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HomeMy WebLinkAboutAugust 27, 2001PICKERING AGENDA SPECIAL COUNCIL MEETING Thomas J. Quinn Chief Administrative Officer AUGUST 27, 2001 AGENDA SPECIAL COLSNCIL MEETING AUGUST 27, 2001 6:00 P.M. (I) RESOLUTIONS To consider CAO Report 0_%-01. concerning Picketing Nuclear Generating Station, PNGS-A Return to Service, Relicensing of PNGS-A (11) ADJOURNMENT RESOLUTION OF COUNCIL DATE MOVED BY SECONDED BY That Report to Council CAO 05-01 concerning the return to service of PNGS- A be received. That Council advise the Canadian Nuclear Safety Commission (CNSC) that it supports the CNSC staff recommendation to allow the restart of the PNGS-A reactors, subject to the conditions outlined in CMD 01-H17, and providing all the required improvements and modifications specified in Appendix D of that document are completed betbre any unit is returned to service, with the following clarification: That Item 31 of Part A of Appendix D be reworded as follows: "Submit evidence that a memorandum q/understanding has been entered into with the (Tm. qf P~ckermg concermn2 mutual aid. coordinated fire response andjoml &i/ix." That Council request the CNSC to add the following as condition of relicensing: "That OPG make appropriate arrangements' with the City of Pickering concerning the provis'ion of adequate.fire and emergency response services to the community." That a copy of Report to Council CAO 05-01 be forwarded to the Canadian Nuclear Safety Commission, the Ontario Power Generation, and the Honourable Dan McTeague, M.P. Pickenng-Ajax-Uxbridge. CARRIED: MAYOR OFFICE OF THE CHIEF ADMINISTRATIVE OFFICER MEMORANDUM August 21, 2001 To~ Subject: Mayor Arthurs Members of Council Thomas J. Quinn Chief Administrative Officer Pickering Nuclear Generating Station - A Return to Service Report to Council CAO 05-01 File: UT 3550 This memorandum has been prepared in response to various questions and comments raised at the Council meeting of August 7, 2001 concerning Report to Council CAO 05- 01 and the restart of Pickering Nuclear Generating Station (PNGS) - A. In Report to Council CAO 05-01, we recommended that Council advise the Canadian Nuclear Safety Commission (CNSC) that it supports the CNSC staff recommendation to allow the restart of PNGS - A subject to the conditions, improvements and modifications contained in Appendix D to the CNSC staff report. We stand by this recommendation. Subject to one minor wording change (which we identified in the Report to Council), CNSC staff has addressed all of the issues that we raised in our letter of May 16, 2001, to our satisfaction. In terms of overall health and safety considerations, we have relied on the technical expertise of CNSC as the regulator to conduct a comprehensive review of the station and provide us with the assurance that PNGS-A can safely be returned to service. In our May letter, we asked CNSC staff to ensure that a number of iinportant safety concerns are properly addressed prior to relicensing (i.e. shut down system enhancement, fire safety upgrades, emergency core cooling strainers, maintenance performance, and configuration management). These concerns were subsequently included by CNSC staff in Appendix D as "required" improvements that must be made by OPG prior to the return to service of any unit. In our May letter, we also asked CNSC staff to ensure OPG addresses various staffing issues before restart (i.e. staff training and certification, and establishing an appropriate fire protection protocol with Pickering). Subject to the one minor wording change (noted in our Report to Council) CNSC staff also dealt with these staffing issues in Appendix D as Mayor Arthurs Members of Council Pickering Nuclear Generating Station - A Return to Service August 21,2001 Page 2 "required" improvements that must be made prior to restart. The next concern outlined in our May letter involved the Follow-up and monitoring program In April of this year, CN$C staff issued a draft follow-up and monitoring program for public comment. Upon receipt of this draft, copies of tile program were distributed to Mayor and Council information. Staff also reviewed tile draft, and as part of our May letter, we provided comments on the program to CNSC stall'. We advised them of' our general satisfaction with tile draft program, subject to tile addition of an explicit provision requiring OPG to provide periodic updates to tile City of' Picketing. We also asked that as a condition of relicensing, CNSC ensure OPG implements tile follow-up and monitoring program. CNSC stall' agreed to impose such a condition. As noted in our Report to Council, as a condition of restart, OPG will be required to conduct and report on the follow-up and monitoring program. Furthermore, it is expected that tile follow-up and monitoring program will be finalized and issued by CNSC stall' within tile next few weeks. This is consistent with our earlier expectations. When CNSC circulated the draft follow-up and monitoring program for comment, it ,,vas expected that it would take a number of months to finalize. The last issue relates to tile Community Benefits Agreement. In our May letter, we reminded CNSC stall' of a previous Council resolution requesting that OPG be required to enter into a Community Benefits Agreement with the City as a condition of relicensing We again requested that this condition be imposed, ttowever, in a subsequent conversation wifl~ CNSC staff, we were advised that it would not be within the mandate of the Commission to impose such a condition. In our negotiations with OPG, we therefore tbcussed attention on fire and emergency protection, as we felt that these concerns would be more in keeping with the mandate of the Comlnission. Because we were making progress on