power bruce - canadian nuclear safety commission · bruce po\ver frank saunders vice...

$: Power Bruce - Canadian Nuclear Safety Commission · Bruce Po\ver Frank Saunders Vice President-Nuclear Oversight and Regulatory Affairs P.O. Box 1540 BlO 4th floorW Tiverton ON NOG$
Bruce PowerJanuary23,2018

NK21 -CORR-00531 -14147NK29-CORR-00531 -14834NK37-CORR-00531 -02910

Mr. B. TorrieDirector General, Regulatory Policy DirectorateCanadian Nuclear Safety CommissionP.O. Box 1046280 Slater StreetOttawa, OntarioK1P 5S9

Dear Mr. Torrie:

Bruce Power Comments on DIS-1 7-01:Framework for Recovery in the Event of a Nuclear or Radiological Emergency

The purpose of this letter is to provide Bruce Power’s comments on this Discussion Paper,which considers actions decision makers might consider prior to, or following, an emergencyresponse. Answers to the specific questions posed in the paper are detailed in theattachment to this letter. Those responses stem from our own, internal company review anda collaborative evaluation with our industry colleagues.

Lessons from the Fukushima experience helped inform our responses, including the criticalrole government support agencies play in recovery operations. Given this, there is a need toclearly define the roles and responsibilities of these support agencies well in advance of anypotential event. Similarly, the Fukushima event demonstrated the need for predefinedreference levels for the safe return to any affected area. Without these, members of theJapanese public were skeptical of the levels once they were finally determined. For fixedfacilities in Canada, it would be greatly beneficial to have set, scientifically-based referencelevels for safe return established and publicized well ahead of any potential event.

Once again, let me thank you for the opportunity to comment on this Discussion Paper. If yourequire further information or have any questions regarding this submission, please contactSteve Cannon, Senior Strategist, Nuclear Oversight and Regulatory Affairs, at(51 9)-361 -6559, or steve.cannon @ brucepower.com.

Yours truly,

Frank SaundersVice President Nuclear Oversight and Regulatory AffairsBruce Power

cc: CNSC Bruce Site Office (Letter only)K. Owen-Whitred, CNSC-Ottawa

Attach.Bruce Po\ver Frank Saunders Vice President - Nuclear Oversight and Regulatory Affairs

P.O. Box 1540 BlO 4th floorW Tiverton ON NOG 2T0NK21-CDRR-00531-14147 Telephone 519 361-5025 Facsimile 519 361-4559NK29-CORR-00531 -14834 [email protected] -02910

Attachment A

Bruce Power comments on Discussion Paper DIS-17-O1 - Framework for Recoveryin the Event of a Nuclear or Radiological Emergency

NK21 -CORR-00531 -14147NK29-CORR-00531 -14834NK37-CORR-00531 -02910

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.Do

youconsider

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appropriatein

thecontext

ofestablishing

arecovery

framew

ork?If

not,how

shouldthe

scopebe

modified

orim

proved?

To

licensees,the

scopeand

contextseem

soverly

complex,

vagueand

focusedon

what

isoutside

ofscope

ratherthan

what

isw

ithinscope.

As

aresult,

thepaper

doesnot

clearlyarticulate

what

itis

tryingto

achieve.For

example,

thenext-to-last

paragraphof

Section

2says,

“InC

anada,the

framew

orkfor

emergency

preparednessand

responseis

well

establishedand

documented

inapplicable

legislation,inform

ationand

guidancedocum

ents.”G

iventhat,

what

isthe

needfor

thisdocum

ent?

Also,

thispaper

focuseson

activitiesin

thepublic

domain

toprotect

mem

bersof

thepublic

andcontains

verylittle

thatapplies

tonuclear

facilities.Y

etthe

Executive

Sum

mary

saysthe

paper’spurpose

isto

informfuture

regulatoryguidance.

