DPT-NSAS-00003. The outputs of the SRU Process are: 

The Safety Report Basis (SRB), consisting of a listing of Analysis of Record items and auxiliary documents, is the repository of all relevant documents since the last Safety Report revision, the contents of which are applicable to future SRU consideration.



The SRB is used as the basis for the next scheduled update of the Safety Report. The SRB is maintained in accordance with DPT-NSAS-00002.



The update of the Safety Report as per the S-99 requirement.

Meetings with CNSC Ottawa staff are held on an annual basis to communicate the SRU process and to provide updates on various safety analysis work programs. Safe Operating Envelope (SOE) As discussed in SCA 03 above, a Project Execution Plan for the completion of the SOE documentation and its implementation for both Bruce A and B was provided to CNSC staff in 2007.

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The “project” phase of SOE is considered complete as of Q4 2012. Bruce Power staff are updating the Operating Safety Requirements (OSR) documents per the normal processes to maintain the definition of the SOE current, as required for compliance with CSA N290.15, Requirements for the Safety Operating Envelope for Nuclear Power Plants. Also, Bruce Power staff recently assisted OPG in benchmarking their SOE governance. Past Performance Starting with latest updates of Part 3 of the Bruce A and Bruce B Safety Reports, Bruce Power is providing a more comprehensive description of the Revision History in the Safety Report. Bruce Power will also continue providing the CNSC staff an informal update comprising of a listing of SRB indicating the submission to be included in the upcoming Part 3 Safety Report update. The SRB is also presented to the CNSC at the annual COG CNSC-Industry SRU meeting. Future Plans Bruce Power plans to implement a Safety Report Improvement (SRI) framework, which integrates the existing Safety Report (SR) Update program with Safety Report improvement activities undertaken to meet the requirements of the CNSC Regulatory Document RD-310, Safety Analysis for Nuclear Power Plants, once it is formally introduced into the Power Reactor Operating Licences of Bruce facilities. In preparation for executing SR improvement activities, Bruce Power has undertaken an update of the Bruce Power Deterministic Safety Analysis (DSA) governance (processes and procedures) to ensure consistency, accessibility and reproducibility of safety analyses consistent with RD-310. A detailed Safety Report improvement plan in being prepared and will be provided prior to the end of 2013, as further described in Bruce Power’s PROL renewal applications for Bruce A and Bruce B. Challenges The main challenges with respect to the Safety Report are in making the reports RD-310 compliant. Bruce Power is preparing an RD-310 implementation plan based upon industry discussions with the CNSC that it intends to submit to the CNSC before the end of 2013, and discussions are ongoing with the CNSC through the COG sponsored Safety Analysis Improvement task team to agree upon the implementation of the various RD-310 clauses. Requests None

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Probabilistic Safety Analysis Relevance and Management Nuclear safety assessment is defined as the integration of deterministic safety analysis and probabilistic safety assessment (or probabilistic risk assessment (PRA)) to ensure nuclear safety requirements are defined for issues that may impact the station’s design basis or Safety Report Basis. Bruce Power’s Nuclear Safety Assessment procedure defines the elements, functional requirements, implementing procedures and key responsibilities for the nuclear safety assessment process. The Probabilistic Risk Assessment (PRA) Process evaluates the safe operation of Bruce A and Bruce B by utilizing PRA. Station-specific PRAs were developed for each station and the results are assessed against the safety goals and limits defined in the governing procedures. Bruce Power continues to Chair the CANDU Owners Group Risk and Reliability Task Team and ensures the Bruce Power PRA program is consistent with the industry. Bruce Power has a well organized system which provides adequate risk oversight and governance by both station and independent committees. Risks are reported and reviewed by these committees via technical reporting or business risk log summaries. Past Performance As part of the previous licence renewal, Bruce Power committed to a transition plan to update the Bruce A and Bruce B Probabilistic Risk Assessments to CNSC Standard S-294, Probabilistic Safety Assessment for Nuclear Power Plants. The plan involves expanding the scope of PRAs to include internal and external events such as fire, seismic and flooding and developing the relevant PRA methodology documents. The plan has been funded as a multi-year Bruce Power Capital Project and the update of PRAs to S-294 has been ongoing over the licence period. The methodology documents governing the PRA update have been submitted for CNSC acceptance consistent with current licence conditions and S-294. Methodologies for Level 1 PRA for at-power unit, Level 2 PRA for at-power unit, Level 1 PRA for outage unit, fire PRA, seismic PRA, external hazards screening, internal flooding PRA and high wind hazard PRA have been accepted. Updated Level 1 and Level 2 PRAs for an at-power unit at Bruce A and Bruce B have been completed. External hazards screening has been completed, and PRAs for fire, seismic, internal and external flooding, and high winds are being completed. The Bruce A Probabilistic Risk Assessment (BAPRA) and the Bruce B Risk Assessment (BBRA) for internal events were updated in 2008 and 2009, and were submitted to the CNSC. The 2008 and 2009 BAPRA and BBRA met safety limits for severe core damage and large release. Future Plans Future performance improvement areas for SCA will include:    

Development of a site-specific (rather than unit-specific) PRA; Inclusion of External Hazards in Safety/Risk Management Development of relevant PRA safety goals; Seismic risk estimation.

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The work performed in these areas will be in collaboration with the industry via Bruce Power’s participation and leadership in the CANDU Owners Group Risk and Reliability Task Team. Challenges Challenges to the SCA have arisen due to the Fukushima-Daiichi nuclear event and the resulting Fukushima Action Items. The work already ongoing for S-294 implementation was reviewed to ensure there was no additional scope required due to Fukushima, and has been used to address Fukushima Action Items (FAIs) wherever possible. For example, external hazards screening performed for S-294 will be used to provide a response to FAI 2.1.1 (Re-evaluation, using modern calculations and state of the art methods, of the site specific magnitudes of each external event to which the plant may be susceptible). Additional work to address the impact of seismically-induced consequential fire and flooding events is being completed as part of Fukushima response. Revision of S-294 to REGDOC-2.4.2 (Draft August 2013) as part of Fukushima omnibus amendments has been a challenge since it has the potential to impact the existing scope of S-294 work. To manage this risk, Bruce Power has collaborated with the industry and provided comments to the CNSC regarding the draft omnibus amendments, including REGDOC-2.4.2. Requests Until such time as REGDOC-2.4.2 is finalized and issued, the current licence condition referring to S-294 should be retained. When REGDOC-2.4.2 is issued, Bruce Power will need to develop a transition plan and implement the required changes. 3.4.3

Criticality Safety Relevance and Management Nuclear criticality safety management is required when reactor fuel with 235U content above its natural concentration of 0.7% is present outside of the reactor. Bruce Power’s program for Management of Nuclear Criticality Safety establishes the requirements for management of nuclear criticality safety at Bruce Power and addresses the following elements of nuclear criticality safety management: 

Integration with the formal Bruce Power processes for controlling changes and addressing adverse conditions.



Identification of any requirements that must be met by the operation under consideration to ensure that risk due to criticality is sufficiently low.



Integration with the formal Bruce Power processes for implementing new design and operating requirements and for ensuring compliance with the new requirements going forward.



Integration with the formal Bruce Power processes for ensuring that personnel are qualified to perform their nuclear criticality safety related tasks.



Periodic performance reviews and reporting.

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The Nuclear Criticality Safety Management procedures implement nuclear criticality safety management practices consistent with international standards, such that the potential for enriched reactor fuel to form a critical configuration outside the reactor core is always prevented and any formed configuration of the enriched fuel is subcritical. Bruce Power also employed a Criticality Safety Evaluations process to implement criticality safety evaluation practices consistent with international standards such that, in operations involving enriched reactor fuel, any potential for the enriched fuel to form a critical configuration outside the reactor core is identified so that appropriate preventative measures can accordingly be defined and implemented prior to undertaking the operation. With the suspension of the Low Void Reactivity Fuel (LVRF) project, and considering Bruce Power has no plans to bring additional enriched fuel bundles onto the Bruce Site, new criticality safety analyses are not needed. Bruce Power intends to request CNSC’s consent to dismantle the Criticality Safety program. Past Performance There is no risk to criticality safety since the booster fuel assemblies are permanently stored in the Booster Storage Facility. In the case of Bruce B, due to the LVRF Demonstration Irradiation (DI), twenty-two irradiated LVRF bundles from the DI continue to be safely stored in a subcritical state in the irradiated fuel bays under normal and credible abnormal conditions. Challenges None Future Plans and Requests Bruce Power will submit a request under separate cover request that Licence Condition 13.5 in the current Bruce A PROL and Licence Condition 13.3 in the current Bruce B PROL be removed from the current licences. 3.4.4

Severe Accident Analysis Relevance and Management Bruce Power executes a robust program of monitoring, testing, data collection and evaluation to ensure the safe operation of the station and has a process to evaluate the safe operation of the stations by utilizing Probabilistic Risk Assessment (PRA) and evaluation against defined safety goals and limits. This includes assessment of severe accidents as part of the Level 2 PRA. Past Performance As Part of the previous licence renewal, Bruce Power committed to a transition plan to update the Bruce A and Bruce B PRA to align with CNSC Standard S-294, Probabilistic Safety Assessment for Nuclear Power Plants.

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The Plan involves expanding the scope of existing PRAs to include internal and external events such as fire, seismic and flooding, and developing the relevant PRA methodology documents. It also includes updating the Level 2 PRA methodology. The plan has been funded as a multi-year capital project. Update of these PRAs to S-294 has been ongoing ever the current licence period. The methodology for Level 2 PRA for at-power unit has been accepted by CNSC staff and updated PRAs for an at-power unit at Bruce A and Bruce B have been completed. Future Plans Following the Fukushima-Daiichi nuclear event, the CANDU Owners Group (COG) formed a joint project (JP4426) to undertake a revision of the generic COG SAMG guidance documents. Bruce Power has participated in this project to expand the scope of the SAMG and review it against Fukushima lessons learned and other research and developments. These activities have been supported by severe accident analysis performed by the utilities and vendors. Challenges Challenges have arisen due to the Fukushima nuclear event and the resulting Fukushima Action Items. The work already ongoing for S-294 implementation was reviewed to ensure there was no additional scope required due to Fukushima, and has been used to address Fukushima Action Items (FAIs) wherever possible. For example, Level 2 PRA work was used to provide a response to FAI 1.3.1 (Assessment of adequacy of the existing means to protect containment integrity) and FAI 3.2.1 (An evaluation of the adequacy of existing modeling of severe accidents in multi-unit stations). Revision of S-294 to REGDOC-2.4.2 (Draft August 2013) as part of Fukushima omnibus amendments has been a challenge since it has the potential to impact the existing scope of S-294 work. To manage this risk, Bruce Power has collaborated with the industry and provided comments to the CNSC regarding the draft omnibus amendments, including REGDOC-2.4.2. Requests As noted in 3.4.2 above, until such time as REGDOC-2.4.2 is finalized and issued, the current licence condition referring to S-294 should be retained. When REGDOC-2.4.2 is issued, Bruce Power will need to develop a transition plan and implement the required changes. 3.4.5

Management of Safety Issues This subsection addresses the following safety issues:      

Heat Transport System Ageing Large Loss of Coolant Margin Restoration Enhanced Neutron Over-power (NOP)Analysis for Aged Conditions Hydrogen Behaviour in Containment Modified 37-element Fuel Bundle Project Generic Action Items

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Heat Transport System Ageing Relevance and Management The Heat Transport System (HTS) Aging Safety Margin Management Program was mandated to assess the impact of aging HTS components on safety analysis margins in an integrated, systematic and comprehensive manner. Phase 1 of the Program was completed in 2001. A systematic review of all components in the HTS (and components which interface with the HTS) was performed to determine dominant aging mechanisms which could affect the HTS performance and in turn affect the safety margins. This review allowed for identification of data collection requirements. In 2008, the major conclusions of the Phase 1 work were re-assessed, documented and issued in order to provide a technical basis for the current Program. The Technical Basis Document for the Program, applicable to both Bruce A and B, has been provided to the CNSC. 1.

The proactive strategy currently in place is the HTS Aging Safety Margin Management Program. The program defines the scope of HTS aging impact that needs to be accounted for in nuclear safety analysis (NSA). Further review of existing practice in terms of monitoring of significant aging effects and any feedback of NSA results on fuel channel inspection is ongoing with a target completion of Q3 2012. The objective is to confirm adequacy, and any potential improvement of the current process, governing the interface between fuel channel inspection and NSA. Note that the current safety case for continuing operation has been established in the Bruce A and B Safety Reports accounting for the effects of HTS degradation on the basis of the HTS Aging Safety Margin Management Program.

2.

Safety significant SSCs were assessed as part of the Phase 1 work discussed under Item 1 above.

3.

Assumptions, methods, acceptance criteria and data - HTS aging impact assessments has been performed for the key accident categories that are prone to the effect of HTS degradation including Neutron Overpower (NOP), Loss of Flow (LOF) and Small Break LOCA (SBLOCA) as detailed in the respective sections of Part 3 of the Bruce A and B Safety Reports. The current assumptions for the key aging parameters used in those analyses are also identified.

4.

Critical conditions that affect aging and parameters to be modeled - The critical parameters that affect safety analysis which require ongoing monitoring were established as part of the Phase 1 work discussed under Item 1 above.

5.

Data and information to be collected to confirm safety analysis – Refer to Item 4 above.

6.

Relevant OPEX with respect to aging will be reviewed on an ongoing basis as per normal business practice, including the filing of Station Condition Records (SCRs) and S-99 reports where appropriate. Any adverse impact on the existing safety case will be assessed in order to support continuing operation. Such analyses may result in the establishment of a new safety case which will be submitted to the CNSC and included in the Safety Report at the next scheduled update as governed by the existing Safety Report Update process.