this issue, we thought it prudent to include in our Repo~ to Council a recommendation that Core,oil request CNSC to add a condition of relicensing that OPG "make appropriate arrangements xvith the City of Pickerino concerning the provision of adequate fire and emergency response setx'ices to the community". I trust this is satisfactoD', but should you have any questions, please do not hesitate contacting either Tom Melvmuk or myself. TJQ/TM:Ir Copy: Division Head, Corporate Projects & Potic;' - ?ICKERING REPORT TO COUNCIL FROM: Thomas J. Quinn Chief Administrative Officer DATE: July 31, 2001 REPORT NUMBER: CAO 054) 1 SUBJECT: Pickering Nuclear Generating Station. PNGS-A Return to Service - Relicensing of PNGS-A - File: UT 3510 RECOMM EN I)ATION S' 1. That Report to Council CAO 05-01 concerning the return to service of PNGS-A be received. That Council advise the Canadian Nuclear Safety Commission (CNSC) that it supports the CNSC staff' recommendation to allow the restart of the PNGS-A reactors, subject to the conditions outlined in CMD 01-H17, and providing all the required improvements and modifications specified in Appendix D of that document are completed before any unit is returned to service, with the following clarification: That Item .3 l of Part A of Appendix D be reworded as follows: "Xubrni! evidence that a memorandum qi" understanding has been entered into with the Ci0' qf Pickering concerning mutual aid, coordinaledfire responxe and.joint drills." 3. That Council request the CNSC to add the following as condition ofrelicensing: "That OPG make appropriate arrangemenlx with the CiO' qf Picketing concernin~ the provi,vion o/'adequate fire and emergency res~onxe service,v to the commtmiIv. " That a cop3.' of Report to Council CAO 05-01 be lbrwarded to the Canadian Nuclear Safety Commission. the Ontario Power Generation, and the Honourable Dan McTeague, M.P. I ickering-Ajax-Uxbrid~e. OR1GIN: Correspondence from the Canadian Nuclear Safety Commission concerning Ontario Power Generation's application to restart PNGS-A. Comments are requested before the end of August in order to be considered bv the Commission at the second day of public hearings on the application. [The second day of public hearings is scheduled for October 3, 2001.] AUTHORITY: Canadian Environmental Assessment ,4 ct Nuclear Sqfety and (Tontro[ ,4 ct (fi~rmerly the Atomic Ener£9; (;onlrol A ct) Report to Council CA() 05-01 Subject: PNGS A Return lc) Service [)ate: Juh 31.2001 Page~ '~ of 7 FINANCIAI~ IMPLICATI()NS' l'}lcre are no immediate financial implications associated xx/th thc recommendations contained in tiffs Report. l towcvcr, according to klI~ ccononaic impact analvsi~ commissioned bx ()PG and completed in March 2000. should l)N(i%-.k bc returned to service, there should be significant financial benefits to thc local and rcuional cctmomics as a result of direct and indirect expenditures associated with the restart ~c.g. operating and construction payrolls, and expenditures on goods and scrx ices). I{Xt!C[ 7I'IVE S[IMMARY: ()I>G has applied to the (_'NSC' for an amendment to it~ opcratin~ license to alloxx tho return to service of PN()N-A. Betbrc makin~ a decision. CNNC has invited comments from those interested in this matter. ('ommcnts arc requested belbrc tine cad of,NuguNt. In May of this year. City staff scm a letter to (CNSC staff outlinin~ OLlr main issues of concern with respect to thc restart. Xk'c requested that ('NS(' staff consider tmr comments in preparing thdr report to thc Commission (see Attachment 1. t.cttcr from fi'M) to ('NSC' staff). In June. xvt received a reply, advising tis final CNS(' staff xxill bc i'ccomnncndinu that ()P(i bc required to complete a number of planned improxcmcnts bclbrc alax of thc rccictors arc alloxxcd to restart. including those l'CqUestcd in our Max lc~tcr. ('kNC' stafI' also udxiscd that various other conditioiTs of approval would address linc other is>ties n~cnt~oncci in our letter that are within the We subsequenlly reviex~ed thc ('NS(' staff report (C'NII) 01-1{17) to ensure that it actequatety addresses thc concerns xve raised in Nlax. and to assure ourselves that CC'NSC staff thorou,,hlv reviewed all pertinent issues assocmtcci with rcsta,-ting }'NGS-.;X. 'I'tnc (7NSC staff report includes an extensive hist of inaprovcmcnts and moctificatit,ns that must bc in place prior to the restart of any reactor ( sec :Xttaclamcnt 3...Xppcndix I) to ('N SC' staff report ). Based on tiao CNSC staff revicxx, and sub cci to OlaC tnaillor xxordin5 change, it is rccomnacndcd that Council support the ('NSC staff:' reconamcndation lo allow tiao restart of PN(iN-:X su[aiccl to the various conditions, improvements and modiilcations contained in tiao CNS(' sutlTreport. Thc one minor wording chan,,c=, that xxe arc requesting deals, with thc issue of mutual aid and coordinated tire response arrangements (Item 31 of Part :X oi .Xppcndix D of thc CNSC staff report). Rather than simply requiring ()l)(i to submit evidence that ~zdcq~aze w'ra.