OPG Progress Report No. 3 on CNSC Action Plan Fukushima Action Items

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1 W. M. (Mark) Elliott, P. Eng. Senior Vice-President Nuclear Engineering and Chief Nuclear Engineer 889 Brock Road P82-5A1 Pickering, Ontario L1W 3J2 Telephone: (905) x5418 July 15, 2013 File#: N (P) CD#: N-CORR MR. M. SANTINI Director Pickering Regulatory Program Division MR. F. RINFRET Director Darlington Regulatory Program Division Canadian Nuclear Safety Commission 280 Slater Street Ottawa, Ontario K1P 5S9 Dear Messrs. Santini and Rinfret: OPG Progress Report No. 3 on CNSC Action Plan Fukushima Action Items The purpose of this letter is to provide the CNSC with a third progress report on OPG s activities related to Fukushima Action Items (FAIs), as assigned to OPG in the CNSC s February 17, 2012, letter [1]. This letter is further to: Our first progress report [2, 3] and the subsequent CNSC reply [4], and Our second progress report [5, 6] and the subsequent CNSC reply [7]. In this letter we are requesting FAI closures as presented in Table 1. Further information is provided in the body of this letter and Enclosure 1, Fukushima Action Item Status Report, N-REP R003. We also acknowledge receipt of your letter of June 18, 2013 [8], regarding follow-up Action Items related to closed FAIs. Because these Action Items are generic in nature, they will be managed through the Fukushima Support project. Ontario Power Generation Inc., This document has been produced and distributed for Ontario Power Generation Inc. purposes only. No part of this document may be reproduced, published, converted, or stored in any data retrieval system, or transmitted in any form by any means (electronic, mechanical, photocopying, recording, or otherwise) without the prior written permission of Ontario Power Generation Inc.

2 1.0 Introduction Further to previous correspondence [1-11] on this subject, OPG continues to make significant progress at its facilities to address the lessons learned 1 from the Fukushima Daiichi event. OPG s plans are well-aligned with the CNSC Staff Action Plan [12-13]. The activities undertaken are captured in the Fukushima Action Item Status Report, N-REP , which is updated regularly and which will be OPG s primary means for reporting on our progress in this area. The report is provided as Enclosure Review of OPG Progress on FAIs Implementation and Closure The FAI Status Report (Enclosure 1) presents our progress in completing each of the FAIs in detail. The attached Figure 1 shows OPG s overall progress against the CNSC schedule for FAI closure and clearly demonstrates that OPG s timely efforts to address Fukushima issues has resulted in excellent progress to date. New CNSC Action Items related to closed FAIs [8] are also included in this document. The status of selected OPG activities against their associated FAIs is presented in the next three sections. Table 1 summarizes changes to status and target completion date(s) requested by OPG in this letter. 3.0 FAI Closure Requests Related to Strengthening Defence-in Depth OPG has made significant progress in addressing FAIs in this area and has met CNSC expectations provided in Reference 13 for closure of specific FAIs, as discussed in the subsections listed below. 3.1 If additional (Shield Tank) relief is beneficial and practicable, submit a plan and schedule for provision of additional relief. (FAI 1.2.3). OPG had determined that improvements to the Darlington Shield Tank Relief capability would be part of the Darlington Refurbishment project and FAIs and were closed on that basis (see Enclosure 1 for details). OPG s plan and schedule to provide additional shield tank relief at Darlington is summarized in Enclosure 2. OPG requests closure of FAI for Darlington. No follow-up actions are required for the closure of this FAI. 1 In previous correspondence, OPG actions were aligned with the eight "Lessons Learned" discussed in Reference 10. 2