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Future Plans Bruce Power is designing and implementing a change to the 37-element fuel bundles to support the aging and margin management programs. The project is part of Bruce Power’s integrated aging management means to adhere to the requirements of Regulatory document RD-334 on Aging Management for Nuclear Power Plants Regulatory Document, June 2011. The change involves a reduction to the central-element diameter within the bundle and the details of this project are described in the “37M Project”. Bruce Power intends to implement Asset Management to ensure safe plant operations throughout its life cycle. In order to do so the safety basis process and Composite Safety Profile (CSP) will be developed to provide an integrated measure of safety and predicted change in safety of the plant on year over year basis for a period of 5 years. The safety basis process and CSP measures on safety will be used to identify the risk areas and help optimized plant safety improvement and the integrated improvement plan. This part of work is covered under “Asset Management” project. Challenges Bruce Power is preparing the aged thermal hydraulic models to reflect the aged core conditions and assessing the aging impact on heat transport system (HTS) for Units 3 - 4 and Units 5 - 8, for the next licensing period (2015 - 2019). Units 1 and 2 have just been refurbished hence, there are no immediate aging concerns for Units 1 and 2. The HTS ageing models for the aged condition are based on the data trends from operating plant data from the Plant Information (PI) system database for Units 3 - 4 for Bruce A model and Units 5-8 for Bruce B models. The impact assessments evaluate the impact of aging on the normal operation and shut down system trip effectiveness in maintaining fuel and fuel sheath integrity under the limiting accidents. The aging impact assessments contain the following:   

Loss of Flow Event (LOF) Assessment Small Break LOCA (SBLOCA) Event Assessment Large Break LOCA Assessment

Requests None 3.4.5.2

Large Loss of Coolant Margin Restoration Relevance and Management The Bruce Power strategy to address Large Loss of Coolant Accident (LLOCA) safety margin restoration is focused on making physical design changes as the preferred solution while at the same time pursuing other industry alternatives. This was communicated to CNSC staff through a number of submissions from 2007 to 2011.

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Bruce Power is actively working to implement the new neutronic trips (NNT) in all the Bruce reactors as communicated to the CNSC in the implementation plan submitted in 2011. The engineering work started in 2010 and the current focus is on the installation of the design demonstration units on each shutdown system (SDS) in the two lead units, Bruce A Unit 2 and Bruce B Unit 8. Bruce Power has committed to provide CNSC staff with semi-annual updates on the progress of the implementation of the new neutronic trips and the CNSC has opened Action Item 1207-3320 to track Bruce Power progress on the implementation of this project. Past Performance Bruce Power has been actively working on all aspects of the LLOCA safety margin restoration strategy since 2008 and has completed a number of key milestones in the strategy. This included identifying the most practical physical change to implement in the Bruce reactors to give the required improvement in LLOCA safety margins. After conducting extensive assessments, it was determined that improvement in the effectiveness of the two shutdown systems (SDSs) is the most promising option to significantly improve LLOCA safety margins. Consequently, in 2009 Bruce Power initiated a feasibility study to evaluate several new design concepts of fast neutronic trips. The objective of this work was to evaluate the improvement in the credited detection time for the most limiting postulated LLOCA scenarios which directly correlates to improvements in LLOCA safety margins. The preliminary results were very promising and showed installing linear rate trips on each SDS will improve LLOCA safety margins, and in 2010 a Bruce Power Capital Project was approved to begin the engineering work for the installation of two fast linear rate trips on each SDS. Positive feedback received from CNSC staff on Bruce Power strategy and work undertaken to install fast new neutronic trips (NNT), and CNSC staff was satisfied that there are no impediments for the release of items 7 and 17 of section 13.3 of Bruce A Licence Conditions Handbooks with respect to the regulatory hold-point for fuel loading of Units 1 and 2. Bruce Power in 2011 provided the CNSC with a detail implementation plan for the NNT and requested the closure of AI 080705 as key commitments and activities were either completed or being addressed under various generic Industry programs with full CNSC participation. In June 2012, the CNSC closed AI 080705 (LLOCA Margin Restoration Project) and opened a new Action Item 1207-3320 to track Bruce Power’s submissions and progress on the implementation of the new linear rate neutronic trips in the Bruce reactors. Future Plans The request for quotes to various suppliers for the design, construction, and testing of the equipment have been issued. Challenges None Requests None

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Enhanced Neutron Over-power (NOP) Analysis for Aged Conditions Relevance and Management In 2009 an Independent Technical Panel completed the review of the enhanced NOP methodology used to address all NOP issues, including aging of the HTS. A set of recommendations resulted which were combined with comments received from CNSC staff. All ITP recommendations have been addressed and are complete. Comments received from CNSC staff have also been completed. Following the ITP review, the CNSC undertook a research project to benchmark the methodology. Bruce Power has provided support to this work. At the completion of this project CNSC staff expressed concerns with respect to the enhanced methodology used to support the NOP TSP with aging conditions in. Bruce Power has provided additional justification to provide support for planned NOP trip setpoint to at least August 30 2016. This justification supports the existing analyses that the NOP trip coverage with aging in Bruce reactors. Annual monitoring of aging trends will continue to confirm the validity of the implemented NOP TSP. These planned TSPs provide adequate safety margin until at least August 30, 2016. NOP analysis with aging will be submitted before the lead Unit EFPDs noted above are reached, once CNSC comments on the methodology have been addressed. Past Performance CNSC review of the NOP enhanced methodology used to support Bruce Power units with aged primary heat transport system has been extensive over the past licence period. CNSC review has started in 2007, followed by ITP review completed in 2011 and CNSC benchmarking activities completed in 2013. ITP activities have been completed in 2011. Final item from CNSC review has been submitted in July 2013 closing all outstanding comments. More recently, in 2011-2013, support to the CNSC review has been provided by Bruce Power, including support for the CNSC Independent Research Project to benchmark the statistical methodology. This project was completed in early 2013. As result of this project and independent review, CNSC staff indicated reservation with respect to the implementation of the methodology and has asked formally for: a) additional confirmation of NOP TSP supporting the Bruce Power units operation for the next 3 years; and, b) a path forward on the NOP methodology. Progress to date on these issues is as follows: 1.

Several meetings have taken place in June and July of 2013 resulting in a positive path forward supporting NOP TSPs for the next 3 years. A submission documenting the path forward was submitted to the CNSC in September 2013. It consists of a composite approach encompassing the following measures: 

Physical (37M implementation).



Empirical (fuel inspection after events).



Operational (limiting operation with abnormal configuration, including high zone levels and monitoring of aging conditions).

BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B 

2.

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Analytical (showing that no impact on the fuel occurs with a simplified error methodology). This safety composite approach has been documented in a submission to CNSC.

Bruce Power is confident that NOP enhanced methodology can be used in the future once all CNSC comments are addressed and the impact on the NOP TSP will be minimal.

Future Plans Over the next three years CNSC concerns on the uncertainty models in the enhanced NOP analysis will be addressed. Submissions to the CNSC will be made to document the revised methodology in support of ongoing operation. In addition, monitoring activities will be performed to ensure the actual aged condition is as predicted in NOP analyses. Challenges Bruce Power will continue to work to address all outstanding issues and obtain CNSC approval for use of the enhanced NOP methodology. This will be performed over the next three years using a systematic approach. Requests In consideration of the progress that has been made addressing the issues identified by the ITP, Bruce Power requests that the requirement in the Licence Conditions Handbooks to provide quarterly updates be removed. Bruce Power will make submissions related to the specific outstanding issues as it progresses over the next three years. 3.4.5.4

Hydrogen Behaviour in Containment Relevance and Management CNSC staff closed Generic Action Item 88G02 (Hydrogen Behaviour in Containment) in July 2008 as a result of Bruce Power’s commitment to implement Passive Autocatalytic Re-combiners (PARs) starting with Bruce A Units 1 and 2. The PARs will form the principal credited measure for long-term hydrogen mitigation, while providing defence in depth in supplementing the existing short-term hydrogen mitigation based on hydrogen igniters. The conditions for closure also include implementation of PARs for the remaining Bruce A and Bruce B units, and to perform long-term hydrogen mixing analyses to support the number and placement of PAR units. Past Performance Bruce Power has installed PARs in Bruce A units 1, 2 and 4, and Bruce B units 5, 6 and 8. Overall Bruce Power has advanced the schedule of PARs installation for both Bruce A and Bruce B units. Bruce Power has submitted the long-term mixing analysis to support the determination of the number of PARs in both Bruce A and Bruce B containments. This analysis demonstrates the adequacy of the number of PAR units to be installed for both a) the single failure Design Basis Accident, that being the Loss of Coolant Accident (LOCA); and, b) for a LOCA combined with a Loss of Emergency Core Cooling System (LOCA + LOECI).

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Future Plans Install the PARs in the remaining Units of Bruce A and Bruce B (Units 3 and 7), the plans for which have been communicated to the CNSC. Challenges CNSC staff raised a number of comments on the results of the short-term hydrogen mixing analysis. The analysis demonstrates that maximum hydrogen concentrations in the main portions of the reactor vault and the limiting pre-heater and primary pump enclosures do not pose a concern with respect to deflagration and/or to detonation transitions and therefore precludes the potential for damage to containment structures and/or related equipment. Bruce Power is actively working on addressing the comments from CNSC staff. Requests None 3.4.5.5

Modified 37-element Fuel Bundle Project Relevance and Management Sustained operation at 93% full power (FP) through the design service and/or licensing period requires implementation of measures to address the reduction in margins due to aging of systems, structures, components and equipment. Introduction of the modified 37-element fuel bundle (37M) improves thermal-hydraulic margins. Bruce Power is implementing the change to 37M fuel bundles to support Bruce Power’s aging and margin management programs and to adhere to the requirements of Regulatory Document RD-334, Aging Management for Nuclear Power Plants. The change in design involves a reduction to the central-element diameter within the bundle as illustrated below:

Figure 21 37M Fuel Bundle Updated Safety Analysis showing the margin improvement between standard 37-element and 37M fuel bundles was completed and submitted to the CNSC.

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Past Performance The 37M design change began implementation at Bruce A in 2013 as part of refueling the reactor units consistent with the agreed 37M Project Regulatory Communication Plan established in 2011. The implementation should be fully effective by the end of 2014, once all inner zone thermal-hydraulic fuel channels have been fuelled with 37M fuel to the 10th bundle position. No issues have arisen during the transition to 37M fuelling. Future Plans Following CNSC consent to use the fuel design, implementation of 37M fuel bundles at Bruce B is planned to start in 2014, per the 37M Project Regulatory Communication Plan as agreed by the CNSC in July 2013. The magnitude of the benefit attributed to the 37M design change is being discussed under CNSC Action Item 1107-2296. Safety analysis for the licensing period 2014 to 2019 recognizes the Bruce stations will be in transition from standard 37-element bundles to 37M fuel bundles, and the safety analysis is being completed consistent with licence conditions. Challenges None Requests None 3.4.5.6

Generic Action Items and CANDU Safety Issues Relevance and Management Bruce Power has made significant progress, while actively working with the Industry, towards the resolution of Generic Action Items (GAIs). All of the outstanding GAls have now been closed with follow-up actions, or have been re-categorized and tracked as CANDU Safety Issues (CSIs). In 2007, the CNSC staff initiated a project to address the outstanding CANDU safety issues related to design and analysis. The issues were identified using IAEA TECDOC-1554, information from currently operating reactors, life extension assessments, and pre-licensing reviews. The CNSC staff identified sixteen Category 3 safety issues. Three of those issues were reclassified to Category 2. Past Performance The following are the GAls that have been closed or re-categorized: GAl 00G01: Channel Voiding During LBLOCA GAl 00G01 was closed in 2012 with post-closure actions tracked under Action Item AI 1207-3315.

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GAl 95G05: Moderator Temperature Predictions The CNSC closed 95G05 for Bruce B, Darlington and CANDU 6 in July 2009. In May 2010, CNSC closed the GAl for both Bruce A and Pickering A with post closure actions tracked under AI 100704. GAI95G04 (Positive Void Reactivity Uncertainty) GAl 99G02 (Replacement of Reactor Physics Computer Codes used in Safety Analysis), CNSC closed these two GAl in Feb. 2012 noting that the issues covered by these GAls are not yet addressed. The closure is based on the activities planned under industry Large Break LOCA and Positive Void Reactivity Implementation Project (COG JP-4367), Technical Area #1, and the closure criteria of the Gal's are a subset of there-categorization criteria of LB-LOCA CANDU Safety Issues. GAl 01 G01 (Fuel Management and Surveillance Software Upgrade). This GAl was closed in July 2012 with post closure actions tracked under AI 12073468. CANDU Safety Issues The following four CSIs related to Large Break Loss of Coolant Accident (LBLOCA) are managed and reported to the CNSC separately as part of a COG Joint Project (JP #4367):    

AA 9 - Analysis for Void Reactivity Coefficient PF 9 - Fuel Behaviour in High Temperature Transients PF 10 - Fuel Behaviour in Power Pulse Transients PF 12 - GAl 00001 Channel Voiding during a Large LOCA

As discussed above, CSI PF 12 has recently been re-classified to CSI Category 2 issue. Bruce Power is anticipating that a request for reclassification of the other three issues could be made in Q3 of 2013 as all the tasks assigned to the JP #4367 have been completed and documented. Aside from the LBLOCA issues, there are a total of nine non-LBLOCA CSIs that are managed by the COG CSI Task Team since the team was established in 2011: 

AA 3 - Computer code and plant model validation.



CL 1 - Cl 1 Fuel Channel Integrity and Effect on Core Internals.



GL 3 - Aging of Equipment and Structures.



IH 6 - Need for systematic assessment of high energy line break effects. Target date: Station specific - Linked with Life Extension Project.



SS 5 - Hydrogen control measures during accidents.



PF 19 - Impact of ageing on safe plant operation.



PSA 3 - Open design of the balance of plant - steam protection.



PF 18 - Fuel bundle/element behaviour under post-dryout conditions.



PF 20 - Analysis methodology for NOP I ROP trips.