~gements are i~/alac'e with Ibc ('i0' q/l'ic'kc'ri,,~ ]')'ru /)d?Llrllt'ldnl" COIqCCI'Ilillg this issue, it is requested that a more lbrmal condition bc established. In this regard, stai'I' recommends that Council ask thc Commission to replace Item 31 as currcntl> proposed xxith a condition that OPG submit evidence In response to earlier direction from Council (ctmcorzainu tho ciatering into of a ~community benefits agreement" with ()P(~). ox cr thc past iDxx moixh5 ~taI'f have ladd a number of meetings with OPG. Although negotiations haxc not vet been completed, progress is being inadc on thc issue of community-wide fire protection and cmcrgcn% response services. To lhcilitatc and support these negotiations, it is rccomnacndcd that Council ask thc Commission to include another condition of reliccnsing, requiring that OPe; ' ,~c~ke rq¥,',l,'ir~tc r,'ra~A, ct, c~/.s' u/Il? lite ~he communiO,. " BACKGRO['N D: Thc operatiola of the PN(iS-A facilitx has been regulated by the Canadian Nuclear Safety Commission (formerly tiao .,\romic tZncrg> Coiatrol Board) since tiao tbur "A" reactors became Report to Council CAe 05-01 Sul~iect: PNG% A Return to Service l)alc: ,lutx ',I.,() ~ ()l I)agc 3 oI'- operational in the earl~ 1970's. At the end of 1997. the PNGS-A reactors were placed in a non- routine shutdown state. In 1999, OPG requested permission to return PNGS-A to service. Part of the return to service process involved the successful completion of a screening level environmental assessment under tile ('anadian Em,ironmen~al Asse,s'sment Ac~. The Environmental Assessment was approved earlier this year, and OPG has now applied tbr an amendment to its operating license in order to bring the PNGS-A reactors back to full power. If all approvals are given, OPG anticipates being in a position to restart the first reactor by the end of the first quarter of 2002. ()n May 29th. 2001. CNSC staff issued their report to the Commission on the return to service of I)NGS-A (CMD 01-H17). The CNSC staff report recommends that thc Commission allow the restart of PNGS-A. subject to certain conditions, and providing various improvements and modifications are completed betbre any reactor is restarted. Condition 10.1 of tile current license tbr PNGS-A requires that PNGS-A remain in an approved shutdown state unless otherv¢ise specified in writing by the Commission, or by a person authorized bv the Commission. CNSC staff is recommending that Condition 10.1 of the current license be deleted and replaced with a new Condition 11.1 as follows: Prior to the restart of a reactor, the licensee shall obtain approval of the Commission, or a person authorized by the Commission. With the request for approval, the licensee shall provide a completion assurance report on the installation of the improvements and modifications specified in Appendix D of CMD 01 -HI 7. [Note: Appendix D is included as Attachment 3 to this Report to Council.] The other new conditions of relicensing that are being recommended bv CNSC staff are as tbllows: · A standard condition on environmental qualification that has been included in thc licence of all operating power reactors in Canada: · :\ condition relating to thc availability of the site electrical supply, which is shared between PNGS-A and PNGS-B; and · A condition requiring OPG to conduct and report on a tbllow-up and monitoring program. In a letter to the CNSC dated May lo , staff' identified our kev issues with respect to the restart of PNGS-A. We requested that these issues be addressed as licensing requirements, should CNSC staff be inclined to recommend that PNG~'S-A be allowed to return to service. Our concerns xvcre addressed under Ibur main headings (see Attachment 1 ): 1. Equipment Fitness for Service 2. Staffing Issues 3. Follow-Up and Monitoring Program 4. OPG / City of Pickering Agreement In Max,' staff met CNSC staff to discuss the letter. A formal response from CNSC was received in mid June (see Attachment No. 2). The CNSC staff report on the restart of PNGS-A adequately addresses most of the issues identified in our May letter. }towever, there are two areas where Council should request additional clarification from the Commission, one with respect to the issue of mutual aid and coordinated fire response, and the other with respect to the provision of adequate fire and emergency response services to the community. Report to Council CAe 05-01 Subject: PNGS A Return to Service Date: Jul\ 31.2001 Page 4 of 7 Beloxx is a summary of each of thc issues raised bx staI¥ in our Nlax letter', and the CN%C stal'I' response to tlnat issue. EQUII'MENT FITNESS FOR SERVICE Staff' identified five issues under thc hcacting "equipment Iltncss for service": a) Shut Down System tinhancomcnt b) Fire Safety [;pgradcs c) lLmcrgcnc> Core Cooling Strainers d) Xlaintenancc Pcrlbrmancc c) Configuration Nlanagcmcm Program Slmt Do\va %vstem Enhanccnaont In ~mr Max letter, we rectucsted thai ¢'N%C as a condition of rcliccn~in5 ensure that a guaranteed and protected secondarx stautdoxxn sxstcm lbr PN(i%-.X bc alex&epcot and installed prior to re s tart. Item 3 ot' Part A of Appendix I) to ttac ('NSC' staI'I' report requires thc installation of tho shut do~vn system enhancements prior to return to service. ('NS(.' staff' also state that OPG has committed to install and commissio~a tiao shutdoxx~a ax'stem enhancement in all units. In addition. CNSC staff' has advised it xxill naOlaitor the commisslolain~ activities and will assess these activities to ensure that tine shutdoxx n sx stem enhancements have been properly implemented and are cit'cctivc prior to restart. This issue appears to have been dealt xx ith at>propriatcl.x in tiao ('NSC' staff' report. Fire Sal'ctv [ipgradcs In our Mav letter:, xxc requested as a condition of relicensin~, that ('NN(' cnsLtrc implementation of all essential fire salktx upgractcs recommended by CNNC'5 I cchnical Adxisorx Committee reviewing ()PG's fire salbtx assc55nlClat and I~1'o protection program. Flue Citx's Chief Building Official is a member of this Icc}mical .\dx isorx Committee. The essential fire safety upgrades recommended by the Technical Advisor\ ('ommittcc are included in thc ('NSC staff report as Items 2<~ throug}~ 34 of Part A and Item 1 o~' Part B of Appendix D. These items deal xxith xarious issues including the fire suppression sxstem, fire alarms and detection systems, and various other upgrades. It is required that those improvements be made prior to thc restart of an\ unit. This issue appears to have been dealt with appropriatcl) i~q tile ¢'NN(' staI'I' report. Emergency Core Coolin~ Strainers In our May letter, xxe requested that as a condition of reliccnsing, CNSC should ensure tlnat OPG install the new improved strainers at PN(}S-,.