3 3.2 An evaluation of the potential for hydrogen generation in the IFB area and the need for hydrogen mitigation. (FAI 1.5.1) OPG has completed an assessment under 1.6.1, demonstrating that there is high confidence that the Irradiated Fuel Bays (IFB) at Pickering A will remain filled under an extended loss of IFB cooling event, when crediting IFB coolant make-up strategies. Therefore, H2 production, aside from the normal production from radiolysis, will not occur and H2 mitigation in the IFBs is not required. See Enclosure 3 for further information. OPG requests closure of FAI for Pickering A. No follow-up actions are required for the closure of this FAI. 3.3 An evaluation of the structural response of the IFB structure to temperatures in excess of the design temperature (FAI and 1.6.2) OPG has completed an assessment of the structural integrity of the IFB, and AIFB, as temperature would proceed towards boiling (100 deg C) at Pickering A. It has been determined that potential leakage is well within the mitigation capability of additional water sources, such as portable emergency mitigation equipment (EME). This assessment is attached as Enclosure 4. OPG requests closure of FAI and for Pickering A. No follow-up actions are required for the closure of these FAIs. 3.4 Site-specific implementation plans for RD-310 (FAI 2.2.1) Following a series of meetings with industry and CNSC staff, and submissions to the CNSC under Action Item 2010OPG-05 [14, 15], OPG requested closure of FAI for Darlington, Pickering A and Pickering B in its January 2013 progress report [5]. The CNSC granted closure [7] for Darlington based on the information provided, but deferred closure of this FAI for Pickering A and B pending submission of the detailed RD-310 compliance plan for Pickering. This is discussed under the entry for FAI in the FAI Status Report (Enclosure 1). OPG submitted its detailed plan for Pickering in April 2013 [16] and OPG requests closure of FAI for Pickering A and Pickering B. No FAI follow-up actions are required for closure of these FAIs. All follow-up actions are tracked under Action Item 2010OPG FAI Closure Requests Related to Enhancing Emergency Response OPG has met CNSC expectation provided in Ref. [1] for closure of specific FAIs in this area and all FAIs are now closed [4, 7]. Work continues as outlined in References 2 and 5. However, there are no specific developments in this area to report at this time. 3

4 5.0 Status of Ongoing Fukushima Follow-up Activities Significant progress has been made on several other activities since OPG s last formal report [5] and these are discussed in Enclosure 1. The progress in selected areas is presented below. 5.1 Update to Assessment of Shield Tank Relief Capacity Assessment for Pickering NGS B (FAI 1.2.1, 1.2.2, 1.2.3) CNSC staff closed this FAI [4], based on the assessment provided in Enclosure 2 of Reference 2. This assessment has been updated recently as a result of ongoing work in this area, and is attached as Enclosure 5. Overall conclusions remain unchanged and adequate relief capacity is demonstrated. 5.2 Implementation of Emergency Mitigation Equipment (FAI 1.7.1) Since the January 2013 update [5], OPG has completed the following activities related to the implementation of Emergency Mitigating Equipment (EME) at Pickering and Darlington: Phase 1 EME has been declared in service at both Darlington and Pickering. The completion of this work is summarized in Enclosure 6. Therefore, as discussed under the entry for FAI in Enclosure 1, OPG met its interim completion date for implementing EME to provide cooling water make-up to the boilers and Heat Transport System (HTS). Work to install station modifications to facilitate EME connections is in the design phase with an EPC 2 contract issued for the DNGS water quick connections and another for PNGS, and DNGS is in the process of being awarded to the selected vendor. Work on Phase 2 EME (large generators) to re-power the EPS electrical system (at DNGS and P58) and Class III (at P14) continues. Field deployment of EME was successfully tested during a major drill at Pickering in February Field deployment of EME will be tested during a major drill at Darlington in 2013 (DN EME was tested previously in 2012). See the entry for this FAI in Enclosure 1 for further information. 5.3 Instrument and Equipment Survivability (FAI 1.8.1) As reported in Enclosure 14 of the OPG FAI Progress Report #2 [5], closure of this FAI is being supported by work activities being undertaken through COG Joint Project JP Engineer, Procure, Construct 4

5 COG is providing generic guidance on methodology for equipment and instrumentation survivability assessments. OPG is now preparing specific methodology to be used for the OPG plant assessments, and targets completion of the assessments for late summer Should equipment upgrades be required following the assessments, OPG is on track for completion of a plan and schedule by the Target Completion Date of December An evaluation of the habitability of control facilities under conditions arising from beyond-design-basis and severe accidents. Where applicable, provide a detailed plan and schedule for control facilities upgrades. (FAI 1.9.1) This is a two part FAI and the first part (i.e. the evaluation), has been completed for Darlington as per the interim target completion date (see Enclosure 5 of Reference 5). OPG is reviewing CNSC comments [7] and will reply in its next submission. In parallel, similar studies for Pickering A and Pickering B will be completed in 2013, per the current OPG TCDs. The second part of this FAI for a plan and schedule for upgrades related to habitability will be completed for all OPG stations by Q 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 (FAI and 2.1.2) External hazards have been assessed and submitted to the CNSC as part of OPG s S-294 compliance project and are discussed under the entries for FAI and in the FAI Status Report (Enclosure 1). OPG requested closure of FAI for Pickering A and Pickering B, FAI [5], based on PRA and S-294 compliance work completed at that time. All the required follow-up actions were to be managed under FAI The CNSC declined this request [7] and requested further information to support closure. Discussions with CNSC staff are in progress to clarify the information required. Assessments of seismic events leading to consequential internal flood or internal fire are complete for Darlington and Pickering B, and the Pickering A assessment is ongoing. These are reported under FAI in Enclosure For Multi-unit Stations, Provide Plans and Schedules for the Inclusion of Multi-unit Events in SAMG (FAI 3.1.2) As reported in Enclosure 14 of the OPG FAI Progress Report #2 [5], closure of this FAI is being supported by work activities being undertaken through COG Joint Project JP4426. COG has prepared generic guidance for inclusion of multi-unit events into SAMG and for 5