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The Industry has held a number of meetings with CNSC staff to review the status of the outstanding non-LBLOCA CSIs. As discussed at these meetings, the industry is continuing to make solid progress towards addressing the remaining issues and adhering to the committed schedule for requesting reclassification. In the case of Bruce Power, such effort has resulted in the request for reclassification of seven issues in 2012 of which three, namely SS5, IH 6 and PF 19, have been granted by the CNSC to date. Future Plans Bruce Power continues to work with the industry and the CNSC to re-classify the remaining Category 3 issues. Challenges The CNSC has not accepted the request by Bruce Power tore-classify CSI PF-20 on Analysis methodology for NOP I ROP trips. A series of past CNSC reviews have identified aspects that required improvement. Corrective actions have been taken as appropriate. Comments from 2009 have all been resolved. For the current findings, a position supporting the planned setpoints has been provided. Bruce Power will continue to work to address all outstanding issues and obtain CNSC approval for use of the enhanced NOP methodology. This will be performed over the next three years using a systematic approach with early communication with CNSC staff. Requests None 3.4.6

Environmental Risk Assessment Monitoring of radioactive and non-radioactive (hazardous) contaminants, physical stressors, potential biological effects, and pathways for both human and non-human biota, necessitated a structured Environmental Monitoring Program (EMP) for the Bruce Power site. The design of the EMP is risk informed; thus, an Environmental Risk Assessment (ERA), consisting of a Human Health Risk Assessment (HHRA) and an Ecological Risk Assessment (EcoRA), is required to identify, quantify and characterize the risk associated with the points mentioned above. The ERA follows the direction of CSA Standard N288.6, Environmental Risk Assessments at Class I Nuclear Facilities and Uranium Mines and Mills. In 2012, a Screening Level Risk Assessment (SLRA, i.e., Tier 1) was completed on the Bruce Power site that identified Contaminants of Potential Concern (COPC) and physical stressors of potential concern. These COPCs/physical stresses require a Preliminary Quantification Risk Assessment (PQRA, i.e., Tier 2) with respect to site specific receptors or Valued Ecosystem Components (VECs) identified in previous studies, including the SLRA Under direction of CSA Standard N288.6, the following tasks will be completed: 1.

Review SLRA with respect to reference documents to identify any weaknesses that should be addressed (e.g., missing COPCs or receptors/VECs of importance to the Bruce Power site) and update SLRA accordingly (if applicable).

BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B 2.

3.

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Review available site concentration data (measured or modeled) for each COPC and physical stressor carried forward from the SLRA (including updates from Task 1, if applicable) to produce preliminary estimates of exposure for each pathway, including temporal/spatial considerations, and risk characterization for each receptor/VEC along with dose calculations as part of the PQRA (includes Human Health Risk Assessment (HHRA and Ecological Risk Assessment [EcoRA]): 

Maximum COPC concentration levels used in the SLRA will be reduced to the mean COPC concentration for the PQRA to compare with guideline values used in the SLRA.



COPCs that do not have a guideline value (i.e., radionuclides) and with mean concentrations greater than the guideline value (with temporal/spatial consideration) will carry forward to the Detailed Quantification Risk Assessment (DQRA).

Develop four Risk Tables (i.e., Human-Radiological, Human-Non-Radiological, Non-Human-Radiological and Non-Human-Non-Radiological) presenting each receptor/VEC with corresponding COPC/physical stressor and associated pathways sorted by the level of risk. Develop criteria to sort each receptor/VEC into monthly, quarterly and annual monitoring depending to the level of risk associated with each.

The outcome of the foregoing will be reviewed and incorporated into Bruce Power’s Effluent and Environmental Monitoring Programs. 3.5

SCA 05 - Physical Design The physical design SCA relates to activities that affect the ability of structures, systems and components (SSCs) to meet and maintain their design basis, given new information arising over time and taking changes in the external environment into account. The annual assessment of physical design examines:      

Design Principles and Requirements Site Characterization Facility Design Structure Design System Design Components Design

Relevance and Management The Physical Design of the Bruce nuclear generating stations is managed through the Configuration Management Engineering suite of programs. These programs provide a disciplined approach to the control of the physical configuration, design requirements, and facility configuration information (FCI) such that station operators have high confidence that structures, systems, and components are fully functional and support safe, reliable plant operation. Included in this suite are programs governing Plant Design Basis Management, Engineering Change Control and Configuration Management. This program suite complies with CSA N286-05, Quality assurance for nuclear power plants and all relevant legal and regulatory requirements.

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The overall objective of the program suite is to ensure that structures, systems, components, and tools meet design basis requirements and enable the plant to operate safely, reliably, and efficiently for the duration of its operating life. This objective is further supported by processes that ensure: 

Design requirements are defined and documented.



Changes are correct, documented, controlled, and approved.



Operations, maintenance, and training documentation is up to date and consistent with the plant design.

Organizational responsibilities and change approval authority are assigned to promote proficiency through standard processes and activities while ensuring commitment to Nuclear Safety: Reactor, Radiation, Environmental and Industrial Safety, is maintained. The Bruce Power site is located on the eastern shore of Lake Huron in the Municipality of Kincardine, Bruce County, Ontario. The site hosts two nuclear generating stations, Bruce A and Bruce B. Bruce Power’s location in relation to neighbouring communities is shown in the illustration below

BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B

Figure 22 Bruce Power Site Location

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Figure 23 Bruce Power Site Layout

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Figure 24 Bruce A, General Station Layout Following an intensive campaign of investment in Bruce A NGS, Bruce Power returned two further units to service in October 2012. All eight PHWRs at the Bruce site were originally designed by Atomic Energy of Canada Limited (AECL) and Ontario Hydro (OH).

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Bruce A NGS is comprised of four nuclear reactors, four turbine generators and associated equipment, services, and facilities as shown in Figure 3 (above), Bruce A, General Station Layout. Notable building and structures at Bruce A include: 

Four reactor buildings.



Four reactor auxiliary bays.



A powerhouse including the turbine hall and turbine auxiliary bay running the entire length of the station.



A central service area.



A vacuum building.



An ancillary services building.



Four pump houses.



The water treatment building (which includes the new Qualified Power Supply (QPS) System).



Four standby generator enclosures.



An emergency filtered air discharge system building.



Emergency coolant injection structures which include an accumulator building, recovery pump room and a storage tank.

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Figure 25 Bruce B, General Station Layout Bruce B NGS has four nuclear reactors, four turbine generators and associated equipment, services, and facilities as shown in Figure 4 (above), Bruce B, General Station Layout. Notable building and structures include: 

Four reactor buildings.



Four reactor auxiliary bays.



A powerhouse including the turbine hall and turbine auxiliary bay running the entire length of the station.

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A central service area.



A vacuum building.



An emergency filtered air discharge system building.



An ancillary services building.



Four pump houses.



A water treatment building.



Four standby generator enclosures.



An emergency power and water supply building.



Emergency coolant injection structures which include an accumulator building and a storage tank.

Major plant systems at both Bruce A and Bruce B include the Reactor, the Reactivity Control System, Heat Transport System, Special Safety Systems, Steam System, Feed Water System, Turbine Generator Systems, Electrical Power Systems, and Process and Service Air and Water systems. Figures 6 and 7 below, Bruce A and B Simplified Unit Flow Diagrams show a schematic of major plant systems for each generating unit. Each reactor consists of a horizontal, cylindrical tank (the calandria). The calandria is penetrated by 480 through-tubes and contains heavy water which moderates the nuclear reaction. Nested in each through-tube is an additional tube known as a fuel channel. It is in this channel that fuel bundles are placed during operation. The reactor is surrounded by a tank containing light water in order to shield nearby structures and equipment from radioactivity during operation. The reactors at Bruce A and Bruce B use a natural Uranium fuel. Each fuel bundle, as shown in Figure 5 below, is made up of thirty-seven (37) fuel pencils arranged in concentric circles. At Bruce A, each of the four hundred eighty (480) channels in two (2) reactors contain thirteen (13) bundles; the channels in the other two (2) units contain twelve (12) bundles. At Bruce B, the channels contain twelve (12) bundles in all reactors.

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Figure 26 Thirty-seven (37) Element Fuel Bundle Control of the nuclear reaction is measured using instruments which provide input to a pair of fully redundant control computers. Output from the computers allows operators to continuously monitor the reactor and its supporting systems. Heat is generated as the nuclear reaction occurs. Generated heat is removed by the Heat Transport System. This system uses four very large pumps to circulate heavy water through all 480 channels and past each fuel bundle. This system forms a closed loop and transfers the heat to regular water by circulating through thousands of small tubes in each steam generator. Each reactor unit has eight steam generators, four on each side of the reactor. During normal operation, two Boiler Feedwater pumps operate to supply demineralized water to the steam generators. As heat is transferred from the heavy water on the steam generator ‘primary’ side, the regular water on the steam generators ‘secondary’ side heats up and turns to steam. This steam travels through insulated piping to the turbines. The motion of the steam entering the turbines causes them to turn. The turbines are directly connected rotating portion of the electrical generator known as the rotor. The generator has a second part – the stator. The stator is stationary and fits around the rotor. As the rotor turns, electricity is generated and flows to the power distribution system.

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Figure 27 Bruce A Simplified Unit Flow Diagram

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Figure 28 Bruce B Simplified Unit flow Diagram

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Past Performance Over the licence period, focus has been on continuous improvement. With requirements met, the vision has shifted to one that includes innovation and excellence in design management. An unwavering focus on this goal has resulted in the realization of a high number of plant improvements. Management continues to focus on this area through the use of a Design Products Challenge Board and rigorous use of project controls to ensure good scope control and cost and schedule performance is sustained. During the licence period from October 31, 2009 to August 2, 2013 – Bruce Power installed over 3300 modifications. This number includes modifications installed both at the generating stations and at support buildings. Approximately half of these modifications were installed at Bruce A and half were installed at Bruce B. Examples of major modifications completed at Bruce A include:             

Special safety system upgrades in Unit 1 and 2 as part of the recently completed Restart project Replacement of Unit 1 and 2 Pressure Tubes and Calandria Tubes Replacement of Unit 1 and 2 Steam Generators Fuel Handling South Extension Trolley Returned to Service Fuel Handling invertors Heat Transport Pump Transformer protection circuit upgrades in Unit 3 Station electrical power transformer replacements in Units 0A, 3 and 4 Extensive pressure tube refurbishment in Unit 3 Nuclear instrument upgrades in Units 3 and 4 Liquid Zone Control pump replacement in Unit 4 Low pressure turbine replacement in Units 1 and 4 Generator replacement in Unit 4 Enhanced cooling capability for beyond design basis conditions

Examples of major modifications completed at Bruce B include:          

Installation of Maintenance Cooling vent lines in Unit 5, 7 Valve and pump replacements in the Steam and Feedwater Heating systems in Unit 6 Heat Transport System solid mode pressure control system upgrade Battery Bank Replacements in Unit 5, 6 and 8 with Unit 7 underway Standby Generator 7 and 8 control system upgrades PHT Pump Motor refurbishment Controller replacements throughout the station Motor Control Centre refurbishments Digital Control Computer air conditioning units Enhanced cooling capability for beyond design basis conditions

Key contributors to good performance have included implementation of new planning tools, use of human performance tools (such as procedure use and adherence, technical pre-job briefs, and turnover), and management oversight and reinforcement of high standards.

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An area of particular attention has been modification quality. Improvements to the conceptual engineering process, use of requirements traceability matrices, failure modes and effects analyses, a new digital design guide and improvements to engineering project management have assured that high quality and effective solutions are developed to solve identified station challenges. To support this, design engineering roles and responsibilities are being refreshed to reflect a high standard of excellence. This focus was chosen in support of the Equipment Reliability program to ensure that equipment improvements are done right the first time and every time. Enhancements in this area have resulted in more efficient plant modifications that support improved safety and reliability. Improvement in this area has been noted very positively by industry peers at both Bruce A and Bruce B. Future Plans Effective use of stakeholder involvement and the corrective action program are driving further improvements in design engineering governance. Bruce Power will be implementing and optimizing a pre-engineered change process to improve cost effectiveness of component replacements. Design quality will be further improved through early construction involvement in the engineering change process. Measurement and reinforcement of procedure use and adherence, improvements to the conceptual engineering process, use of requirements traceability matrices, failure modes and effects analyses and the new digital design guide will further improve the effectiveness of solutions to identified station challenges. To support this, design engineering roles and responsibilities are being refreshed to reflect a high standard of excellence. Processes for controlling design changes and equipment data collection and maintenance will continue to be improved and streamlined in the next year. The objective is to ensure the processes meet a high standard of excellence and reinforce the use of error prevention tools. As part of a continual exercise, we plan to benchmark the broader nuclear industry to optimize safety and performance during design and implementation of modifications. Challenges Historically, design registrations to pressure retaining systems were not updated as changes were made to Bruce A and Bruce B. The changes made met safety standards at the time, but some administrative requirements were not completed. In support of the focus on world-class nuclear operations, historical installations are being reconciled and registrations are being updated. Completion of this project will ensure full compliance with all system registration requirements. All current installations already meet this requirement. Requests None

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SCA 06 - Fitness for Service The fitness for service SCA covers activities that affect the physical condition of structures, systems and components (SSCs) to ensure that they remain effective over time. This includes programs that ensure all equipment is available to perform its intended design function when called upon to do so. This SCA comprises:      

Equipment Fitness for Service/Equipment Performance Maintenance Structural Integrity Aging Management Chemistry Control Periodic Inspection and Testing

Relevance and Management Fitness for Service programs are intended to ensure that the physical conditions of Systems, Structures, and Components (SSCs) remains effective over plant life. Fitness of service of the Bruce A and B Nuclear stations is mainly governed by its Equipment Reliability program, with other various supporting and interfacing programs as described below: Equipment Reliability The objective of Bruce Power Equipment Reliability program is that station staff monitor and maintain Structures, Systems and Components (SSC) in a manner such that nuclear safety, reliability, availability, cost and performance are optimized while ensuring regulatory compliance. This is accomplished by an integrated and coordinated Equipment Reliability (ER) program based on the INPO Equipment Reliability Process Description (AP-913) with the enhancements to address the regulatory and business requirements applicable to Bruce Power. The equipment reliability process represents the integration and coordination of a broad range of activities, which are integrated in this program. The activities include: 

Scoping and identification of Critical SSCs important to maintain safe, reliable power operation.



Development and optimization of the preventive maintenance technical basis assessment and tasks to support a documented PM program.



Implementation of Preventive maintenance, including periodic, predictive and planned maintenance, to support continuous improvement of the ER program.



Performance monitoring, by using an established performance criteria and monitoring parameters for important SSCs and programs.