\ prior to restart. C,N, ( staff' deals xxittn this issue in Item ('~ of Part ,.\ of :\ppcndix I) of tiao CN,.( staff report. New. larger surlhce area strainers must be installed bclbrc tile return to scrx ice of each unit. Maintenance Perlbrmance In our May letter, we rcquestcci als a condition of rclicensing, tlnat CNSC ensure ()P(i upgrades its maintenance perfommncc both prior to restart and on an ongoing basis after restart. Many of tine items listed in :\ppendix I) to tiao (.'NSC_' stall-' report relate to maintenance issues, including Item 17 el'Part :\ and Item lt) of Part B. Item 17 requires OPG to report on tiao status Report to Council CAO 05-01 I)atc: Juix 51.2(/(tl Subject: PNGS A Return to Service Page ¢Ot''~ o£ their maintenance program prior to restart, including the status of thc Integrated Improvement Program projects. CNSC will require this report to include a comparison between PNGS-A and PNGS-B with respect to these issues (i.e. information showing how the maintenance related Integrated Improvement Program prqiects are equivalent to PNGS-B prior to restart). This issue appears to have been dealt with appropriately in the CNSC staff' report. Configuration Management In our May letter, we requested that CNSC ensure OPG completes its configuration management restoration project prior to the restart of PNGS-A. This issue is dealt with by CNSC staff through Item 38 of Part A of Appendix D. requiring OPG to complete (prior to restart) the configuration management master equipment list, the operational flo~vsheets, f]ox~ diagrams, on-line wiring and electrical wiring diagrams tbr all safety-related systems. This issue appears to have been dealt with appropriately in the CNSC staff report. STAFFING ISSUES In our .Xlax letter, we identified two staffing issues for CNSC's consideration: a) Training and Certification ot'OPG Staff b) Fire Protection Staffing Issues Training and Certification of Staff. In our May letter, we requested that as a condition of relicensing. CNSC should ensure that ()PG provides and maintains an acceptable level of trained and certified stafl} and provides adequate training programs tbr all stafffbr the safe operation of PNGS-A and PNGS-B. CNSC staff' addresses the issue of training and certification of staff in Items 41 and 42 of Part A of Appendix D. Item 41 requires the availability of a sufficient number of qualified operators. while item 42 requires ttaat all workers successful complete refresher training and upgrade training appropriate to thc knowledge and skill requirements of their position. It should also be noted that the existing operating license for PNGS-A also deals with staff training, certification requirements and continuing training requirements. This issue appears to have been dealt with appropriately in the CNSC staff report. Fire Protection In our May letter, we requested that as a condition of relicensing CNSC ensure that a detailed protocol is established for a co-ordinated response, that a joint drill be undertaken prior to the restart of PNGS-A and that an appropriate commitment be made to .joint training. In response to this request CNSC staff included Item 31 of Part A of Appendix D. This item requires OPG to submit evidence that adequate coordinated fire response arrangements are in place with the City of Pickering Fire Department and that a .joint drill be held. Although this provision meets the general intent of our request, in order to ensure a fbrmal fire protection protocol is established with the Citx. it is requested that the Commission reword Item 31 to require OPG to: "Submit evidence that a memorandum qf understanding has been entered into u:ith thc CiO o./'Pickerin~ concerning mutua] aid, coordinated.fire response and./oin! drills." Report to Council GAO 05-01 Subfiect: PNG-S A Return to Service Date: ,lulx' .31. 2001 Page 6 o1~7 m~tlas ~ttac drills arc schedt~lcd I'~'o~ ()ctol~c~' 7 t}ar~c~t~ N~x'cmbct' 4. 2001 ). C'NSC' stal'i' has undertake these evaluatio~s. Stal't' recommends tlaat ('otmcil ~'c~tt~csr tl~c ('NNLq' tt~ revise ltcna 31 of l'art :X of ..\ppc~dix D as noted aboxe {see Recommcndatio~ _~ t~I' tl~is t?,cpo~'t to (_;ouncil). AND M()NI'FOI~.IN(; I~IR.O(;R. AM program. ()l~(i be required to pros idc i'cg~la~' t~pdatcs t~ l~ickcring (~ociiacil. .~\s ~ conditioIa of rclicciasiiag. ('NS(_' staCC is rcco~mcildmg tlnat ()t~(; ~c ~-Cclcii~'cd to coI~duct a~d advised us that the Ik~tl(~xx-t~t~ amd molaitoz'i~ng p~-t~gram h~s t~t x ct i~ccla I]~alized. alad it should als() be noted that shoctld tl~c i'cstc~t't t~c c~pto~'oxcd, i~l o~'dof to obtaitl iaecossatrx seasonal information, some aspects of thc c~axiI'olai~qclqt~xl motaito~'i~l~ pi't~graml x\ ill laavc to bc initiated prior to restart. Accordiilgl5, itcl~ 43 t~I' I):~i't .\ of/\pt~cl~dix 1) i'ccttlircs ()}~(i to complete the pre-restart portion oCtlae l'ollox~-ttp amd molait<~riia 'Ibis issue appears to have beci~ do:ill xx ith :lt~pi'otoriatel.v ill the ('NSC' st~l'i' ~'cpoi't. OPG / CITY OF PICKERI N(; .