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will

adocum

entfocused

onthe

publicdom

ainapply

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CR

egulatoryD

ocuments

donot

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provincialand

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illthe

partnershipw

ithH

ealthC

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C)

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HC

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guidancewill

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aybe

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uclearInsurance

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ebsite.

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suggest:

•T

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ithinits

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hefram

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thecreation

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RE

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etailsaround

rolesand

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ance

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would

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•M

oredetails

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what,

precisely,is

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suchas

information

onw

henrecovery

startsand

ends.Sim

ilarly,m

orecontext

couldbe

add

edaround

multi-level

recovery(organizations

beingat

differentlevels

ofresponse/recovery).

•M

oredetails

couldbe

added

toclearly

showthe

linkagesbetw

eenlicen

sees,m

unicipalities,provincial

andfederal

gov

ernm

ents/ag

encies.

•S

inceem

ergencyprep

aredn

esstypically

focu

seson

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on

sep

hase

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referringto

Em

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anagement

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repared

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ouldw

edefine

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heassu

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clearly?If

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?A

uthoritiesH

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ithCSA

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there

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Astan

dard

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would

bethe

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Inthis

case,the

leadprovincial

agen

cyis

theA

HJ

with

otherfederal,

provincialand

municipal

agen

ciesin

asupporting

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Question(s)

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Additional

Com

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IP

lansfor

recoveryin

Can

ada

Q3.D

idw

ecorrectly

capturethe

existingfram

ework

forrecovery

froma

federal,provincial

andm

unicipalpoint

ofview

?If

not,p

leaseprovide

information

asyou

seeit,

accompanied

bythe

sou

rceof

information

thatsupports

yourproposal.

Q4.A

rethere

existingdocum

entsor

sources

ofinform

ationthat

providem

oreclarity?

Forthe

most

part.

How

ever,the

Departm

entof

National

Defence

(DN

D)

has

arole

toplay

inresponding

tonuclear/radiological

emerg

encies.

Their

roleis

definedin

DA

OD

8006-0,C

hemical,

Biological,

Radiological

andN

uclearD

efencelast

updatedin

August

2016.T

hisrole

need

sto

betaken

intoconsideration

indescribing

aC

anadianfram

ework

forem

ergen

cyresp

on

se.O

therwise,

avaluable

resourceis

beingoverlooked.

Also,

most

licensees

haveestablished

framew

orksto

add

resstheir

bu

siness

decisionsand

internaln

eeds

tosupport

recovery.R

ecoveryoperations

thatdo

notaffect

publicsafety

arenot

appropriatefor

thisfram

ework.

Most

licensees

maintain

busin

esscontinuity

pro

cessesfor

recoveryoperations

anddetailed

plansare

developedas

required.

Forinstance,

within

New

Brunsw

ick,the

Point

Lepreau

Nuclear

Off-site

Em

ergencyP

lanfor

Radiological

Em

ergen

ciescovers

allasp

ectsfor

theresp

onse

andrecovery.

The

municipalities

fallunder

thisplan

andw

ouldnot

havetheir

own

specificplan

forradiological

events.

The

CN

SC

couldconsider

addingan

existingplan

suchas

New

Brunsw

ick’sat:

http://w

ww

2.gnb.ca/co

nten

t/dam

/gnb

/Dep

artmen

ts/ps

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uclear/PointL

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Section

Question(s)

IR

esponsesto

Questions

IA

dditionalC

omm

ents

Q5.A

tthe

prep

aredness

stage,

doyou

considerthat

itis

possibleto

establisha)

responsibilityand

accountabilityduring

recoveryand

b)a

mechanism

forthe

transferof

responsibilitiesthat

will

takeplace

duringthe

transitionbetw

eenthe

emergency

andthe

recoveryphases?

Ifso,

how?

Ifnot,

why?

Yes,

we

feelit

ispossible

toestablish

responsibilities,accountabilities

anda

transferm

echanismduring

thisp

hase.