Equipment Reliability Problem Identification and Resolution including corrective actions to follow when a critical SSC experiences an unplanned failure or degraded performance observed by performance monitoring.



Long Term Planning and Life Cycle Management for developing and implementing Life management/extension.

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The Equipment Reliability program also addresses Bruce Power specific requirements for Equipment Reliability including nuclear safety, business planning and asset management. The objective of System Performance Monitoring is to ensure systems important to safe, reliable plant operation will perform their functions under all design basis conditions. These objectives are achieved by creating and maintaining System Performance Monitoring Plan (SPMP) by capturing the “Functions important to safety” identified from the analysis performed. The performance monitoring is accomplished by monitoring and trending of SSC performance; Use of operator rounds monitoring, collection of reliability data, monitoring of safety system test (SSTs) results, monitoring by engineering walk-downs and monitoring of maintenance results (as-found condition, PMT and work completed). These monitoring and trending activities are captured in System Health Reports on a routine basis. If degraded performance has been observed by comparing the monitoring/trending results against the SPMP, system health improvement plans are developed and implemented. Components performance monitoring is based on types of components and equipments and the program activities are designed to assure that component and equipment performance support the safe and reliable plant operation. Component health is evaluated and trended by means of technical evaluations, inspections, testing and maintenance craft feedbacks. Testing of the equipment is performed in accordance with licensing requirements, codes and standards. These activities ensure reliable equipment performance as credited in licensing requirements. Bruce Power has an integrated and comprehensive Ageing Management Program for Critical components, consistent with CNSC direction RD-334, Ageing Management for Nuclear Power Plants, and the recommendations in INPO AP-913, Equipment Reliability. The program includes Technical Basis Assessment (TBA) process which provides a baseline for the maintenance strategy of a component type and documents this information in the form of a maintenance template. Generating a TBA includes performing a Failure Modes and Effects Analysis, determining the applicable degradation mechanisms and developing monitoring and mitigating tasks and frequencies. The TBA is an integral part of Equipment Reliability Program and is governed by Bruce Power’s Continuing Equipment Reliability Integration procedure. Work Management The overall objective of the On-Line Work Management Program is to support nuclear safety and foster a nuclear safety culture to promote work and worker efficiency through the incorporation of guiding principles and values. This program ensures timely identification, screening, scoping, planning, scheduling, preparation and execution of work necessary to maximize the availability and reliability of station equipment and systems. This program also manages the risk associated with work through the proactive identification of situations or activities that could jeopardize or adversely impact safety margins and enable the development of mitigation strategies. The purpose of Outage Work Management Program is to identify the controls associated with planning, implementation, and control of work performed on a reactor unit when the unit is shutdown such that maintenance, inspections, and modifications are performed safely and on the basis of value to maintaining safe, reliable and lowest cost operation. This includes selecting and controlling the scope of work, planning, scheduling, coordinating work execution, and closing out the outage.

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Maintenance Bruce Power’s Conduct of Maintenance Program establishes processes to effectively maintain plant SSCs such that the availability and reliability of safety related and production sensitive equipment is maximized and Operators are not challenged by equipment failure. This program also focuses on managing identification and execution of preventive maintenance and repetitive task work activities by using modeling work orders in support of operation and testing of plant equipments. Predictive maintenance is an integral part of Bruce Power maintenance program, which provides early detection of degradation prior to failure of the equipment. Inspections Bruce Power’s Periodic Inspection and Testing Program ensures the requirements for periodic inspection of safety related plant structures, systems and components (SSCs) are established and documented through creating, updating and revising the Periodic Inspection Plans (PIP) and Schedules. Procedures document the methods for review, evaluation and disposition of Periodic Inspection findings, as required and identify the roles and responsibilities for PIP personnel. Periodic Inspections and the associated reporting is conducted in accordance with requirements of the Bruce A and Bruce B Power Reactor Operating Licences, Licence Condition Handbooks and applicable CSA standards. A Buried Piping Inspection Program has been established. The process specifies the requirements to detect and assess degradation in buried piping as a result of its aging and material degradation due to the effects of related degradation mechanisms, and to initiate corrective action at Bruce Power. These activities are performed to maintain buried piping integrity in order to reduce the risk of the potential impacts to the environment and public confidence in case if unanticipated buried piping failures occur, and to ensure that buried piping systems important to the safe operation of the plant are capable of meeting their design basis requirements until the projected end of life of the generating units/stations. Design Management The objectives of Plant Design Basis Management Program is to define, document, and control changes to the Design Basis to maintain it within approved safety margins and regulatory requirements, and to perform such Safety Analysis as is required to ensure that plant operation conforms to the Design Basis and licensing assumptions, and remains within the bounds of analyzed conditions and the Safe Operating Envelope (SOE). This program is also supported by the Environmental Qualification (EQ) process, which establishes an integrated and comprehensive set of requirements that provide assurance that credited essential equipment and components can perform their safety-related functions if exposed to harsh environmental conditions resulting from Design Basis Accidents, in accordance with the plant design and licensing basis and that this capability is preserved over the life of the plant.

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Past Performance Bruce A During the current licensing period, Bruce A has successfully transitioned from a station with two operating units to one with four operating units. The restart of Units 1 and 2 was achieved while safely operating Units 3 and 4 and also improving the reliability of Units 3 and 4. The Equipment Reliability Index (ERI) is the performance indicator used to measure and demonstrate this. Since 2009, the Bruce A ERI has increased from 38 to 58.

75 70 65 60

BA Target

55 50

ERI Targets initiated in January 2009.

45 40

Sep-13

Jul-13

Mar-13

May-13

Jan-13

Nov-12

Jul-12

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35

Figure 29 Bruce A Equipment Reliability Index - January 2009 to August 2013 Bruce A continues to subscribe to a capital investment program to improve overall reliability. Significant improvements over the licensing period include: 

Repairs and return to service of key pumps in the Liquid Zone Control, PHT feed and End Shield Cooling systems.



Transformer TSS31 upgrades.



Replacement of fuel handling inverters.



Replacement of the generator exciter system.

In accordance with the inspection and testing program for Concrete Containment Structures (CSA N287.7- In Service Examination and Testing Requirements for Concrete Containment Structures for CANDU Nuclear Power plants), all Bruce A Reactor Vaults have been inspected and tested at regular intervals. As a result of the most recent inspections, no deteriorations were observed that would compromise containment integrity and no significant changes were identified when compared to previous inspections.

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The results of the Bruce A main containment structure positive pressure tests were also compared to previous tests and there is no indication of any significant negative performance trend. During the period between positive pressure tests, containment performance is monitored and trended via the quarterly on-power leak rate test (SST 4.15) which measures the leak tightness of the containment structure at negative pressure. Since all 4 units have been returned to service as well as an extensive leak-repair campaign, the leakage rate for main containment is within the OP&P limit and there is no indication of any negative performance trend.

3.00

Equvalent Laminar In-leakage [% mass/hr at 68.9 kPa(g)]

2.75 2.50 2.25 2.00

OP&P Limit

1.75 1.50 1.25 1.00 0.75 0.50 0.25 0.00 Oct-09 Feb-10 May-10 Sep-10 Dec-10 Apr-11 Aug-11 Nov-11 Mar-12 Jun-12 Oct-12 Feb-13 May-13 Sep-13 Date

Figure 30 Bruce A Quarterly Leak Rate Test (SST 4.15) Results Bruce B Performance of Bruce B during the current licensing period remained excellent; one achievement for Bruce B was receiving an improved rating on its biannual peer review conducted by the World Association of Nuclear Operators. Excellent performance is confirmed by almost every performance indicator; the most obvious is the ERI where a significant increase (from 45 in 2009 to 70 in 2013) was achieved during this licensing period. Improvement in Forced Loss Rate (FLR), reduction in Corrective Maintenance backlogs, enhancement in Safety Systems performance, Improvement in Plant System Health Colours and enhancement in work management performance indicators are some other factors contributing to increasing trend in ERI.

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75 70 65 60

BB Target

55 50

ERI Targets initiated in January 2009.

45 40

Sep-13

Jul-13

Mar-13

May-13

Jan-13

Nov-12

Sep-12

Jul-12

May-12

Jan-12

Mar-12

Nov-11

Sep-11

Jul-11

May-11

Mar-11

Jan-11

Nov-10

Sep-10

Jul-10

May-10

Mar-10

Jan-10

Sep-09

Nov-09

Jul-09

May-09

Mar-09

30

Jan-09

35

Figure 31 Bruce B Equipment Reliability Index - January 2009 to August 2013 Throughout the licensing period, all four units of Bruce B operated normally at high power with minimum unplanned outages. As a station, a record was set when all four units operated reliably, in parallel, for 125 straight days. In 2012, Bruce B Unit 6 rated as the world’s top-rated CANDU reactor, with a perfect Score of 100 on the WANO Nuclear Performance Index. During the licensing period Bruce B successfully executed maintenance outages on all operating units. During these outages, commitment to strong operational focus and long term plant health has been demonstrated. In accordance with the inspection and testing program Concrete Containment structures (CSA N287.7- In Service Examination and Testing Requirements for Concrete Containment Structures for CANDU Nuclear Power plants), all Bruce B Reactor Vaults have been inspected by Independent Industry experts. The inspection results from each unit’s containment concrete structures were compared to previous testing. The findings are that containment structures inspected were observed to be in good condition with no significant deteriorations found that can threaten containment integrity. Containment performance is also monitored and trended via the quarterly on-power leak rate test (QLRT) which measures the leak tightness of the containment structure at negative pressure. The results of these on-power tests show that containment leakage remains well within the OP&P limit of 2%/hr at the design pressure and MSC, and there is no indication of any negative performance trend.

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2.5 2 1.5 1 0.5

March-13

September-12

February-12

August-11

January-11

July-10

December-09

May-09

November-08

April-08

October-07

March-07

August-06

February-06

July-05

0

January-05

% contained mass/hr at 82.7 kPag

BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B

Date

% equivalent laminar at 82.7 kPag

% Laminar OP&P limit

Figure 32 Bruce B QLRT Results The Bruce B design uses Fiberglass Reinforced Plastics (FRP) Spray headers, located inside the Vacuum Building as part of the dousing system. Access to FRP spray headers is only available every 12 years, during the Vacuum Building Outage (VBO), therefore to verify the integrity of FRP spray headers, an FRP Aging facility, which replicates the conditions inside the VB, has been used since 2011. The FRP samples collected in the 2004 VBO are being aged in the aging chamber and will be tested in 2014 to monitor and assess any aging process. Bruce Power properly noted the seriousness of the Fukushima Daiichi event and the impact the event would have had on our operations. A significant amount of actions have already been completed or in progress based on lessons learned from this event. A significant amount of communication material was prepared and presented to educate and heighten the awareness of staff to the event itself and to the preparations and modifications Bruce Power is making to align with both our internal and industry-wide requirements. Bruce Power is continually making investments and improvements as part of our “Safety First” culture. Bruce Power focus on improvement led to the purchase of new emergency response equipment, including spare power generators and specially built fire trucks that would provide another layer of back-up cooling for our reactors and nuclear fuel bays in the highly unlikely event the stations lose all primary and backup power sources. To demonstrate its readiness for a major natural disaster, Bruce Power was a key participant in a provincially-led drill called “Huron Challenge” involving more than 50 participating organizations. This drill, a proof of concept for the new emergency response plan, was completed successfully in October 2012. The follow up to this drill in October 2013 verified the effectiveness of new emergency response procedures and guides. Bruce Power also understands the importance of human performance and the associated risks. Employees from the shop floor to station leadership are being extensively trained to use Human Performance (HU) tools; some of which include self and peer checks, three-way communication and procedure use and adherence.

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Future Plans Bruce Power plans to continue its capital investment in the stations to improve equipment reliability through projects to replace and upgrade key equipment. This includes the continued installation and commissioning of new instrument air compressors at Bruce A. To continue with the targets for improving the equipment reliability and Forced Loss Rate, Bruce B is focused on maintenance backlog reduction and completing the refurbishment projects. Bruce B has invested significant capital to improve the reliability of Emergency Power System and Installation of a third Emergency Power Generator. Some other significant projects in progress are commissioning of a new Demineralized water plant and overhauling of Fuelling Machines. Bruce B has proposed a Vacuum Building Outage (VBO) and a Station Containment Outage (SCO) in the spring of 2015. The outages will include positive pressure tests on both Vacuum Building and Containment structures and thorough inspections of the same structures to meet CSA N287.7 and N285.5 requirements. Inspection of the Vacuum Building structure’s post tensioning system and roof seal will also be completed during this outage. Bringing the Vacuum Building outage ahead from 2016 also allows faster installation of Fukushima related improvements to containment. During the Bruce B VBO, detailed inspections of the in-service FRP spray headers (including hangers, spray header thickness, condition of manways, field joints and existing reinforcements) will be performed to determine the condition of the repaired/reinforced sections and the in-service condition. Additionally, material samples will be collected from the FRP spray headers to validate current material properties and will also be used in Aging Facility to estimate the future trending. Challenges Effective management of aging and obsolescence issues with plant equipment becomes increasingly important as units age. These issues are being addressed through our aging and obsolescence program and the strategies to address them are incorporated into our health reports and health improvement plans. Engineering utilizes prescribed strategies highlighted in System and Component Health Reports to mitigate risks due to aging and obsolescence concerns. These strategies are endorsed by Station Plant Health Committee and supported by all involved departments. Requests In order to ensure timely completion of Fukushima related modifications to containment Bruce Power has requested rescheduling of the Bruce B SCO by approximately 6 months to the spring of 2015 and will complete the Vacuum Building Outage at the same time; a year ahead of schedule. This will allow those modifications to be made during the current containment outage rather than a future one. This change necessitates moving the Bruce A SCO to 2016 and this is also requested in the submission.