~,(; 1{~ E 5I 1~ NT in otlr May letter, we reminded Lq'NS(' st~I't' tt~:~t LqTotmcil llad p~s~cd c~ rcs(~lt~tio~ i~l ()ctobcr 2000 (as part et'the City's commci~ts on tl~c ti:\ } ~t~thorizillg st~I'I to ~c~(~t~atc :~ "('ommunitv Benefits /%greemcnt" with OP(; on ~l xvithotlt t~'c. iudicc basis to pr'elect tl~c iiatorest cC the City. Accordingly, wc requested ttlat ('NS(' c~st~rc as a co~aditi~rq c~I' roiicoIlsila5. that aia appropriate Community Bc~aet]ts ~,%greemem bet\\con (II)(} and Lq'its' ix execrated pi'ic~r to restart. Discussion, s xxith ()t)G concemi~g ii,is ~l~ttcr }~:tx c bcc~n t~-goi~g l:~r tlac past mmabc~' of months. Although xacgotiatioias have ~ot \ct bcc~q core, pitted. [3r'og~'css has bcel~ made cia thc issue of ensuring adectuatc 15re protcctio~ a~ad cmc~'gc~c> r'cspo~se services to tt~c commu~it>', a~d clarilb'ing Ot)(;'s intex'cst in this mattc~'. The CNSC staff' report docs i~ot ~:lkc :li~x )'ti'crop,cc to thc isscic of a ('ommtmitv Benefit Agreement (xvt t~ave becin ads iscd xc~'ballx tlaar it ix ~qot xxittai~a tlaci~' ma~datc). Nevcrtl~cless. as assista~cc i~a our negotiatio~as with OI'G. it is I'ccollqlllcladcd that (;otmcil ask tiao C',~mmissio~a to i~aclt~dc a~a additional co~qdition oF relice~si~g. ~'cqttiring that ()t)(} '~;lrtkc' ~7;/;~'o/~'ialc to ti~is t¢cport to Cotmcil. Report to Council CA() 05-01 Subject: PNGS A Return to Service I)atc: ,lulx X l ATTACI tMENTS: 1. I,etter from CAO to CNSC staff (May 2001) 2. Response from CNSC Staff (June 2001). 3. Appendix D to CNSC Staff Report (CMD 01-H17) Prepared By: Approved/Endorsed By: G o r o~l_9_~R~e idt Project Co-ordinator Thomas J. Quinn T;hief Administrative Officer Thomas E. Melvmuk Corporate Projects & Policy Division Head TJO/'jgr/tem ,Attachments Copy: Director. Operations & Emergency Services Division Head. Corporate Projects & Policy Fire Chief Manager, Building Services (C.B.O.) Recommended for the consideration of Pickering City Council ..-o ~ ~~'nn, Ch~~ Administrative Officer 1 :'d(E PORTSX, Cao05-01 .doc PICKERING ATTACHMEN'T ~_~ ~,= qEPORT # Pickermg Civic Complex One The Esplanade Picketing, Ontano Canada LIV 6K7 Direct Access (905) 420-466o ci .tyofpickenng. com OFFICE OF THE CHIEF ADMINISTRATIVE OFFICER Department (905) 420-4648 Facsimile (905) 420-6064 cao @city. pickerin g. on.ca N,lav 16,2001 Canadian Nuclear Safety Commission Pickering A P.O. Box 160 Pickering, Ontario L1V 2R5 Attention: Dr. J.S.C. Tona. Head, Site Office, Pickerinr A Subject: Pickering A Return to Serw'ice Project - City ofPickering Conunents File: UT 3550 The enclosed comments from the City of Picketing are tbr your consideration and inclusion into the Canadian Nuclear Safetx- Commission tCNSC) staff report as part of the upcoming Public Hearings for the Picketing A Return to Service project. In the event that you are inclined to recommend that PNGS-A be allowed to return to service, we would urge you to include the actions that we t2ave outlined in this letter as conditions of relicensing. At this time, the City has identified four main concerns as follows: 1. Equipment Fitness for Service 2. Staffing Issues 3. Follow-up and Monitoring Program 4. OPG / City of Pickering Agreement 1. EQUIPMENT FITNESS FOR SERVICE In the area of equipment fimess for service, we have issues: a) Shut Down System Enhancement ibr PNGS-A b) Fire Safety uPgrades c) Emergency Core Cooling Strainers d) Maintenance Performance e) Configuration Management Program conmnents at this time on the following' Canadian Nuclear Safety Commission - Picketing A Return to Service Project May 16, 2001 Page 2 a) Shut Down System Enhancement for PNGS-A Part of the reason for the shutdown of PNGS-A in 1997 was the lack of installation of an acceptable enhanced secondary shutdown system. The CNSC must ensure that PNGS-A has a safe and acceptable secondary shutdown system for all reactors. The svstem should be installed. tested and fully operational prior to the restart. ' ' Action: As a condition of relicensing, CNSC should ensure that a guaranteed and protected secondary shutdown system for PNGS-A is developed and installed prior to restart, and that sufficient operational mechanisms, procedures and training are carried out to assure the system's practical effectiveness and reliability.. b) Fire SafeW Upgrades _[&v zt e '. The City's Chief Building Official is a member of CNSC's Teclmical Advisory Committee. reviewing OPG's Fire Safety Assessment and their resulting Fire Protection Prog(am. Detalle~ comments have been communicated by the Chief Building Official to CNSC, and the City appreciates being given the opportunity to assist the Commission in this area. The CNSC Technical Advisory. Committee's work is not yet concluded. However, in a letter to OPG dated April 17, 200 l, the CNSC outlines a number of issues that OPG need to address. We also understand that a more recent meeting took place on April 26, 2001 between OPG and the CNSC to further discuss these issues. It is imperative in terms of public and occupant safety, that all the essential Technical Advisory Committee fire protection initiatives be implemented at PNGS-A and be rigorously monitored and enforced by the CNSC. Action: As a condition of relicensing CNSC should ensure that OPG implements all essential firet protection upgrades identified and recommended by the Technical Advisory Committee. c) ~Emergency Core Cooling Strainers CMD 01-H3 indicates that emergency core cooling s~rainers in the flow path of the emergency core cooling recovery pumps are vulnerable to clogging by debris following a loss of coolant accident. OPG has completed the process of choosing a new and improved strainer design for PNGS-A and expect that new strainers will be installed before the restart. May 16, 2001 Canadian Nuclear Sa.fety Commission - Picketing A Return to Service Project Page 3 Action: As a condition of relicensing CNSC should ensure that OPG install the new improved strainers at t PNGS-A prior to restart~ d) Maintenance Performance ]ssues: CNSC staff, in their report of Januazw 18, 2001. identified maintenance conditionally acceptable subject to improvement in the following areas. · performance to be developing and implementing an effective equipment calibration program; . · improving the survival rate (actual % amount o£ work accomplished vs. scheduled work) and increasing the number of scheduled tasks in