Robust

procedures,specific

trainingand

exercises--

includingform

alturnovers

--

helpen

sure

rolesand

responsibilitiesare

addressed

.M

uchof

thisis

alreadyin

place.For

example,

Bruce

Pow

er’sp

rocess

seesits

executiveleaders

(theC

risisM

anagement

Team

)appoint

anE

mergency

Recovery

Director,

who

putsa

teamin

placeto

assum

econtrol

fromthe

Com

mander

ofthe

Em

ergencyM

anagement

Centre.

This

ensu

resa

successfultransition

fromem

ergencyto

recoveryand

providesflexibility

forthe

Recovery

Director

tocustom

izehis

team,

sinceem

ergen

ciescan

presen

tvery

differentrecovery

requirements.

While

stabilityof

thesituation

isa

primary

responsibilityof

thelicensee

—and

considerationshould

bead

ded

toclarify

thisin

futureguidance

--

theprovince

isstill

thelead

beyondsite

boundaries.T

herefore,the

transferof

responsibilitiesw

illonly

bebetw

eengovernm

entsupport

organizations.

Based

onthe

Fukushim

aexperience,

therole

ofgovernm

entsupport

organizationsis

significantand

criticalto

success.

As

aresult,

theroles

andresponsibilities

ofgovernm

entsupport

agen

cieshave

tobe

documented

andag

reedto

well

inadvance

ofany

potentialevent.

Although

thisis

possible,it

shouldalso

berecognized

thatreso

urces

usedin

eventresp

onse

will

likelybe

usedfor

recovery.C

onsideringthat

respon

seand

recoveryfrom

aradiological

eventcould

takew

eeks,m

onthsor

evenyears,

resou

rcesw

illhave

tobe

managed

atthe

utility,m

uniciraland

provinciallevel.

Sm

aller

Transition

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Em

ergen

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Q6.D

oyou

agreethat

theresponsible

recoverym

anagement

organizationshould

havethe

authorityto

selectthe

appropriatereference

levelvalue(s)

within

theband

of1—

20m

Sv?

Q7.D

oyou

agreethat

thevalue

shouldbe

setat

theend

ofthe

emergency

situationand

shouldbe

periodicallyre

evaluatedthroughout

therecovery?

Ifyou

donot

agree,please

indicatew

hy,as

well

asw

hoshould

selectthe

valuesand

when

thatdecision

shouldbe

taken.

Yes.

How

ever,values

will

bem

uchdifferent

forN

uclearE

nergyW

orkers(N

EW

s)perform

ingrecovery

activitieson

site.T

hisshould

behighlighted.

Fortransportation

accidents,itw

ouldm

akesen

seto

setthe

valueat

theend

ofthe

emergency

situation.

How

ever,industry

proposessetting

thevalue

aheadof

anyem

ergencysituation

forfixed

facilitiessuch

asnuclear

power

plants.O

neof

thelessons

fromF

ukushima

was

thatthe

Japan

esegovernm

entdid

nothave

predefinedreference

levelsfor

safereturns

tothe

affectedarea.

This

resultedin

mistrust

bythe

publicw

henlevels

were

finallydeterm

ined.Ifthis

isdone

inadvance

--

with

scientificbacking

--

thenitw

illenhance

publicconfidence

inthe

level.

The

recoveryshould

bestaged

with

predefinedreference

levelsand

theevaluation

focuson

thestate

ofprogress

throughthe

recoverystages,

butnot

redefiningthe

referencelevels.

Itiscritical

thatreference

levelsbe

predetermined,

usinga

solidscientific

basisand

thatbasis

betransparent.

Protecting

thepublic S

ectionQ

uestion(s)I

Resp

onses

toQ

uestionsI

Additional

Com

ments

organizationsm

aynot

practicallybe

ableto

changeout

allindividuals

usedfor

responseas

theytransition

torecovery.

Partially.