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SCA 07 - Core Controls and Processes - Radiation Protection The radiation protection SCA covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations. This program must ensure that contamination and radiation doses received are monitored and controlled. This section addresses the following subjects:     

3.7.1

Application of ALARA Worker Dose Control Radiation Protection Program Performance Radiological Hazard Control Estimated Dose to the Public

Application of ALARA, Worker Dose Control, Radiological Hazard Control Relevance and Management The Bruce Power Radiation Protection Program describes the processes used at Bruce Power to control contamination and monitor radiation doses received by workers. Radiological hazard identification, measurement and control support the control of worker doses below regulatory limits and the application of As Low As Reasonably Achievable (ALARA) to reduce collective dose. Through routine and work-specific radiological surveys, hazards are identified and measured so that appropriate mitigating measures can be applied. Hazards are eliminated when possible. Hazards that cannot be eliminated are controlled using engineered barriers and posted to identify the level and extent of hazard areas. Specialized tooling is often used to allow remote operation by workers in low or no dose areas and ventilation systems and strategies are used to mitigate airborne hazards. With hazards identified, measured and controlled, work is then planned and executed to control doses to workers and prevent dose to the public ALARA. Personnel protective equipment, alarming dosimetry and area radiation monitors are used extensively in addition to work surveys to prevent unplanned exposures and to ensure doses to individual workers do not exceed regulatory limits. Monitoring, tracking and restricting the movement of radioactive material prevents the escape of radioactive material. Extensive work planning and dose reduction initiatives are utilized in order to reduce collective dose to levels that are ALARA. Techniques typically include mockup rehearsals of higher risk or long duration work in order to improve worker skill and reduce the chance of errors. Improved system filtration and chemistry control is used to reduce the radioactive source term available to expose workers. Past Performance Application of Bruce Power’s Radiation Protection Program has been effective at identifying and controlling radiological hazards. During the current licensing period Bruce Power has consistently maintained worker radiological exposures below regulatory limits and many enhancements to the RP Program have been implemented. Many of these programmatic upgrades have been the focus of a newly developed internal awareness campaign called “Rad Event Zero” using modern marketing methods to raise the profile of radiation safety.

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Contamination control has been improved with the introduction of specific contamination controls for Discrete Radioactive Particles (DRPs). Improved hazard controls have played an important role in reducing the spread of contamination and controlling worker doses. Personnel contamination monitoring standards have been increased to an industry best level, with the first phase of reactor building rezoning complete. Significant improvements to contamination control are being realized by enforcing the monitoring standard for entering public domain at the zone 3/2 boundary, which helps to control contamination at the source. Several initiatives have been undertaken to reduce worker doses ALARA. Improved filtration and purification on the heat transport system has reduced the amount of radioactive material (particularly Co60 and Sb124) in the system that leads to worker doses. Major improvements have been made to the shielding program including the purchase of a very large quantity of specialized reactor face shielding, the installation of permanent shielding in high dose rate areas, process enhancements to the use and tracking of shielding and improved radiation hot spot identification and tracking. An improved ALARA work planning and hazard assessment process has been developed to ensure potential hazards are identified and appropriate controls are utilized. An opportunity for improvement was identified early in the reporting period during the refurbishment of Units 1 and 2 when significant alpha contamination levels were measured. Since this time, Bruce Power has made a large investment in Radiation Protection in order to measure and control alpha contamination. Capabilities to measure surface and airborne alpha contamination have been greatly improved through the purchase and programmatic use of various detection instruments. Early warning capabilities have also been strengthened through the use of intelligent Continuous Alarming particulate Monitors and Personal Air Samplers. Another significant enhancement to airborne hazard control includes the greatly expanded use of continuous tritium in air monitors to provide early detection of potential tritium hazards and to prevent unplanned uptakes. In addition to these new instruments, older instruments have been upgraded to ensure the latest technology is available to ensure the safety of workers. Electronic Personal Dosimeters (EPDs) and gamma meters have both been upgraded and lifecycle planning is underway to plan for further upgrades in the future.

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Figure 33 Alarming continuous air monitors provide early warning of airborne radioactive material Future Plans Bruce Power has been an active leader in developing industry-wide radiation protection performance indicators in order to facilitate comparison of performance between CANDU nuclear operators. This initiative will help to standardize performance measures to identify strengths and also opportunities for improvement in Radiation Protection to support Bruce Power’s ongoing quest to be an industry leader in safe and reliable nuclear operation.

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Future strong performance in Radiation Protection will be partially realized through an increased focus on source term reduction using both proven and developing technologies to decrease the amount of radioactive material that leads to worker dose. Bruce Power is also focusing on technological opportunities to proactively improve the radiological safety of its workers. Challenges None Requests None 3.7.2

Radiation Protection Program Performance Relevance and Management Bruce Power’s Radiation Protection (RP) Program defines implementing standards and processes to ensure all applicable requirements of the Radiation Protection Regulations (RPRs) and the following objectives are met: 

Ensure public and occupational exposures to ionizing radiation are controlled such that: 

Individual doses are kept below regulatory dose limits.



Unplanned exposures are avoided.



Individual and collective doses are maintained at levels As Low as Reasonably Achievable (ALARA), social and economic factors being taken into account.



Control the movement of people and materials in a manner that prevents the uncontrolled release of contamination or radioactive materials from Bruce Power facilities.



Ensure compliance with CNSC Regulations, Licences and CSA requirements pertaining to contamination control and radiation protection, specifically CSA N286 05, Management System Requirements for Nuclear Power Plants.



The achievement of high standards of radiation protection performance in accordance with industry best practices and the World Association of Nuclear Operators (WANO) Guidelines for Radiological Protection at Nuclear Power Plants, WANO GL 2004 01 (Rev 1).

Responsible Managers as detailed within the Program provide oversight and support staff and services to assist in the safe execution of radiological work as planned. Line Managers are responsible and accountable for the safe execution of radiological work as described in these processes. They are also responsible for encouraging their workers to execute radiological work conservatively and with a sense of responsibility for radiation protection.

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Past Performance Following the Bruce A Restart Alpha event in December 2009 Bruce Power undertook an extensive review of the radiation protection program and implemented a number of significant improvements to radiation safety. These improvements included enhanced alpha radiation detection and protection training, the purchase and implementation of new radiation protection instruments and the development and implementation of alpha dosimetry. Bruce Power is now a recognized industry leader in alpha dosimetry processes and was a key member of the Electric Power Research Institute (EPRI) working group that has established the new international best practice guidelines for protection against alpha radiation. Contamination control program, training and implementation improvements have been made during this licence period that has improved the performance for personal contamination events. There has been a consistent decline in personal contamination events since 2010 and Bruce Power’s performance is now better than the industry standard for PCEs during outages. The following graph illustrates Bruce Power’s improved performance in personal contamination events since 2010. The 2013 column includes the actual number (blue) and the forecast (red) for the end of year performance for 2013. 1400 1200 1000 800 PCEs (projected) 600

PCEs (YTD)

400 200 0 2010

2011

2012

2013

Figure 34 Bruce Power Personal Contamination Event Performance Bruce Power has undertaken a number of radiologically significant maintenance projects during this licence period that have brought two units (Bruce A Units 1 and 2) back into service and extended the operating life of two further units (Bruce A units 3 and 4). The tables below (Figures 40 to 45) show the collective radiation exposure by Station and include the Bruce A Restart collective radiation exposures for Units1 and 2.

Collective Dose (p-mSv)

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8000 6000 4000 2000 0

2008

2009

2010

2011

2012

0

0

0

0

11

Refurbishment/Outages

3204

5110

4123

6971

1792

Total

3204

5110

4123

6971

1803

Routine Operations

Year

Collective Dose (p-mSv)

Figure 35 Collective effective dose by operational state for Bruce A - Units 1 and 2

8000 7000 6000 5000 4000 3000 2000 1000 0

2008

2009

2010

2011

2012

Internal Dose

88

565

25

161

196

External Dose

3116

4545

4098

6810

1607

Total

3204

5110

4123

6971

1803

Year

Figure 36 Collective effective dose from internal and external exposures for Bruce A - Units 1 and 2

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Collective Dose (p-mSv)

12000 10000 8000 6000 4000 2000 0

2008

2009

2010

2011

2012

Routine Operations

387

341

265

310

150

Refurbishment/Outages

3853

2402

3277

3038

11124

Total

4240

2743

3542

3348

11274

Year

Collective Dose (p-mSv)

Figure 37 Collective effective dose by operational state for Bruce A - Units 3 and 4

12000 10000 8000 6000 4000 2000 0

2008

2009

2010

2011

2012

Internal Dose

578

244

194

245

367

External Dose

3662

2499

3348

3103

10907

Total

4240

2743

3542

3348

11274

Year

Figure 38 Collective effective dose from internal and external exposures for Bruce A - Units 3 and 4

BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B

Collective Dose (p-mSv)

8000 7000 6000 5000 4000 3000 2000 1000 0

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2007

2008

2009

2010

2011

2012

Routine Operations

640

639

570

534

728

495

Refurbishment/Outages

3572

6013

3737

3079

6374

994

Total

4212

6652

4307

3613

7102

1489

Year

Collective Dose (p-mSv)

Figure 39 Collective effective dose by operational state for Bruce B - Units 5 to 8

8000 7000 6000 5000 4000 3000 2000 1000 0

2007

2008

2009

2010

2011

2012

Internal Dose

382

588

333

618

491

120

External Dose

3830

6064

3974

2995

6611

1369

Total

4212

6652

4307

3613

7102

1489

Year

Figure 40 Collective effective dose from internal and external exposures for Bruce B - Units 5 to 8

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A number of dose reduction and dose control initiatives have been completed during this licence period and as a result the collective radiation exposure for 2013 is 1200 person mSv below target. The initiatives included: 

Improvements to the ALARA Program requiring more rigor for assessing and reviewing radiological work.



Improved oversight of activities by radiation protection technicians.



Improvement of dryers to reduce tritium activity.



Implementation of new technology to better identify tritium leaks.



Source term reduction through antimony removal and improved filtration in the primary heat transfer system.



Use of temporary shielding on reactor face to reduce dose rates.



Installation of permanent shielding in high dose rate areas (CV5/6).



Development and implementation of a discreet radioactive particle control program.



Improved training and awareness for reducing CRE.



Improved tooling for performing pressure tube inspections.

Bruce Power operates and maintains all its units whilst ensuring no worker receives a radiation dose in excess of regulatory limits. The initiatives developed have shown to be effective with significantly reduced collective radiation exposure in 2013. Future Plans Bruce Power has a Radiation Protection Improvement Plan in progress. This plan has identified improvements to the radiation protection organization structure and training improvements for safety technicians and radiation protection technicians. Combined, these initiatives will enhance the delivery of radiation protection and contribute to further reducing personal contamination events and collective radiation exposure. New technology is being investigated and assessed for implementation that will allow for better radiation dose tracking and work site dose estimates. Whole body monitors are being replaced that will have alarm settings below regulatory requirements and improve the control of radioactive contamination. The backbone to the improvement plan is the dose reduction project. This project is evaluating several dose reduction measures including:    

Improved use of nano fibre filtration technology Improved FME controls to prevent to ingress of cobalt Further improvements to shielding Removal of deposits from the ECI system

Source term reduction will continue to be a focus and Bruce Power is working with COG to develop new technology and methods.

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Bruce Power will continue to benchmark other utilities to identify areas for improvement in RP processes. Governance and oversight will be strengthened and new processes developed to support these activities. Challenges None Requests None 3.7.3

Estimated Dose to Public Relevance and Management The 2012 dose to public assessment demonstrates that the maximum dose received by a member of public due to Bruce Power site operations continues to be very small percentage of the annual legal limit of 1000 μSv/Year. Doses to each Potential Critical Group (PCG) were calculated using the IMPACT code, based on the monitoring data. The most recent site specific survey results (2011 Site Specific Survey), 2012 meteorological data, effluent and environmental monitoring data for Bruce site for year 2012 are all taken into account for the calculation. Radiological Effluent Data from Bruce Power, Ontario Power Generation (Bruce Site) and Atomic Energy Control Limited (Douglas Point) were used. The Bruce Power radiological environmental monitoring program carries out sampling and analysis of the following environmental parameters:      

External Gamma Radiation in Air Tritium and Carbon-14 in Air Precipitation Water Aquatic Samples (including fish, sediment and sand) Terrestrial samples (including animal products, vegetation and soils)

The external gamma dose rates and the provincial monitoring program samples were measured by the OPG Whitby Health Physics Laboratory. Environmental external gamma dose rates were measured using Harshaw EGM Thermoluminescent Dosimeters (TLDs). The dosimeters were exposed for three month periods (quarterly) and the annual doses are the sum of the quarterly results. The accuracy of the dosimeters is estimated to be ± 15 percent. The accuracy is verified by the quality control program described in the Ontario Power Generation 2012 Results of Radiological Environmental Monitoring program. The IMPACT code is used for the calculation of doses to potential critical groups. IMPACT is a customizable tool that allows the user to assess the transport and fate of contaminants through a user specified environment. It also enables the quantification of the human exposure to those environmental contaminants for nuclear facilities.

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Past Performance The historical dose to public trend is shown in Figure 1 below. The data point for 2009 shows an increased dose to public value due to tritium emissions from vacuum building/unit outages occurring at the same time as the annual produce sampling. Bruce Power chose to report this conservative value in 2009. Methods remain consistent with industry best practice and represent realistic values to members of the public. The Dose to Public in 2012 was 1.17 uSv/a, which is a deminimus fraction of regulatory limits.

4.41

Dose to Public

2.4

2.3

2.7

2.45 2.1

1.98 1.58

2.85

2.07 1.53 1.17

20 01 20 02 20 03 20 04 20 05 20 06 20 07 20 08 20 09 20 10 20 11 20 12

μSv/a

5 4.5 4 3.5 3 2.5 2 1.5 1 0.5 0

Year

Figure 41 Historical Dose to Public Trend Future Plans Canadian Standards Association (CSA) N288.4-10, Environmental Monitoring Programs at Class 1 Nuclear Facilities and Uranium Mines and Mills, was published in 2010 and supersedes the first edition published in 1990 titled Guidelines for Radiological Monitoring of the Environment. The first edition of this standard (N288.4 M90) discussed the monitoring of radioactive contaminants in the environment in pathways leading to human exposure. The recent edition of CSA N288.4-10 expands to protection of the environment in alignment with the Nuclear Safety and Control Act and includes radiological and conventional contaminants, physical stressors, potential biological effects, and pathways for human and non human biota.