their 13 week rolling maintenance program; · reducing both the corrective and the preventative maintenance backlog; · completing the preventative maintenance model work and implementing the change requests resulting from an internal review of plant systems: and · changing the production rate o£maintenance procedure upgrade. The City is concerned about the conditionally acceptable rating in this area and would like to see substantial improvements made in maintenance performance. Action: As a condition of relicensing, CNSC st~ould ensure 0PG tzpgrades its maintenance performance both prior to restart of PNGS-A and on an ongoing basis after restart. e) .Configuration Manaaement Issue: CNSC recognizes in their staff reports that COrLt]guration management is a major safety concern and that it contributes to maintenance bac~ogs. Significant improvement is needed in this area and CNSC should ensure that OPG completes the necessary Configuration Management Restoration Project prior to restart. Action: As a condition of relicensing CNSC should ensure that OPG completes the Configuration Management Restoration Project prior to restart. Canadian Nuclear Safety Commission - Picketing A Return to Service Project May 16, 2001 Page 4 2. STAFFING ISSUES The City has identified two staffing issues. These include: a) Training and Certification of OPG Staff; and b) Fire Protection Staffing Issues a) Training and Certification of OPG Staff OPG staff must be trained to a level of competency to handle both the existing PNGS-B reactors as well as the older PNGS-A equipment on an ongoing basis. The issue is one oF quality and quantity of trained nuclear operators. A related issue is the need for ongoing training programs for shift supervisors and other staff. CNSC must ensure that sufficient trained staff are available to safely operate and maintaSn the station. Action: As a condition of relicensing, CNSC should ensure that OPG provides and maintains an acceptable level of trained and certified staff and provides adequate training programs for nuclear operators, supervisors and all other staff for the safe operation of PNGS-A and PNGS-B. b) Fire Protection Issue: There is no detailed protocol that outlines the expected actions, services and responsibilities expected of Pickering Fire Services in responding to incidents at PNGS. There is also at this time no formal commitment for joint training between OPG and Picketing Fire Services. Discussions are currently underway between OPG and City staff to develop this protocol. The protocol is necessary to specifically clarify the role of the n~unicipality in assisting the station, to develop better command and control strategies when City and PNGS staff are working together, to confirm the expected Pickering Fire Services response times to the plant and to ensure adequate municipal fh-e protection resources are available and in place. Action: As a condition of relicensing CNSC should ensure that a detailed protocol is established for mutual aid and co-ordinated response, that a joint drill be undertaken prior to restart and that an appropriate commitment be made for joint training. The protocol should include any actions, services and responsibilities to be provided to PNGS by Picketing Fire Services including appropriate provisions concerning the availability of necessary resources to carry out required duties. Canadian Nuclear Safety Commission - Picketing A Return to Service Project May 16, 2001 Page 5 3. FOLLOW-UP AND MONITORING PROGI~4M / EA DECISION The environmental assessment Screening Report identified the need for a follow-up and monitoring program and outlined the main elements of such a pro,am. In commenting on the EA process, Picketing Council adopted a resolution requesting that "the approval of the City, of Picketing be obtained for the revised follow-up program prior to the restart of PNGS-A". In the CNSC's decision on the EA, it was required that the 1%Ilow-up and monitoring program outlined in the Screening Report be integrated into the PNGS-A licensing process. Part of the Commission's decision also required that OPG implement specific nzitigation measures, including the development of a Facilitx, Risk Assessment. investigations to conf'n'rn and develop mitigating measures for the sources of tritium in groundwater., and the continuation of OPG's public communication and consultative strategy up to the return to service and for the subsequent period to full operation in 2004. Recently, CNSC released a detailed follow-up and monitoring program for public and stakeholder input. CiW staff has had a~ opportunib' to review the document and, at this time, is generally satisfied with the scope of the program in terms of both the pre-restart and post-restart phases. However we are concerned that CNSC, in reporting the results of the program, did not explicitly require OPG to provide periodic updates to Picketing Council. We would request that CNSC correct tlzis oversight. The City would also like the opportunity to cotangent on Section D, the detailed work plans, which we understzmd wii1 be completed after the consultation process. Action: As a condition of relicensing, the CNSC should ensure that OPG implement an acceptable follow-up and monitoring prograzn and that as part of that program, OPG be required to provide regular updates to Picketing Council. 