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Em

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Sectio

nQ

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IR

espo

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to

Questions

IA

dditional

Com

ments

Return

toa

Q8.W

asthe

conceptof

thenew

normal

well

While

thekey

con

cepts

arehere,

introducingthe

conceptA

snoted

inQ

7,for

fixedfacilities,

itwould

benew

normal

explained?W

hatadditional

information

ofa

‘newnorm

al’seem

scounterproductive.

The

textis

greatlybeneficial

tohave

set,scientifically-

shouldbe

providedto

clarifythe

fine,but

tolabel

itin

thisw

aygives

asom

ewhat

negativeb

asedreference

levelsfor

safereturn

con

cept?

impression

--

almost

likesaying,

“This

isthe

best

we

canestab

lished

andpublicized

ahead

ofany

do,so

youm

ightas

well

getused

toit.”

Infuture

event(the

ICR

Preference

levelscould

bedocum

ents,it

would

bebetter

tosim

plyrefer

tothe

returnused).

This

will

aidin

publicaccep

tance.

toaffected

areas.Sim

ilarly,the

term“contam

inatedland”

isunnecessarily

alarmist

andbetter

describedas

theR

atherthan

say...

“shouldbe

allowed

tolive

“affectedarea.”

incontam

inatedareas,”

thedocum

entshould

state.

..“shouldbe

allowed

tolive

inareas

Also,

theconcept

may

needso

me

additionaldetail

tow

ithso

me

residuallevels

ofelevated

ensurepublic

understanding.F

orinstance,

will

there

beradioactivity,

providingthe

overallrisk

tothe

exceptions,such

aspregnant

wom

an,w

henindividuals

publicis

deem

edacceptable.”

areallow

edto

livein

acontam

inatedarea?

Should

the‘new

normal’

alsorecognize

potentialrealities

suchas

theloss

ofelectricity

generationfor

theprovince

ifunits

aresep

aratedfrom

thegrid?

Additional

guidanceor

examples

aroundlevels

thatare

higherthan

pre

emergency

conditionsw

ouldbe

helpful,as

well

asexplanations

abouthow

radiologicalrisk

isdeterm

inedand

who

comm

unicatesth

ose

risks.

Implem

entingQ

9.Did

we

capturethe

protectiveactions

Not

entirelyas

thediscussion

pap

eris

usingreference

Itis

criticalthat

discu

ssion

son

protectiveR

ecoveryaccurately?

Ifnot,

what

modifications

orlevels

aslim

its.C

onsiderationscould

bem

adefor

theactions

beheld

with

anypotentially

affectedS

trategies

additionsdo

youpropose?

harvestingof

wildlife

andaquaculture

comm

unityduring

thisplanning

ph

ase.T

hisw

illen

sure

comm

onunderstanding

ofw

hatth

ose

actionsm

eanand

why

theym

ightbe

implem

entedfor

differentsituations.

Q1O

.D

oyou

agreew

iththe

delineationof

Yes.

thetw

otypes

ofprotective

actions?A

reS

uggest

rewriting

theph

rase,“D

uringthe

there

othertypes

ofprotective

actionsrecovery

phase,

newprotective

actionsm

aythat

havenot

beenco

nsid

ered?

Ifso,

needto

betaken

tom

aintaindosos

belowthe

what

arethey?

decirodroforenco

lovolfurther

reduceradiation

do

sesas

partof

theongoing

optimization

process.”

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ecovery

inth

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uclear

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adio

logical

Em

ergen

cy

Section

Question(s)

IR

espo

nses

toQ

uestionsI

Additional

Com

ments

Environm

ental01

1.D

idw

em

akethe

correctassum

ptionsY

es,though

considerationshould

begiven

tom

onitoringIt

iscritical

thatw

edevelop

asingle,

andfood

chainregarding

environmental

andfood

chainof

fishand

wildlife

--

particularlyw

ildlifethat

Ishunted

forconsolidated

guidelinefor

alljurisdictions.m

onitoringm

onitoring?If

not,w

hatare

we

food--

asthese

transientanim

alsm

aym

ovein

andout

ofT

hiswill

alsosupport

theintegration

ofthe

missing?

contaminated

zones(this

isnot

explicitlycovered),

roleof

government

supportorganizations.