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While Bruce Power has implemented the first edition, work is underway to document, develop and implement the second edition. Bruce Power is adopting CSA N288.4-10 as part of using applicable best industry standards. Bruce Power adopts applicable best industry standards as a framework for achieving continual improvement and sustainable performance excellence, while minimizing our environmental impact and preventing pollution. Bruce Power will continue towards the implementation of CSA N288.4-10 and its companion standards, CSA N288.5-11 and CSA N288.6-12. Challenges None Requests None 3.8

SCA 08 - Core Controls and Processes - Conventional Health and Safety The conventional health and safety SCA covers the implementation of a program to manage workplace safety hazards and to protect personnel and equipment. This SCA addresses the following specific areas:   

Performance Practices Awareness

Relevance and Management In the last licensing period Bruce Power implemented an Occupational Health and Safety Management System (OHSMS) under Bruce Power’s Health and Safety Management Program to drive continual improvement and manage occupational health and safety hazards and risks. n early 2010, Bruce Power’s OHSMS became the first nuclear facility in Canada to become certified to the Occupational Health and Safety Assessment Series (OHSAS) 18001: 007 Standard by an external registrar. OHSAS 18001 is an internationally recognized standard for achieving both improved and sustainable performance through controls and the systematic management of hazards and associated risk. HSAS 18001 is the best fit for Bruce Power as it integrates well with Bruce Power’s other IS0 management systems and IS0 14001 Environmental Management System. Bruce Power’s OHSMS successfully completed a third party recertification audit in Q4 2012. Past Performance Health and Safety Program Improvements Many initiatives and improvements to Bruce Power’s Health and Safety Program have been made over the current licence period. Some of these initiatives include: 

Implementation of a new Ministry of Labour (MOL) interface procedure, BP-PROC-00583 to establish consistent protocols for the management of communications, consultations and visits with the MOL.

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Implementation of a new WHMIS program, BP-SM-00080 including roll out of electronic Right to Know computer kiosks.



Extensive revision of BP-PROC-00651 Safety Metrics and Monitoring program to align with the CANDU Owners Group (COG) Guideline GL 2012-01, Guideline For Recording & Measuring Occupational Injury/Illness Experience.

Accident/Injury Performance Bruce Power’s year to date Industrial Safety Accident Rate (ISAR) has been better than target (0.09) for the last five consecutive years. Recently the site has exceeded 14 million working hours without a lost time injury (LTI). Bruce Power’s last LTI was in March 2012.

Figure 42 Bruce Power ISAR YTD (2009 - Q3 2013) Future Plans As part of our OHSMS, Conventional Safety follows the Plan-Do-Check-Act model to continually improve and challenge our health and safety program to ensure regulatory requirements and industry best practices are met. Health and safety objectives are developed annually to drive these improvements. In addition, regular internal and external audits of our OHSMS drive corrective action plans and identify areas for improvement through Bruce Power’s Corrective Action Program. Challenges None Requests None

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SCA 09 - Core Controls and Processes - Environmental Protection The environmental protection SCA covers programs that identify, control and monitor all releases of radioactive and hazardous substances and effects on the environment from facilities or as the result of licensed activities. This SCA looks at:    

Effluent and Emissions Control (releases) Environmental Management System Assessment and Monitoring Protection of the Public

Relevance and Management Bruce Power Environmental Safety Management program and procedures are designed to comply with all relevant environmental legislation, regulations, and other requirements. Bruce Power adopts applicable best industry standards as a framework for achieving continual improvement and sustainable performance excellence, while minimizing our environmental impact and preventing pollution. The first edition of CSA N288.5, Effluent monitoring programs at Class 1 nuclear facilities and uranium mines and mills was issued April 2011. This standard is part of a series of guidelines and standards on environmental management of nuclear facilities. Bruce Power recently adopted CSA N288.5, and is currently working towards the implementation of CSA standards N288.4-10 and N288.6-12. Bruce Power complies with the Environmental Compliance Approvals and Permits issued by the Ontario Ministry of Environment and complies with the Federal Regulations and programs which protect human health and the environment under the Canadian Environmental Protection Act. The Bruce Power Environment Management System (EMS) has been registered to the IS0 14001: 2004 standard and has been implemented at all Bruce Power facilities. An audit by the registrar (Quality Management Institute - QMI) resulted in successful re-registration to the standard in December 2012; the next re-registration audit is scheduled for October 2013. The Bruce Power EMS is described in Bruce Power’s Environmental Safety Management Program which has been designed to meet the requirements of CNSC Regulatory Standard S-296 Environmental Protection Policies, Programs and Procedures at Class I Nuclear Facilities and Uranium Mines and Mills. Environmental spill risk assessments are conducted as part of Spill Management and Contaminated Lands program. Risks are assessed based on probability, chemical characteristics, size of release, access to the environment, impact on environment and operations and documented. Higher risk activities, which are reviewed annually, are documented in each stations spill plan with mitigation factors to minimize risk. Bruce Power conducts live exercises/spill drills annually as part of Bruce Power’s Emergency Management activities. If an event were to occur, Bruce Power notifies and assists the Province and Municipality to ensure public safety.

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Past Performance Tritium in Air - Bruce A and Bruce B show similar long term trends with regard to tritium in air emissions. Both facilities showed past increasing trends with recent decreasing trends which can be attributed to maintenance and refurbishment initiatives (Figure 43 below). 1.4E+15 Bruce A Bruce B 1.2E+15

Bq/year

1E+15

8E+14

6E+14

4E+14

2E+14

0 12 20

11 20

10 20

09 20

08 20

07 20

06 20

05 20

04 20

03 20

02 20

01 20

Year

Figure 43 Historical Tritium Emissions in Air Note: Bruce A Units in Lay-up 2000-2004, Bruce A Units 3 & 4 in Operation 2004-present, Bruce A Units All in operation 2012 to present.

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Tritium in Water - Bruce A shows a long term stable trend with regard to tritium releases in water. Bruce B shows tritium releases in 2003, 2007 and 2012 associated with steam generator tube leaks (Figure 44 below). These emissions remain well below the Derived Release Limit (DRL). 1.2E+15 Bruce A  Bruce B  1E+15

Bq/year

8E+14

6E+14

4E+14

2E+14

0 12 20

11 20

10 20

09 20

08 20

07 20

06 20

05 20

04 20

03 20

02 20

01 20

Year

Figure 44 Historical Tritium Emission in Water Note: Bruce A Units in Lay-up 2000 2004, Bruce A Units 3 & 4 in Operation 2004 present, Bruce A Units All in operation 2012 to present.

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Carbon (C14) emissions in air have been stable at Bruce A over the long term. Bruce B shows increasing C14 air emissions peaking in 2006 with a decreasing trend in recent years. This is a result of an increased focus on ion exchange resin (IX) management and reduction of cover gas purging. C14 water emissions have generally declined over time (Figure 45). Figure 46 details the historical trend in C14 emissions in air and Figure 4 details the historical trend in C14 emissions in water. C14 in air and water is a radiological emission associated with dose to the public.

1E+13

8E+12 Bruce A Bq/year

Bruce B 6E+12

4E+12

2E+12

0 12 20

11 20

10 20

09 20

08 20

07 20

06 20

05 20

04 20

03 20

02 20

01 20

Year

Figure 45 Historical Carbon-14 (C14) Emission in Air Note: Bruce A Units in Lay-up 2000 2004, Bruce A Units 3 & 4 in Operation 2004 present, Bruce A Units All in operation 2012 to present.

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10000000000

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Figure 46 Historical Carbon-14 (C14) Emission in Water Note: Bruce A Units in Lay-up 2000 2004, Bruce A Units 3 & 4 in Operation 2004 present, Bruce A Units All in operation 2012 to present.

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2.50E+08 Bruce A

Bruce B

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Figure 47 Historical Iodine Emission in Air Note: Bruce A Units in Lay-up 2000 2004, Bruce A Units 3 & 4 in Operation 2004 present, Bruce A Units All in operation 2012 to present. Future Plans Derived Release Limits and Environmental Action Levels have been reviewed, and revised and approved by CNSC staff. Work is in progress to amend the current licences for Bruce A and Bruce B. Challenges None Requests None

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SCA 10 - Core Controls and Processes - Emergency Management and Fire Protection The emergency management and fire protection SCA covers emergency plans and emergency preparedness programs that exist for emergencies and for non-routine conditions including any results of exercise participation. This also includes conventional emergency and fire response. This SCA includes the fire response rating while fire protection operations, design and analysis are discussed and rated in the appropriate SCA of operating performance, safety analysis or physical design. Emergency management and fire protection includes:   

Conventional Emergency Preparedness and Response Nuclear Emergency Preparedness and Response Fire Emergency Preparedness and Response

Relevance and Management Bruce Power has established and maintains an Emergency Management Program designed to ensure that Bruce Power manages the consequences of events, such as spills and releases, which have the potential to impact on employee, public and environmental safety and the continuity Bruce Power’s business operations. The program also identifies the processes and response mechanisms in place to support planning, reporting, providing assistance and testing of plans. Nuclear safety is the paramount consideration guiding all decisions and actions. This program also manages the fundamental business need, functional requirements, constituent elements and key responsibilities associated with the management of fire safety. The Emergency Management Program describes the preparedness and response plan elements and provides a list and description of the plans issued to mitigate the consequences of identified hazards. It identifies the strategic objectives that each plan issued to implement the Emergency Measures Program shall include as well as requirements for: 

Communication to applicable stake holders (employees, public, regulatory agencies) as appropriate”.



Establishment of Response organizations.



Establishment of response facilities and equipment.



Evaluations of Program Effectiveness.

The Program also identifies the off site authorities with whom Bruce Power must notify and/or interface, Bruce Power’s emergency response organization and Bruce Power’s emergency facilities that are implemented post-accident to deal with the effects of an accidental release. Essential to Bruce Power’s emergency response are the three key emergency response plans. They are: 

BP-PLAN-00001, Bruce Power Emergency Plan addresses the response required to minimize the impacts of radiological hazards and their associated risk to safety (employee, public and environment) from operating incidents and reactor accidents.

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BP-PLAN-00005, Radioactive Material Transportation Emergency Response Plan, address the response required to minimize the impacts of radiological hazards and their associated risk to safety (employee, public and environment) from transpiration accidents involving radioactive substances.



BP-PLAN-00006, Conventional Emergency Plan addresses the response required associated risk to safety (employee, public and environment) from the non-radiological hazards.

In addition to these plans, procedures are in place and are used to provide direction for the response to situations and events in the following areas:      

Event Response and Reporting Spills to the Environment Radioactive Liquid Emissions Response Shift Emergency Controller Procedure Emergency Recovery Director Emergency Preparedness Drills and Exercises

The Emergency and Protective Services (EPS) – Fire process supports the foregoing plans in its management of radiation releases to the environment by regularly testing the skills of the EPS-Fire members. In conjunction with the Emergency Preparedness Organization, the EPS-Fire personnel are evaluated in the following elements while responding to potential radiation releases:         

Selection and use of the appropriate PPE Evaluation of radiation hazards at an emergency medical scene Control of contamination at the source Establishment of a Contaminated Casualty Treatment Area Decontamination of a patient when required Transportation of a contaminated patient to the hospital Management of a contaminated patient while at the hospital In Plant Survey Team actions Source Term Survey Team actions

Upon completion of the evaluated drills, de-briefings are conducted. Lessons learned are added to an EPS-Fire OPEX database and reviewed with all EPS-Fire members. Official Drill Reports are prepared and filed for future reference. Other processes are in place to provide response to situations that involve increased level of radiation in the public domain resulting from events, including beyond design basis accidents. Past Performance Emergency Response and Fire Protection performance has been favorable over the licensing period. Enhancements made during this period have been focused on use of OPEX as well as minor improvement findings that become apparent during drills and exercises. More recent efforts have been made on implementing the CNSC Post Fukushima Recommendations. Training and drills to support the deployment of Emergency Mitigating Equipment have been conducted and will continue into the future. All response aspects will be tested over a 5-year period based on a drill and test plan.

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Following testing and validation during the Huron Challenge IV Exercise in 2012, Bruce Power has opted to re-organize the Emergency Response Organization implementing the Incident Management System Command Structure. Emergency response duties have been redistributed with clear lines of accountability and meeting operational goals as described in the plan. Further analysis of the approach to staffing was conducted during the October 2013 Corporate Exercise and as part of the 5-year drill/exercise and training programs that are currently being developed. This was a CNSC observed drill aimed at final verification of the new emergency response plan. CNSC staff conducted an inspection of the Industrial Fire Brigade’s performance during May 2013 and concluded, from observation of the drills and the fire response capability of the Bruce Power Industrial Fire Brigade, that Bruce Power satisfied the current licence conditions. CNSC provided a positive observation that for the exercises observed the response was structured and had a good systematic flow. It was further stated that the responses followed a systematic approach and used fire fighting benchmarks/objectives to ensure the responses were effective and expedient. Huron Challenge Huron Challenge was a four-day, full-scale emergency exercise conducted in 2012 by Emergency Management Ontario that became the largest of its kind in Ontario history emergency. Bruce Power played a major role in developing, supporting and participating in the exercise. Huron Challenge was a success for Bruce Power and the nuclear industry at a time when public confidence in nuclear technology had been shaken by events at home and abroad. Sensational media images of the Fukushima incident in 2011 had eroded faith in the nuclear industry’s safety record after 25 years of continuous improvement following Chernobyl. Five months later, nervousness within our own community rose after a tornado tore through Goderich Ontario, a neighboring community. It was against this backdrop that Huron Challenge was designed and delivered as a series of workshops and training events over 12 months, culminating in October of 2012 with a four-day, full-scale emergency exercise. Its primary objectives were to: 1.

Reassure our employees, neighbours, regulators and investors that we can work with our communities, external emergency response agencies and governments to respond to any natural disaster that may descend upon our site and the counties around us.

2.

Highlight areas for improvement within our Emergency Response Organization.

3.

Strengthen our social license to operate the world’s largest nuclear generating facility by publicly demonstrating post-Fukushima improvements to our plants and emergency response organization. This included: 

Deploying newly-developed Emergency Mitigation Equipment such as fire pumpers and portable generators to keep our fuel cool and stations powered in the event of a total loss of electricity.