4. OPG / CITY OF PICKERING AGREEMENT Issue: On October 11, 2000, as part o£ the environmental assessment process, City Council passed a resolution authorizing staff to "negotiate a Corrun~ty Benefits Agreement with Ontario Power Generation on a without prejudice basis to protect the interests of the Cit of Pickerin" Y g. Negotiations on the agreement with OPG have been in progress since early 2001 but to date an agreement has not yet been reached. As the host municipality for PNGS, Picketing is significantly affected by the return to sen'ice of PNGS-A, and an appropriate agreement with the City must be in place prior to the restart. Canadian Nuclear Safer¢- Commission - Pickering A Return to Service Project May 16, 2001 Page 6 Action: As a condition ofrelicensing, CNSC should ensure that OPG and the City execute an appropriate Community Benefits Agreement prior to the restart. Summary: The City appreciates the opportunity to provide input into the development of a CNSC staff report on the relicensing of PNGS-A and requests that the action items included in the letter be incorporated as licensing conditions, in the event that CNSC is inclined to approve the restart of PNGS-A. If you have any questions about this letter, please do not hesitate to contact my staff (Tom Melymuk, Division Head, Corporate Projects & Policy, or Gordon Reidt, Project Coordinator) or myself. Yours vew truly Thomas J. Quinn, RDMR, CMM Chief Administrative Officer TJQ:lr Copy: Mayor Arthurs Members of Council Director, Operations & Emergency Services Director, Corporate Services & Treasurer Director, Planning & Development Division Head, Corporate Projects & Policy Project Coordinator Bob Strickert. Site Vice President, Nuclear Support J :\P&ECO\SHARE\UTIL\UT3550\ 1051601, doc I,I Canadian Nuclear Commission canadienne .,~[N-f.¢: --' TO REPgRT# Safety Commission de sOret~ nucl~aire 1- r'~ ~'_ -.-,, ,~'~ ~ P.O. BOX 1046, Station B C.P. 1046, Succursale B f [~::(.~..~ ~,~ ~..1~I ~, Ottawa, Ontario Ottawa (Ontario) ~' ~ """" - _ _, ~ 1P5S9 K1PfS9 ~ i ~, ~t '~/ ) ~?,x: (613)995-5086 T~i~copieur: ,6:3)995-50S6 ~, ¢~rat~r~¢ts/ Directorate of Reactor Regulation ~'~& policy / ro.~,~¢ Votr.,¢~or~.¢¢ Our h~e Notre r~fere~e 26-]-4-]-0 June 12, 2001 fRECEIVED:I JUN -1 ZLIOi Mr. Thomas J. Quinn Chief Administrative Officer City of Picketing Picketing Civic Complex One The Esplanade Picketing, Ontario L 1V 6K7 FVVD / CO PY/ClRCU LATE TO: ' t.~A'~C.~ I COUNCIL & DEVEL CLERK & EMERG ! CORR SERV. REC. i HUMAN RES. ~CCN DzV Dear Mr. Qui~m: · '."", rqOF Thank you for your leuer of May ~6. 2001 wtdch includes con~nents and concerns from the CiD, of Picketing regarding Ontario Power Generation's (OPG) Picketing A Return to Sera, ice project. Staff of the Ca:~adian Nuclear Safety Commission (CNSC) was already aware of the issues mentioned in >'our letter and those d~at are relevant to the mandate of the CNSC are discussed in the CNSC staff Con~n~ission Member Document (CMD) on OPG's application to restart Picketing A. A cop>' of the CNSC s~aff CMD (CMD 0t-H17) is enclosed. La the CMD, CNSC staffis reconm~ending that OPG be required to complete a number of planned improvements before any of the reactors are allowed to resiazt. The list of improvements includes ali the issues mentioned in your letter under Equipment Fitness for Service. Proposed licence conditions would also required OPG to have an adequate number of fully qualified staff, and to complete the Environmental Assessment roi]ow-up and monitoring progrmn. Note ~at Ge monitorinz program has yet to be finalized. The City's comments on reporting requirements will b~ considered with other comments from the public on the program. If you wish to make a formal submission to the Commission on the return to service of Pickering A, interventions must be filed x~dth the the Secremra, of the Commission by July 10, 2001 to: c/o Carmen Elli'son Commission Operations Officer Canadian Nuclear SafeV Commission 280 Slater Street. P.O. Box 1046 Ottaxva, Ontario K1P 5S9 Tel.: (613) 996-2026 or 1-800-668-5284 Fax: (613) 995-5086 E-mail: intervenfions~cnsc-ccsn.gc.ca Peter Elder Acting Director Power Reactor Evaluation Division R.J. Strickert- OPG J.S.C. Tong - CNSC ATTACHMENT# ~ TO REPORT#~ ~ · D-I CMD 01-HI7 APPENDIX D REQUIRED IMPROVEMENTS AND MODIFICATIONS PART A - Safety Related Improvements and Modifications The improvements and modifications listed below must be "completed" or the intbrmation provided for each unit prior to restart of that unit and reported on in the completion assurance report, except as indicated below. "Completed" includes completion of any commissioning activities possible or practicable before restart. The remaining contrnissioning activities must be completed prior to return to service. Unless otherwise indicated, the improvements and modifications refer to those described in Revision 4 of OPG document "Picketing A - Basis tbr Return to Service", April 20, 2001. 5. 6. 7. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. Identify and install any changes to reactor operation required to conform with the resubmitted large loss-of-coolant analysis; Confirm the integrity, of the calandria vault seals and penetrations for all design basis faults; Complete installation of shutdown system emhancements as described in licence condition 10.2 ofPROI, 4.00/2003; Complete installation of seismic upgrades; Complete installation of post LOCA improvements; Complete installation of the Emergency Coolant Injection screens and strainers; Complete replacement o£ Emergency Coolant Injection shutdown cooling isolating valve actuators; Complete work on position assured components; Complete improvements to Class III service water; Complete modifications to calandria inlet valves; Complete installation of Chameleon programmable controllers; Complete improvements to auxiliary feedwater system; Complete inspection and repair of the boiler isolating Velan valves in the heat transport system; Submit report on potential flooding of site (for unit 4 only); Complete upgrade of feedwater piping; Complete modifications to power house venting; Submit report on status of maintenance program including the status of Integrated Improvement Program projects; Complete inspection of feeders for flow-assisted corrosion, outlet elbow cracking and submit results; Complete measurement of pressure tubes axial elongation as described in OPG Fuel Channel Aging and Life Cycle Management Strategy and Plan, N-PLAN-01060-10002; Complete "CIGAR" inspections on 20 fuel channels and submit results; Complete inspection of primary heat transport pressure retaining components and metallic containment components; (7MD 01 -ttl 7 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 36. 