01

2.

Did

we

adequatelydescribe

theneed

Yes

forenvironm

entaland

foodchain

monitoring

inthe

recoveryphase?

Isthere

information

aboutthe

needfor

environmental

andfood

chainm

onitoringthat

shouldbe

added?Ifso,

what

information?

Exposure

01

3.

Did

we

make

thecorrect

assumptions

Not

entirely.pathw

aysand

regardingexposure

pathways

anddose

With

regardto

externaldose,

experiencefrom

Fukushim

adose

assessmen

ts?If

not,w

hatare

we

shows

thatenvironm

entalm

onitoringcan

significantlyassessm

ents

missing?

overestimate

thedoses

when

compared

topersonal

dosimetry.

At

am

inimum

,external

dosesbased

uponenvironm

entalm

onitoringneed

tobe

validatedw

ithpersonal

dosimetry.

Health

014.D

idw

eidentify

allthe

necessaryFor

thegeneral

public,itis

criticalthat

more

claritybe

monitoring

components

regardingthe

healthprovided

regardingw

how

ouldbe

responsiblefor

what

monitoring

program?

Ifnot,

what

arew

easp

ectsof

them

onitoring.Industry

proposesthat

high-m

issing?level

healthm

onitoringplans

bedeveloped

aheadof

anypotential

emergency.

This

will

make

recoverym

ucheasier

thantrying

todevelop

themon

thefly.

This

couldbe

developedas

anA

ppendixto

aC

SAdocum

enton

recovery.

Forthe

licenseew

orkforce,itis

important

forthe

CN

SCto

recognizethat

provincialhealth

insuranceprogram

sw

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Bruce Power comments on Discussion Paper DIS-17-01 - Framework for Recovery in the Event of a Nuclear or Radiological Emergency

Section Question(s) Responses to Questions Additional Comments

NK21-CORR-00531-14147 / NK29-CORR-00531-14834 / NK37-CORR-00531-02910 Page 1 of 10

Scope Q1. Do you consider the scope appropriate in the context of establishing a recovery framework? If not, how should the scope be modified or improved?

To licensees, the scope and context seems overly complex, vague and focused on what is outside of scope rather than what is within scope. As a result, the paper does not clearly articulate what it is trying to achieve. For example, the next-to-last paragraph of Section 2 says, “In Canada, the framework for emergency preparedness and response is well established and documented in applicable legislation, information and guidance documents.” Given that, what is the need for this document? Also, this paper focuses on activities in the public domain to protect members of the public and contains very little that applies to nuclear facilities. Yet the Executive Summary says the paper’s purpose is to inform future regulatory guidance. How will a document focused on the public domain apply to licensees since CNSC Regulatory Documents do not apply to provincial and municipal authorities? Will the partnership with Health Canada (HC) in the development of this framework lead to an HC document that could apply to those authorities? It’s not clear on how this document and resulting guidance will be used in the future. As this discussion progresses, licensees suggest:

There needs to be a clear understanding that a regulatory framework does not impede business decisions a utility might make within its own recovery operations for events that do not impose public safety risks.

The framework should develop scope to support a CSA standard on recovery, not the creation of another REGDOC. Details around roles and responsibilities of key stakeholders should be

It may be appropriate to have a link to the Nuclear Insurance Association of Canada website.




addressed in the CSA standard.

It would be beneficial to include a specific reference to safe dose reference levels for the lifting of protective actions. Having thresholds for habitability or returns (post evacuation and sheltering) clearly set in advance of an accident scenario -- with scientific backing to these “safe return limits” -- would help ease potential confusion.

More details could be added on what, precisely, is in scope such as information on when recovery starts and ends. Similarly, more context could be added around multi-level recovery (organizations being at different levels of response/recovery).