6 update of the Technical Basis Documents ( Multi-Unit Events Update of SAMG and Technical Basis Documents Enclosure 7). OPG is progressing on the preparation of plans and schedules for the inclusion of multiunit events in SAMGs and is on track for completion by the Target Completion Date of December Demonstration of SAMG Effectiveness via Table-top Exercises and Drills (FAI 3.1.4) SAMG table-top exercises have now been conducted for Darlington, Pickering A and Pickering B 3. Evaluation of these exercises concluded that staff successfully demonstrated a good knowledge of SAMG guidance and adequately responded to the events by recommending and simulating appropriate mitigation activities. Additional SAMG drills and exercises will take place in August and September 2013, and will further support the demonstration of SAMG effectiveness. In a substantial effort, procedural and process improvements have now been made to our SAMGs to incorporate use of Emergency Mitigating Equipment where possible, and to address improvement opportunities identified during the 2011 site SAMG implementation and the recent table-top exercises. OPG is on track for completion by the Target Completion Date of December OPG Support for CNSC: Improving Regulatory Framework and Processes Since the last progress update OPG has undertaken the following activities in support of CNSC effort in the above focus area: 1) Review and comments on the Omnibus package of proposed changes to IAEA standards and documents, and 2) Meeting with CNSC staff to discuss closure criteria for FAIs. 3) Recent discussions with CNSC staff regarding OP&P applicability and compliance under BDBA and SA conditions 7.0 Summary and Conclusions OPG has made significant progress in completing the Fukushima follow-up activities [2, 5] and in addressing CNSC Fukushima Action Items [1]. In particular, OPG is requesting FAI status changes as presented in Table 1 and as supported by discussions in Sections 3, 4 and 5, and Enclosure 1 of this letter. In order to 3 OPG provided a summary of planned drills and exercises, which included SAMG, in its response to FAI (Enclosure 9 of Reference 5). 6

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8 References: 1. CNSC Letter, G. Rzentkowski to W. M. Elliott, Opening of Fukushima Action Items (FAIs) on Ontario Power Generation," February 17, 2012, E-Docs # , CD# N-CORR OPG Letter, W. M. Elliott to R. Jammal, OPG Progress Report No. 1 on CNSC Action Plan Fukushima Action Items," July 12, 2012, E-Docs # , CD# N- CORR OPG Letter, W. M. Elliott to R. Jammal, Revision to Enclosure 1 of OPG Progress Report No. 1 on CNSC Action Plan Fukushima Action Items," July 20, 2012, E- Docs # , CD# N-CORR CNSC Letter, M. Santini and P. A. Webster to W. M. Elliott, CNSC Review of OPG Status Update on Fukushima Action Items," October 23, 2012, E-Docs # , CD# N-CORR OPG Letter, W. M. Elliott to M. Santini and F. Rinfret, OPG Progress Report No. 2 on CNSC Action Plan Fukushima Action Items," January 31, 2013, E-Docs # , CD# N-CORR OPG Letter, W. M. Elliott to M. Santini and F. Rinfret, Revision to Enclosures 3 and 4 of OPG Progress Report No. 2 on CNSC Action Plan Fukushima Action Items," May 13, 2013, CD# N-CORR CNSC Letter, M. Santini and F. Rinfret to W. M. Elliott, CNSC Review of OPG Status Update #2 on Fukushima Action Items," April 30, 2013, E-Docs # , CD# N-CORR CNSC Letter, M. Santini and F.Rinfret to G. Jager and B. Duncan, Pickering NGS and Darlington NGS "A, Opening of New OPG Specific Action Items Related to Closed Fukushima Action Items," June 18, 2013, E-Docs # , CD# N- CORR CNSC Letter, R. Jammal to W. M. Elliott, Request Pursuant to Subsection 12(2) of the General Nuclear Safety and Control Regulations: Lessons Learned from Japanese Earthquake, March 17, 2011, E-Docs# , CD# N-CORR OPG Letter, W. M. Elliott to R. Jammal, Request for Closure - CNSC Request Pursuant to Subsection 12(2) of the General Nuclear Safety and Control Regulations: Lessons Learned from Japanese Earthquake, September 15, 2011, CD# N-CORR CNSC Letter, R. Jammal to W. M. Elliott, Closure of Request Pursuant to Subsection 12(2) of the General Nuclear Safety and Control Regulations: Lessons Learned from Japanese Earthquake, September 21, 2011, E-Docs # , CD# N-CORR CNSC Report, CNSC Fukushima Task Force Report, INFO-0824, October CNSC CMD: 12-M23B, CNSC Action Plan: Lessons Learned from the Fukushima Nuclear Accident," April 25, 2012, E-docs # OPG letter, W. M. Elliott to M. Santini and P. A. Webster, Progress Report on OPG Safety Analysis Improvement and RD-310 Implementation Activities Action Item 2010OPG-05," October 24, 2012, CD# N-CORR