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Building a state-of-the-art Emergency Management Centre and unifying our aging Site Management and Corporate Emergency Support Centres into a single, modern command centre.



Adopting the Incident Management System (IMS) as the best practice for emergency response to ensure we respond to all hazards with the same level of expertise we currently apply to radiological emergencies.



Test new situational awareness tools, as well as vital, backup communication links with the stations such as satellite phones and radios.

Huron Challenge was a success on all fronts despite some trials including timing. For instance, the Bruce A Restart schedule saw Unit 2 synchronize to the provincial grid right in the midst of Huron Challenge IV. With station staff at Bruce A properly focused on safely returning the unit to service, exercise activities were amended to ensure Huron Challenge proceeded successfully without disruption to Restart or Operations. Construction of the Emergency Management Centre was also a challenge in terms of time and budget. Training for the two EMC teams was conducted in make-shift command centers and boardrooms throughout the year. They were afforded only one opportunity to train in the EMC ahead of Huron Challenge itself and conducted themselves with professionalism and commitment under the dual spotlight of public scrutiny and internal expectations. With more than 1,000 participants from nearly 70 separate agencies and all levels of government, the final exercise grew larger than originally anticipated by either Bruce Power or Emergency Management Ontario, which served as the lead for the series. External attention grew in the final weeks of exercise planning. Roughly 20 additional agencies signed on as participants in October alone and 20 members of the media and 30 observers from across the industry converged on the region for Huron Challenge IV to analyze our preparations and critique our response. They left impressed and requests for assistance have since come in from organizations such as INPO, OPG and EDF-British Energy, all of whom will be conducting similar exercises. Future Plans Implementing the Incident Management System and use of a new Emergency Management Centre has been the focus over 2013. Normalizing and fully institutionalizing these improvements will be the focus for 2014. Challenges A commitment to implement the Incident Management System and commission the new Emergency Management facility to support an all hazards approach to response is underway. A new Training regiment to support this and Emergency Mitigating Equipment deployment is ongoing. A corporate drill was completed in October to test Command, Control and Coordination between the new EMC and the station Emergency Operations Centre with full implementation of the new emergency response plan planned for Q4 2013. Requests None

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SCA 11 - Core Controls and Processes - Waste Management The waste management SCA covers internal waste-related programs that form part of the facility’s operations up to the point where the waste is removed from the facility to a separate waste management facility. Topics covered on waste management include:     

3.11.1

Waste Management Waste Characterization Waste Minimization Waste Management Practices Decommissioning Plans

Waste Management, Characterization, Minimization and Management Practices Relevance and Management The Bruce Power environment policy reflects the company’s commitment to the environment and is in line with the principles set forth in ISO 14001 Environmental Management standard. One of the environmental policy commitments is on pollution prevention which includes responsible management of waste. Waste at Bruce Power can be categorized in these broad areas: hazardous waste, conventional waste, recyclables, and radioactive waste. Bruce Power programs define the elements of waste characterization, waste minimization, and waste management practices in order to meet regulatory requirements and environmental policy commitments. Waste characterization allows Bruce Power to determine the characteristics of the subject waste in order to properly identify the waste stream where it belongs; thereby allowing the disposition of each waste stream in terms of handling, storage, and eventual transportation to an appropriate waste management facility. By characterizing waste, Bruce Power is able to comply with applicable regulations, protect staff, contractors, and members of the public by ensuring that the subject waste enters the proper pathway for management. To further illustrate, Chemical Waste Management Operating Manuals are in place to define the requirements and process of waste characterization. Sampling and analysis is performed on site in order to determine radiological characteristics and where needed, an external laboratory is utilized for further chemical characterization. Waste minimization allows Bruce Power to minimize waste produced in the various waste streams; thereby minimizing the volume or mass of the waste being sent to the various waste management facilities. By minimizing the amount of waste produced and where in the process they are produced, Bruce Power is able to comply with applicable regulations, to conserve valuable space at the end of the disposal chain (i.e., landfills, radioactive waste management facilities, hazardous waste management facilities), conserve on processing and transportation requirements, reduce the potential amount that cross over radiological zones in the station, reduce exposure of staff, contractors, and members of the public in the total lifecycle of the subject waste. To further illustrate, recycling and composting programs and procedures are in place to minimize materials sent to landfill and to meet the requirements of waste regulations; a procedure is in place to define the requirements of removal of packaging materials prior to entering protected areas and zones, thus reducing the potential for radioactive waste generation that could arise from disposal of packaging materials; oil water separators are utilized to reduce liquid industrial waste.

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Waste management practices are aligned with regulatory requirements with respect to sampling, storing, characterizing, handling, shipping of waste to an approved waste management facility. Best practice requirements are also employed. Bruce Power utilizes licensed carriers and licensed disposal facilities when shipping waste offsite. Furthermore, Bruce Power has licensed PCB waste storage facilities on site, located at Bruce A and Centre of Site. Bruce Power takes measures to meet regulatory compliance in the above mentioned areas. Measures taken to meet regulatory compliance requirements include: keep up to date with current regulations and requirements, the use of action tracking to track regulatory commitments, training of staff to various requirements, procedures and processes in place and updated as needed, waste pick up schedule defined, field inspections conducted, internal and external audits conducted, the use of performance indicators to measure performance, oversight forums established. Past Performance A CNSC Type II Inspection on Hazardous Waste Management at Bruce A and Bruce B was conducted in September 2013. The objective of the inspection was to verify that Bruce Power’s Waste Management program is maintained in accordance with licence requirements. The Preliminary Summary of Findings was provided following the inspection in September of 2013. It identified both programs strengths and areas requiring improvement. There were no significant issues identified. All follow-up actions have been completed. Highlights over the past five years include: 

Bruce Power has complied with the submission of all yearly, monthly, and as required regulatory reports.



Bruce Power has complied with conducting yearly external audits.



Bruce Power has complied with conducting once every three year audits for this program area as established.



Monthly Inspections of chemical waste and PCB waste storage areas are completed as scheduled.



A gap has been identified with respect to 90-day waste storage notifications. An increasing trend has been identified in this area and steps have been taken in 2013 to reverse the trend. Additional actions are detailed under future plans.



Waste process revision took place to reflect changes to Ministry of Environment documentation in 2011.



Organizational change in 2013: Hazardous and conventional waste function transitioned from Site Services, Safety and Environment to Environment Programs Department in order to consolidate and align environmental resources in the management of waste.



Bruce Power had applied and was granted an extension to the PCB Regulations December 31, 2009 End of Use requirement for equipment containing 500 mg/kg or more of PCBs. Under a multi-year Project, Bruce Power has removed all such PCB containing equipment one year ahead of the extension permitted by the regulations.

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Future Plans 

Improving performance and focus on internal process components with hazardous waste management by defining in further detail each process step/task and then allocating specific goals and targets (timelines, number of packages, accountable groups) at each step of the process.



Developing and implementing proactive performance indicators for hazardous waste and other waste streams with a focus on collecting information on volumes, weights, number of packages with the intent to quantify the waste streams in order to quantify performance improvements.



Improving use of compliance indicators for regulatory requirements and compliance indicators for internal requirements



Investigating, developing and implementing waste diversion alternatives.



Developing and implementing quantitative waste reduction, waste diversion goals.

Challenges None Requests None 3.11.2

Decommissioning Plans In the Record of Proceedings referenced below, the scope of Ontario Power Generation’s financial guarantee includes decommissioning activities related to Bruce A and Bruce B, financial guarantee liability for decommissioning and lifecycle management of all used fuel and low and intermediate level waste produced by Bruce A and Bruce B. Bruce Power's position is that no licence conditions related to decommissioning are required under the Bruce A and Bruce B Class 1 facility licences except for a requirement to inform the Commission of any change in the lease arrangement with OPG. Reference: CNSC Record of Proceedings, Including Reasons for Decision, in the Matter of Ontario Power Generation Inc. Subject: Financial Guarantee and Licence Amendment for OPG’s Class 1 Nuclear Facility Licences in Ontario. October 24, 2012.

3.12

SCA 12 - Core Controls and Processes - Security The security SCA covers the programs required to implement and support the security requirements stipulated in the regulations, the station operating licence, in orders, or in regulatory expectations for the facility or activity. This SCA includes:    

Facilities and Equipment Response Arrangements Security Practices Drills and Exercises

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Security (General) Relevance and Management The Nuclear Security program defines the overall business need, functional requirements, constituent elements and key responsibilities associated with providing a World Class Nuclear Utility Protection Service in accordance with the Nuclear Safety and Control Act (NSCA), applicable regulations and other Canadian Nuclear Safety Commission (CNSC) requirements and expectations. The Nuclear Security Program supports Bruce Power’s fundamental nuclear safety objective to protect the public, site personnel and the environment from harm, by establishing and maintaining effective security defenses against malicious and malevolent acts. The core business is the protection of nuclear materials, company assets, employees and the public from malicious and malevolent acts by establishing proactive “best in business” security processes that ensure business and operating objectives are achieved within a framework where safety of the reactors is the paramount objective. This framework is built on Bruce Power’s fundamental safety culture principles:    

Reactor safety. Industrial safety. Environmental safety. Radiological safety.

Past Performance The Bruce Power security program has met all regulatory requirements throughout the current operating licence period. Bruce Power has received a Fully Satisfactory rating for Security in the annual CNSC Nuclear Power Industry Safety Performance Report for 2011 and 2012. This rating is based on a combination of factors including the implementation of the Nuclear Security program as assessed through CNSC inspections, CNSC Performance Testing Program and reports submitted to the CNSC on a scheduled and unscheduled basis. During this period the CNSC has conducted several Type I and Type II Security Compliance Inspections which covered the following focus areas: 

Physical barriers and associated security systems



Assessment, detection, response and delay system interfaces



Condition of the protected area barrier fence and unobstructed area



Security screening for weapons and explosive substances prior to entering and screening for nuclear material on exit from the Protected Area



Access control



Security facilities and equipment



Training, drills and exercises

BRUCE POWER – PERFORMANCE REVIEW OF BRUCE A AND BRUCE B 

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Special equipment and Nuclear Response Force arrangements

Future Plans The Bruce Power Nuclear Security program will continue to operate at a high standard and meet the CNSC licensing requirements. The existing infrastructure and processes in place at Bruce Power currently satisfy the regulatory requirements, with areas for improvement identified. Infrastructure upgrades and other improvement initiatives are currently in progress to enhance physical protection systems performance in the areas identified for improvement. Details of these improvements and progress reports are communicated quarterly to the CNSC through security-protected formal correspondence under Regulatory Standard S-99, Reporting Requirements for Operating Nuclear Power Plants s. 6.4.3 Quarterly Security Reports. Challenges As the site infrastructure ages and new regulatory requirements are introduced, Bruce Power must strategize infrastructure upgrades and program improvements on a risk-based priority order. Bruce Power manages these challenges through performance testing, systems health monitoring and business planning. Requests The modifications proposed under the licence condition for the security program are the addition of two CNSC regulatory documents: 

RD-321: Criteria for Physical Protection Systems and Devices at High-Security Sites



RD-361: Criteria for Explosive Substance Detection, X-ray Imaging, and Metal Detection Devices at High-Security Sites

Bruce Power has conducted assessments to identify gaps with respect to both regulatory documents. The existing infrastructure and processes in place at Bruce Power currently satisfy the regulatory requirements, with areas for improvement identified. Infrastructure upgrades are in progress to enhance the areas identified for improvement. Details of these improvements and progress reports are communicated quarterly to the CNSC through security-protected formal correspondence under Regulatory Standard S-99, Reporting Requirements for Operating Nuclear Power Plants s. 6.4.3 Quarterly Security Reports. 3.12.2

Security - Facilities & Equipment Relevance and Management The Bruce Power site is protected by a series of defense-in-depth security measures starting at the outer boundary of the site property. The first layer of defense is at the controlled area access check points where all personnel entering the Bruce Power site are verified to have a legitimate business need prior to accessing the site property.

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Bruce Power has invested in a world-class main security check-point facility which enables officers to perform best in business security practices. Secondary access points also include security check-points which operate on a scheduled basis to support the station’s operational needs during peak periods. The Bruce Nuclear Generating Stations are surrounded by two security fences equipped with intrusion detection systems designed to detect any attempt at unauthorized intrusion into the protected area or any tampering or component failures that could cause a system malfunction. The protected area outer security perimeter is further surrounded by physical protection measures to mitigate forced land and / or marine vehicle penetration of the protected area. Beyond the perimeter fences, the exterior powerhouse doors are equipped with locking systems to prevent and delay unauthorized access. Searches are performed on all personnel and vehicles, including all packages and equipment entering the protected area for weapons and explosive substances using security search systems and equipment and searches as required. Dedicated security search equipment at Bruce A and Bruce B includes walk-through explosive detectors, walk-through and hand-held metal detectors and x-ray machines. Access to the protected area is controlled by a combination of physical, administrative and logical systems, including proximity cards and biometric hand geometry readers which are used to verify the identity of every person entering to ensure that all personnel accessing the protected area have a valid security clearance. All personnel exiting the protected area must be searched for category I, II, III nuclear material through portal monitors at the protected area exit. Lock-down controls on the turnstiles are used to prevent any person from exiting the protected area if portal monitors alarm. Hand-held radiation monitors are used by Security to perform search of vehicles exiting the protected area for category I, II, III nuclear material. In addition to static security facilities and equipment, Bruce Power is also patrolled by armed Nuclear Response Team members on a 24/7 basis using a variety of light armored vehicles, duty patrol vehicles and associated security equipment. Past Performance During the current licence period Bruce Power has continued to improve the security program through facility and infrastructure upgrades, equipment replacement and introducing new equipment, including:            

Camera system (2010) Protected area fence (2011) Back-up communications (2011) Firearms storage equipment (2012) High-security locks on perimeter doors(2012) Winter all terrain vehicles (2012) On-site pistol range (2012) Patrol Vehicles (2012) Ballistic personal protective equipment (2013) Security Monitoring Room (2013) Light Armoured Vehicles (2013) Security screening equipment improvements (2013)

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Challenges Bruce Power relies on station staff for the effective operation of high-security locks on the powerhouse perimeter doors. Bruce Power is working to improve station staff awareness regarding the purpose and operation of powerhouse doors to reinforce correct use and reporting of system deficiencies and misuse. Requests None 3.12.3

Security – Response Arrangements Bruce Power has established off-site response arrangements with the Ontario Provincial Police through a Memorandum of Understanding. During the current licence period, Bruce Power has been working closely with the Ontario Provincial Police to improve the effectiveness of the exercise program and to integrate the off-site response force into smaller-scale drill activities.