More details could be added to clearly show the linkages between licensees, municipalities, provincial and federal governments/agencies.

Since emergency preparedness typically focuses on the response phase of a nuclear or radiological emergency, the CNSC could consider referring to Emergency Management as was done in section 2.0. Preparedness and Response are only two cornerstones.

Q2. Could we define our assumptions more clearly? If so, how?

Yes. The assumptions should more clearly identify

Authorities Having Jurisdiction (AHJs) to be consistent with CSA N1600. Also, there should be an understanding

that a CSA standard on recovery would be the preferred vehicle to address requirements. In this case, the lead provincial agency is the AHJ with other federal, provincial and municipal agencies in a supporting role.




Plans for recovery in

Canada

Q3. Did we correctly capture the existing framework for recovery from a federal, provincial and municipal point of view? If not, please provide information as you see it, accompanied by the source of information that supports your proposal.

For the most part. However, the Department of National Defence (DND) has a role to play in responding to nuclear/radiological emergencies. Their role is defined in DAOD 8006-0, Chemical, Biological, Radiological and Nuclear Defence last updated in August 2016. This role needs to be taken into consideration in describing a Canadian framework for emergency response. Otherwise, a valuable resource is being overlooked. Also, most licensees have established frameworks to address their business decisions and internal needs to support recovery. Recovery operations that do not affect public safety are not appropriate for this framework.

Q4. Are there existing documents or sources of information that provide more clarity?

Most licensees maintain business continuity processes for recovery operations and detailed plans are developed as required. For instance, within New Brunswick, the Point Lepreau Nuclear Off-site Emergency Plan for Radiological Emergencies covers all aspects for the response and recovery. The municipalities fall under this plan and would not have their own specific plan for radiological events. The CNSC could consider adding an existing plan such as New Brunswick’s at:

http://www2.gnb.ca/content/dam/gnb/Departments/ps-sp/pdf/emo/Nuclear/PointLepreau-NOEM.pdf






Transition Q5. At the preparedness stage, do you consider that it is possible to establish a) responsibility and accountability during recovery and b) a mechanism for the transfer of responsibilities that will take place during the transition between the emergency and the recovery phases? If so, how? If not, why?

Yes, we feel it is possible to establish responsibilities, accountabilities and a transfer mechanism during this phase. Robust procedures, specific training and exercises -- including formal turnovers -- help ensure roles and responsibilities are addressed. Much of this is already in place. For example, Bruce Power’s process sees its executive leaders (the Crisis Management Team) appoint an Emergency Recovery Director, who puts a team in place to assume control from the Commander of the Emergency Management Centre. This ensures a successful transition from emergency to recovery and provides flexibility for the Recovery Director to customize his team, since emergencies can present very different recovery requirements. While stability of the situation is a primary responsibility of the licensee – and consideration should be added to clarify this in future guidance -- the province is still the lead beyond site boundaries. Therefore, the transfer of responsibilities will only be between government support organizations. Based on the Fukushima experience, the role of government support organizations is significant and critical to success. As a result, the roles and responsibilities of government support agencies have to be documented and agreed to well in advance of any potential event. Although this is possible, it should also be recognized that resources used in event response will likely be used for recovery. Considering that response and recovery from a radiological event could take weeks, months or even years, resources will have to be managed at the utility, municipal and provincial level. Smaller




organizations may not practically be able to change out all individuals used for response as they transition to recovery.

Protecting the public

Q6. Do you agree that the responsible recovery management organization should have the authority to select the appropriate reference level value(s) within the band of 1–20 mSv?

Yes. However, values will be much different for Nuclear Energy Workers (NEWs) performing recovery activities on site. This should be highlighted.

Q7. Do you agree that the value should be set at the end of the emergency situation and should be periodically re-evaluated throughout the recovery? If you do not agree, please indicate why, as well as who should select the values and when that decision should be taken.