37. 38. 39. 40. 41. 42. 43. Complete reactor building pressure tests: Submit evidence that all block valves meet thc ovcrprcssure standard recluirements: Submit pressure vessel registrations lbr all out of date registrations'. Complete modifications to reduce thc core damage lkcqucncy: Complete the improvements to reduce the calculated unavailabilities of contaimnent and emergency core cooling: Implement the proposed mechanisms and actions to mitigate control room unmhabitability or unavailability and provide supporting documentation: Complete installation of the committed tire suppression systems*: Complete installation of thc tire iltai'tn and ammnciation system, including the committed incipient detection systems*: Submit evidence that adequate arrangcn2cnts arc in place with thc City of Picketing Fire I)epm'tment lbr mutual aid ai~d coordinated l~i'c response arrangements and hold a 5oint drili~ Complete site implementation of thc approved ()PO fire protection program: Complete implementation of the upgrades idcntii2cd in the Fire Protection Code Compliance Review and the Fire I tazarct :Xssessment; Submit analysis of tlac fire survivability of thc turbine building: ('omplctc upgrades to minimize oxy?n in thc condensate: Complete implementation of thc human factor's engineering program plan: Complete implementation of tho }lklllqan Ik~ctors verificatiol~ and validation plan: Complete the configuration management Master Equipment List, the operational flowsheets, flow diagrams, on-line wiring and electrical wiring diagrams for ali safety-related systems; Complete a detailed walkdown of thc safetvq'elated systems: Complete correction and updating of thc operations and maintenance procedures to be technically cmTect and consistent with thc physical plant: Submit evidence that a sufficient number of workers qualified to operate the unit safely under all operating conditions is available: Submit evidence that all workers have succoss2fllx completed refl'eshcr training ~d upgrade training appropriate to thc knoxxlcdgc and skill requirements of their position to regain their full competence. 'I'}ss evidence Niaall include such test results necessan~ to conlirm that those persons have thc knowledge and skills required to thltill the responsibilities of their position under all unit operating conditions. Complete thc pre-restart portion of the Environmental Assessment Follow-up and Monitoring Program. * The portion of these improvements related to thc turbine hall only need to be completed prior to the turbines being returned to service. D-3 CMD 01 -t t 17 PART B - Required improvements and modifications from the Environment Assessment For the purposes of the Environmental Assessment, it was assumed that a nmnber of improvements and modifications were in place. For the Environment Assessment to remain valid, these improvements mad modifications must be in place prior to a unit being returned to service. Those related to safety issues have been included in the requirements listed above. The remaining requirements are listed below. OPG has committed to have most of these in place prior to restart except those indicated below with an asterisk (*). These items will be completed prior to the turbines being returned to service. Details of these improvements and modifications are given in the Appendix L.5.2 of the Addendtm~ of the Environmental Assessment Screening Report, September 2000. The completion assurance report for each unit must include evidence that the improvements and modifications have been completed. 2. 3. 4. 5. 6. 7. 8. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. Rehabilitation of fire protection equipment Upgrade of vapour recovery Periodic inspection program of expansion joints and piping supports Spills containment and prevention Replacement or repair active liquid waste piping Outfall effluent sampling Condenser tube replacement Improved automatic intermittent injection and dechlorination for control of zebra mussels Moderator system improvements Replacement of stack monitors Replacement of PCB filled components Replacement of irradiated fuel bay heat exchangers Repair of irradiated fixel bay liner Recondition shutdown cooling system Replacement of turbine seal oil and lube oil heat exchangers* Other small oil/water interface heat exchangers will be replaced Groundwater and inactive drainage system sump smnpling to identify sources of tritium in groundwater Reduction of carbon-14 emissions from ion exchange columns Review database of preventive and con'ective maintenance activities to achieve necessary quality standards Upgrading equipment to minimize oxygen in condensate and feedwater Steam generator remediation Rehabilitation of essential reactor building air conditioning units Inspection of the Condenser Cooling Water system forebay and intake structures Reconditioning heat transport system Overhaul fueling machines Turbine generator major maintenance* D-4 CMD 01-HI 7 27. 28. 29. 30. 3 I. i:;2. 33. Fecdwater heating system upgradcs Auxiliary boiler feed system availability improvement Electrical maintenance Transformer maintenance Replacement of digital control computers Condenser Cooling Water system pulnp overhaul Control room ventilation and air conditioning rehabilitation