3.12.4

Security Practices Relevance and Management Security practices are also designed using a defense-in-depth approach. The first layer of defense is the Site Access Security Clearance program which requires all personnel working at Bruce Power site to be security cleared. Non-security cleared visitors must be sponsored by a security cleared site employee. All personnel accessing the Bruce Power site are required to show identification to confirm security clearance and validate business need prior to entering the property. Personnel and visitors who do not have valid site identification are required to have a site sponsor and must register with Security to record the business need for entering site. All delivery vehicles and visitor vehicles are searched at the main security check-point prior to being granted access to the site property. At the protected area access points, security search practices are based on an “alarm-free” policy which requires nuclear security officers to fully investigate and identify the cause of any alarm prior to granting access to the protected area. Access control processes for non-security cleared visitors entering the protected area includes verification of the business-need for all visitors and the assignment of security escort duties to an appropriately qualified security-cleared site employee while the visitor is in the protected area. The protected areas are continuously patrolled by an armed Nuclear Response Team consisting of an adequate number of fully trained and qualified members to effectively intervene and defend against the Design Basis Threat. Nuclear Response Team members are required to meet conditions set out in the Nuclear Security Regulations, RD-363 Nuclear Security Officer Medical, Physical and Psychological Fitness, and S-298 Nuclear Response Force Standard, for authorization as an Nuclear Response Team member.

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Past Performance In 2009 Bruce Power conducted an internal Quality Assurance Audit on the Nuclear Security Program with a focus on processes and practices. A corrective action plan was developed to address audit findings by implementing security procedural and documentation improvements to ensure processes and practices are aligned. Challenges None Requests None 3.12.5

Drills & Exercises Relevance and Management Security drills are performed by shift crews on a monthly basis to test the operation of one or more of the physical protection measures and the readiness of the Nuclear Response Team members. A series of drill scenarios are provided to the shift crews to utilize for the monthly drill program. First Line Managers are provided latitude to modify the scenario to introduce realism and new challenges to the security team. Large scale security exercises are performed at least once every two years, in consultation with the CNSC, to test the effectiveness of the site security contingency plan and the physical protection system. Exercises are performed as part of the CNSC evaluated Performance Testing Program. Details of the drills and exercises, facilities and equipment, security practices, and the response arrangements with the Ontario Provincial Police are provided in the Security Program Descriptions for Bruce A and Bruce B, which were submitted through separate security-protected correspondence. Past Performance During the current licence period, the CNSC also evaluated the integrated response capabilities of the Nuclear Response Team and the effectiveness of physical protection systems against adversaries equipped within the Design Basis Threat through the Performance Testing Program. These evaluations were successfully conducted at Bruce Power in 2008, 2010, and 2012. The CNSC has recognized Bruce Power’s progress in evolving the Performance Testing Program by introducing elements of realism and challenge to the exercises performed. Challenges None Requests None

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SCA 13 - Core Controls and Processes - Safeguards The safeguards SCA covers the programs required for the successful implementation of the obligations arising from the Canada/IAEA Safeguards Agreement and the Treaty on the Non-proliferation of Nuclear Weapons. The SCA includes:     

Nuclear Material Accountability and Control Access and Assistance to the IAEA Operation and Design Information Safeguards Equipment, Containment and Surveillance Import and Export

Relevance and Management Bruce Power’s Safeguards program is met by complying with applicable regulations and the station licence conditions, in accordance with the following: 

INFCIRC/164(a1) Agreement between Canada and the IAEA on application of Safeguards in connection with the Treaty on the Non Proliferation of Nuclear Weapons (NPT).



Regulatory Document RD-336 Accounting and Reporting of Nuclear Material.



Regulatory Standard S-99 Reporting Requirements for Operating Nuclear Power Plants.



The relevant sections of the General Nuclear Safety and Control Regulations.

Bruce Power fulfils these obligations by the implementation of the Fuel Management program and supporting procedures, manuals, reports and documentation. Key safeguards deliverables include: 

Provision of reports and information regarding nuclear materials and activities.



Support of IAEA inspector access to site facilities.



Provision of assistance and safety services to IAEA inspectors to enable verification activities.



Accommodate servicing and installation of IAEA equipment.



Prevention of damage to Safeguards equipment or interference with its operation.

Past Performance Bruce Power continues to maintain and foster open communications with the IAEA on safeguards issues, and has a good working relationship and excellent cooperation. Bruce Power has remained fully compliant with all Safeguards licence conditions and IAEA requirements.

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Future Plans Bruce Power has supported IAEA for an upgrade of the core discharge monitor detectors in the reactor vault for seven of the eight Units, and the primary bay bundle counters have been replaced at Bruce A during the current licence period. Challenges None Requests None 3.14

SCA 14 - Core Controls and Processes - Packaging and Transport The packaging and transport SCA covers the safe packaging and transport of nuclear substances and radiation devices to and from the licensed facility. This SCA includes:   

Package Design and Maintenance Packaging and Transport Registration for Use

Relevance and Management As part of Bruce Power’s Radiation Protection program, procedures are employed to define the requirements to ensure radioactive material is moved in a safe and efficient manner and in accordance with all federal regulations and includes the requirements for movement of radioactive material onsite between Bruce Power and Ontario Power Generation Licensed Facilities and offsite to other CNSC Licensed Facilities. The following elements have been established and describe the process framework employed by Bruce Power to manage radioactive material transportation:      

Worker Selection and Training Classification of Material for Transport Selection and Use of Shipping/Transfer Packages Movement of Radioactive Material for Transport Transport Events and Emergency Response Oversight and Inspection

Past Performance The transport program is a mature process that is periodically reviewed to ensure continuous improvement is maintained. There have been minor enhancements to the transport program including improved training material, periodic program reviews and upgrades which have resulted in no major findings for all the CNSC inspections within the licensed period.

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Future Plans A new procedure addressing radioactive material container life cycle management is being developed to enhance the processes already described in existing processes regarding obtaining, certifying and using certified containers. Challenges None Requests None 4.0

OTHER MATTERS OF REGULATORY INTEREST

4.1

Environmental Assessment There are no Environmental Assessments associated with Bruce Power’s applications to renew the Power Reactor Operating Licences for Bruce A and Bruce B.

4.2

Aboriginal Consultation Bruce Power has a very active and engaged Aboriginal Program (see Figure 48 below). Bruce Power has three signed Aboriginal Relations documents that describe the interactions with the three primary Aboriginal communities whose territories our operation may impact. These are; 1. 2. 3.

The Historic Saugeen Métis (HSM) signed in 2009 The Saugeen Ojibway Nation (SON) signed in 2011 The Métis Nation of Ontario (MNO) signed in 2012

These legal agreements, in broad terms, describe how Bruce Power will deal with regulatory items and discuss other matters of interest such as employment and economic development. Further, the quarterly meetings allow Bruce Power to update communities on operational activities, sponsorship activities and any environmental projects that Bruce Power may be undertaking. In particular, Bruce Power is in the second year of the BP-SON whitefish project. Bruce Power is also a Patron level member of the Canadian Council for Aboriginal Business (CCAB) and as such supports and promotes the ideals associated with that National organization. In 2012 Bruce Power was recognized by the CCAB’s Progressive Aboriginal Relations Program (PAR) as a SILVER level member. We are one of only seven (7) companies achieving that level of recognition in Canada. Bruce Power is actively and directly engaged in various Aboriginal community activities and many are specifically aimed at promoting Aboriginal education and youth development. Some of the best examples of this include entering the third year of direct support to the Chippewas of Nawash Unceded First Nation and the Chippewas of Saugeen First Nation in the Right To Play program. This program involves a three way commitment involving the communities, the Minister of Aboriginal Affairs (Ontario), Right To Play and Bruce Power. Youth development and leadership skills enhancement are provided through the use of play as the medium. With Bruce Power and its partners entering year three of the program, it is a solid indication of how successful the communities and its partners feel this is.

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Other areas of Bruce Power’s Aboriginal sponsorship program have assisted with First Nations Charity golf tournaments, Pow wow’s, assisting Fire Departments with purchasing needed equipment to name just a few. In 2012, as part of upgrading Bruce Power’s emergency response capabilities post Fukushima, a donation of high quality fire trucks was made to both First Nation communities. Finally, another key element to Bruce Power’s Aboriginal relations program is the fact that we have developed an Aboriginal Affairs Working Group (AAWG). This group meets quarterly and is made up of members from all functions of the company. The group reports monthly to the Executive Team (ET) on a series of Actions developed explicitly to progress the Aboriginal program externally and internally. Future Plans By using Bruce Power’s Action Plans to guide the Aboriginal Program on an annual basis, Bruce Power is confident the measured success will be evident in the CCAB PAR assessments every few years. Reaching a SILVER level designation in a matter of a few short years is a testament to achievements made and indicates a bright future. Equally, by continuing to directly engage Aboriginal peoples and community leadership through regular visits and quarterly Council meetings Bruce Power is confident it will receive positive responses regarding the strength of the relationship. In terms of this current licence renewal application, Bruce Power has directly spoken to all three primary Aboriginal communities about Bruce Power’s applications and associated submissions.

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Figure 48 Aboriginal Affairs Program

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Other Consultation Relevance and Management Bruce Power adheres to CNSC Regulatory Document RD/GD-99.3 Public Information and Disclosure through its public information program which reflects the company’s five core values: Safety First, Professional and Personal Integrity, Respect and Recognition, Passion for Excellence, and Social Responsibility. The program is delivered through Bruce Power’s Corporate Affairs Division which includes the following functions: Community and Government Relations, Community Investment and Sponsorship, Aboriginal Relations, Investor and Media Relations, Employee Communications, and Environmental Stewardship. Primary communication vehicles include online mediums such as the corporate website and social media (Twitter, Facebook and YouTube), the quarterly ‘Community Update’ print publication, a public Visitors’ Centre, frequent media releases, stakeholder briefings, tours and mailings, sponsorship presentations, open houses and community events. Detailed information is listed in the annual Bruce Power Corporate Affairs Report ‘Communicating with our Communities.’ In addition, Bruce Power acknowledges that its employees have a strong voice in the community and serve as ambassadors for the company and the nuclear industry. Bruce Power goes to great lengths to keep employees informed and engaged through employee communications vehicles that include newsletters, an Intranet website, electronic information screens, monthly ‘Safety and Business Performance’ videos, and quarterly ‘Team Talks’. Bruce Power’s Stakeholder Information Program ensures consistent standards and procedures for all public disclosure of both material and non material information. Past Performance Bruce Power strives for continuous improvement in regard to its public information program. Specific improvements since 2009 include enhancements to the corporate website, the addition of social media accounts (Twitter, FaceBook and YouTube), and Visitors’ Centre exhibit upgrades with extended hours of operation to include Saturdays in July and August. In addition, a Bruce Power app was added to the list of communications vehicles in 2013 to enhance communications for iPad and iPhone users. A detailed list of communications is provided in the annual Bruce Power Corporate Affairs Report ‘Communicating with Our Communities. Future Plans Bruce Power’s Corporate Affairs Division continues to monitor new approaches to communications through peer groups and the International Association of Business Communicators. In September 2013, the division hosted a corporate communications evaluator from the World Association of Nuclear Operators to assess, benchmark and improve performance through mutual support, exchange of information and the emulation of best practices. Bruce Power will use the results of the evaluation when they are presented to continue to improve its public information program.

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Challenges None Requests None 4.4

Long Term Operation Relevance and Management Bruce Power is committed to the implementation of a Periodic Application of Integrated Safety Review (PAISR) process in support of long term operation of Units 1 through 8, with the first full PAISR submission planned for no later than 2019. Bruce Power is currently using a Periodic Safety Review methodology based on IAEA Safety Guide SSG-25, “Periodic Safety Review of Nuclear Power Plants” to support operation of the reactor units over the next licensing period. As part of an Asset Management Initiative under way since 2009 we have been completing the plant condition assessments necessary to support this work. In support of the renewal process for nuclear power reactor operating licences for Bruce A and Bruce B, safety significant elements of a full IAEA based Periodic Safety Review are being assessed and compiled, along with a Safety Basis Report covering a minimum five year time period. The Safety Basis Report will demonstrate the continuing safety case for operation of Units 1 to 8 until 2019 while the comprehensive PAISR methodology is developed and the full set of safety factor assessments completed. The deliverables which will be submitted in as supplementary information to the licence application will be organized by Safety Factor. In summary these include: 

Assessment of safety significant elements of Safety Factor Assessments based on IAEA SSG-25:      

Safety Factor #1: Safety Factor #2: Safety Factor #4: Safety Factor #5: Safety Factor #6: Safety Factor #7:

Plant Design Actual Condition of SSCs Ageing Deterministic Safety Analysis Probabilistic Safety Assessment Hazard Analysis



PSR Governance document.



A 2013/14 Periodic Safety Review Basis document.



A Composite Safety Profile (CSP) general methodology and initial content.



A Safety Basis Report (SBR) to 2019.



An Asset Management Integrated Improvement Plan (IIP) to 2019.

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Future Plans As part of the PAISR Initiative, Bruce Power intends to develop an integrated safety basis which will be established and regularly reviewed to identify potential improvements for evaluation. By 2019, Bruce Power will complete: 

A Composite Safety Profile (CSP) will integrate the impact of safety significant issues and demonstrate how this profile changes with time.



A Safety Basis Report (SBR) will demonstrate how safe operation is maintained.



An Integrated Improvement Plan will specify timing of necessary improvements.

The Composite Safety Profile, Safety Basis Report, and the associated Integrated Improvement Plan (IIP) will cover a forward looking five to ten year cycle. Challenges None Requests None