Partially. For transportation accidents, it would make sense to set the value at the end of the emergency situation. However, industry proposes setting the value ahead of any emergency situation for fixed facilities such as nuclear power plants. One of the lessons from Fukushima was that the Japanese government did not have predefined reference levels for safe returns to the affected area. This resulted in mistrust by the public when levels were finally determined. If this is done in advance -- with scientific backing -- then it will enhance public confidence in the level. The recovery should be staged with predefined reference levels and the evaluation focus on the state of progress through the recovery stages, but not redefining the reference levels. It is critical that reference levels be predetermined, using a solid scientific basis and that basis be transparent.




Return to a new normal

Q8. Was the concept of the new normal well explained? What additional information should be provided to clarify the concept?

While the key concepts are here, introducing the concept of a ‘new normal’ seems counterproductive. The text is fine, but to label it in this way gives a somewhat negative impression -- almost like saying, “This is the best we can do, so you might as well get used to it.” In future documents, it would be better to simply refer to the return to affected areas. Similarly, the term “contaminated land” is unnecessarily alarmist and better described as the “affected area.” Also, the concept may need some additional detail to ensure public understanding. For instance, will there be exceptions, such as pregnant woman, when individuals are allowed to live in a contaminated area? Should the ‘new normal’ also recognize potential realities such as the loss of electricity generation for the province if units are separated from the grid? Additional guidance or examples around levels that are higher than pre-emergency conditions would be helpful, as well as explanations about how radiological risk is determined and who communicates those risks.

As noted in Q7, for fixed facilities, it would be greatly beneficial to have set, scientifically-based reference levels for safe return established and publicized ahead of any event (the ICRP reference levels could be used). This will aid in public acceptance. Rather than say … “should be allowed to live in contaminated areas,” the document should state …“should be allowed to live in areas with some residual levels of elevated radioactivity, providing the overall risk to the public is deemed acceptable.”

Implementing Recovery Strategies

Q9. Did we capture the protective actions accurately? If not, what modifications or additions do you propose?

Not entirely as the discussion paper is using reference levels as limits. Considerations could be made for the harvesting of wildlife and aquaculture

It is critical that discussions on protective actions be held with any potentially affected community during this planning phase. This will ensure common understanding of what those actions mean and why they might be implemented for different situations. Suggest rewriting the phrase, “During the recovery phase, new protective actions may need to be taken to maintain doses below the desired reference level further reduce radiation doses as part of the ongoing optimization process.”

Q10. Do you agree with the delineation of the two types of protective actions? Are there other types of protective actions that have not been considered? If so, what are they?

Yes.




Environmental and food chain monitoring

Q11. Did we make the correct assumptions regarding environmental and food chain monitoring? If not, what are we missing?

Yes, though consideration should be given to monitoring of fish and wildlife -- particularly wildlife that Is hunted for food -- as these transient animals may move in and out of contaminated zones (this is not explicitly covered).

It is critical that we develop a single, consolidated guideline for all jurisdictions. This will also support the integration of the role of government support organizations.

Q12. Did we adequately describe the need for environmental and food chain monitoring in the recovery phase? Is there information about the need for environmental and food chain monitoring that should be added? If so, what information?

Yes

Exposure pathways and dose assessments

Q13. Did we make the correct assumptions regarding exposure pathways and dose assessments? If not, what are we missing?

Not entirely. With regard to external dose, experience from Fukushima shows that environmental monitoring can significantly overestimate the doses when compared to personal dosimetry. At a minimum, external doses based upon environmental monitoring need to be validated with personal dosimetry.

Health monitoring

Q14. Did we identify all the necessary components regarding the health monitoring program? If not, what are we missing?