9 15. OPG letter, W. M. Elliott to M. Santini and P. A. Webster, OPG RD-310 Implementation Plans Action Item 2010OPG-05," December 10, 2012, CD# N- CORR OPG letter, W. M. Elliott to M. Santini and F. Rinfret, Progress Report on OPG Safety Improvement and RD-310 Implementation Activities Action Item 2010OPG-05," April 23, 2013, CD# N-CORR

10 Table 1: OPG Fukushima Action Item (FAI) Status Change Requests (Closure of shaded FAIs below was requested in the January 2013 Fukushima progress report [5]). Fukushima Action Item (FAI) Requested Status Change Reference Section of Submission for Supporting Information Closure requested for Darlington 3.1 Enclosure Closure requested for Pickering A. 3.2 Enclosure and Closure requested for Pickering A. 3.3 Enclosure Closure requested for Pickering A and Pickering B Per Reference 7, additional information has been provided 3.4 Reference 16 10

11 Table 2 Summary of Regulatory Management Action Made Submission Title: "OPG Progress Report No. 3 on CNSC Action Plan Fukushima Action Items Regulatory Management Actions (REGM): No. Description Date to be Completed 1 Submit to the CNSC, OPG s fourth progress report on Fukushima Action Items. 31 January

12 Total Number of Open FAI Station Actions Mr. M.Santini Figure 1: Overall OPG Progress in Requesting Closure of FAIs 120 CNSC Target for FAI station actions 100 OPG Performance 80 Improved Performance Initial Q Q Q Q Q Q Q Q intial FAI = 36 FAI x 3 stations - 7 N/A Quarter 12

13 Enclosed with OPG Letter, W. M. Elliott to M. Santini and F. Rinfret, "OPG Progress Report No. 3 on CNSC Action Plan Fukushima Action Items," Table of Contents: Enclosures 1 to 7 (enclosed CD) Enclosure Description 1 Fukushima Action Item Status Report, N-REP , R003, July 15, (FAI 1.2.3) 3 (FAI 1.5.1) 4 (FAI & 1.6.2) 5 (FAI 1.2.1,.2 &.3) 6 (FAI 1.7.1) 7 (FAI 3.1.2) Information to Support Closure of FAI Plan and Schedule for Provisions of Additional Relief for the Shield Tank / Calandria Vault in Case of a Severe Accident, NK38-CORR , May 29, Pickering 1-4: Consideration of Irradiated Fuel Bay Cooling Following A Beyond Design Basis Event, N-REP (rev 1), June 18, a) Leakage Rate Through Cracks on the Pickering 1-4 Irradiated Fuel Bay Walls Following Loss of Cooling, P-CORR , March 28, b) Leakage Rate Through Cracks on the Pickering Auxiliary Irradiated Fuel Bay Walls Following Loss of Cooling, P-CORR , May 31, Fukushima Action Item (FAI) Adequacy of Relief Capability for the Pickering 5-8 Shield Tank (Calandria Vault) Revision 1, N-CORR , July 10, Completion of Activities Related to CNSC Fukushima Action Item Phase 1: Evaluation of (Cooling Water) make-up to Boilers and Heat Transport System, N- CORR , March 27, Multi-Unit Events Update of SAMG and Technical Basis Documents, COG-JP R0.