For the general public, it is critical that more clarity be provided regarding who would be responsible for what aspects of the monitoring. Industry proposes that high-level health monitoring plans be developed ahead of any potential emergency. This will make recovery much easier than trying to develop them on the fly. This could be developed as an Appendix to a CSA document on recovery. For the licensee workforce, it is important for the CNSC to recognize that provincial health insurance programs which monitor health already exist. Licensees do provide counselling, psychological and psychosocial support when requested, but not medical monitoring for all workers. Medical physician(s) would be sought when there was any health concern. Introducing the requirement to establish a health monitoring program




would require a change in the legislative framework (e.g. Nuclear Safety Control Act (NSCA), Privacy Act or pertinent regulations. As this subject progresses, industry suggests it is appropriate for licensees to provide counselling, psychological and psychosocial support for individual(s) who participated in the control of an emergency upon request. Special attention or follow-up would also be offered individual(s) who may have received a dose exceeding 50 mSv (5 rem) during and post emergency response activities.

Managing contamination

Q15. Did we make the correct assumptions regarding decontamination? If not, what are we missing?

Yes. Acceptable as-left levels of contamination should be set ahead of any emergency. This should follow the same strategy suggested for dose. Decontamination is addressed, but given the complexities associated with an event, it would be difficult to go into more depth of options or “what ifs.” It is critical that the reference levels be predetermined, using a solid scientific basis and that basis be transparent. In general, industry supports the overall objective as indicated in the paper to return occupants to their homes as soon as possible.

Q16. Did we capture the decontamination elements accurately? If not, what modifications or additions are you proposing?

Yes.

Q17. Are there other types of clean-up activities besides decontamination that need to be discussed in more detail? If so, what activities and what information is required?

No.

Waste management

Q18. Did we make the correct assumptions regarding waste management? If not, what are we missing?

Yes. For large releases, the majority of the waste could be soil, which is not easily volume-reduced. This is why it is important to define




Q19. Did we capture the waste management elements accurately? If not, what modifications or additions do you propose?

Yes. acceptable as-left levels of contamination ahead of any emergency and that there be resources and plans developed in advance to clean up the waste as soon as possible. Fukushima is a good example of this, where decontamination efforts have resulted in large amounts of contaminated soil as waste.

Protecting the public during recovery

Q20. Did we make the correct assumptions regarding the key recovery elements? If not, what are we missing?

Yes Resources should be identified and plans developed in advance to clean up the waste as soon as possible

Q21. Did we capture the key recovery elements accurately? If not, what modifications or additions do you propose?

Yes

Q22. Is the level of information provided is adequate? If not, what subject needs to be described in more detail? Or what are the elements that we did not describe (if any)?

Yes

Protecting recovery workers

Q23. What additional details would be valuable on this topic in the framework?

Industry would like to see details around the use of personal protective equipment (PPE) for recovery workers during this phase. This is a key part of response, but needs to be carried over and given the same rigor. Doses received by persons involved in the control of an emergency are treated separately from those received from planned occupational exposures, which include recovery efforts. Similarly, a distinction should be made with respect to radiation exposures received by workers during recovery efforts as a consequence of their occupation and those received as a result of exposures due to environmental conditions resulting from the emergency. Such a statement should also be included in

As previously stated, it is preferred that any framework for recovery be developed through the CSA process, not a REGDOC. The use of a CSA standard would assist in the harmonizing of government support agencies and the development of a single consolidated guideline for all jurisdictions and support the definition of accountabilities for all parties




Section 15 of the Radiation Protection Regulations; SOR 2000/2003 (published Sept 22, 2017).

Public communication considerations during recovery

Q24. Did we capture the communication considerations during recovery accurately? If not, what modifications or additions do you propose?

Yes, though it would helpful to say that communications need to be completed in a timely manner and be consistently updated.

In this area, it is very important that the Authority Having Jurisdiction (AHJ) have oversight on communications being distributed out by supporting agencies. The statement on consistent messages is paramount for public confidence.

Q25. Is the level of information provided adequate? If not, what subject needs to be described in more details? Or what are the elements that we did not describe (if any)?

Yes