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Bruce Power January23,2018 NK21 -CORR-00531 -14147 NK29-CORR-00531 -14834 NK37-CORR-00531 -02910 Mr. B. Torrie Director General, Regulatory Policy Directorate Canadian Nuclear Safety Commission P.O. Box 1046 280 Slater Street Ottawa, Ontario K1P 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 emergency response. Answers to the specific questions posed in the paper are detailed in the attachment to this letter. Those responses stem from our own, internal company review and a collaborative evaluation with our industry colleagues. Lessons from the Fukushima experience helped inform our responses, including the critical role government support agencies play in recovery operations. Given this, there is a need to clearly define the roles and responsibilities of these support agencies well in advance of any potential event. Similarly, the Fukushima event demonstrated the need for predefined reference levels for the safe return to any affected area. Without these, members of the Japanese public were skeptical of the levels once they were finally determined. For fixed facilities in Canada, it would be greatly beneficial to have set, scientifically-based reference levels 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 you require further information or have any questions regarding this submission, please contact Steve Cannon, Senior Strategist, Nuclear Oversight and Regulatory Affairs, at (51 9)-361 -6559, or steve.cannon @ brucepower.com. Yours truly, Frank Saunders Vice President Nuclear Oversight and Regulatory Affairs Bruce 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 2T0 NK21-CDRR-00531-14147 Telephone 519 361-5025 Facsimile 519 361-4559 NK29-CORR-00531 -14834 [email protected] NK37-CORR-00531 -02910

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  • 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 Powers 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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    Qi

    .Do

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    thescope

    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

    paperspurpose

    isto

    informfuture

    regulatoryguidance.

    How

    will

    adocum

    entfocused

    onthe

    publicdom

    ainapply

    tolicensees

    sinceC

    NS

    CR

    egulatoryD

    ocuments

    donot

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    provincialand

    municipal

    authorities?W

    illthe

    partnershipw

    ithH

    ealthC

    anada(H

    C)

    inthe

    development

    ofthis

    framew

    orklead

    toan

    HC

    document

    thatcould

    applyto

    thoseauthorities?

    Itsnot

    clearon

    howthis

    document

    andresulting

    guidancewill

    beused

    inthe

    future.

    Itm

    aybe

    appropriateto

    havea

    linkto

    theN

    uclearInsurance

    Association

    ofC

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    As

    thisdiscussion

    progresses,licensees

    suggest:

    T

    hereneeds

    tobe

    aclear

    understandingthat

    aregulatory

    framew

    orkdoes

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    pedebusiness

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    utilitym

    ightm

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    own

    recoveryoperations

    forevents

    thatdo

    notim

    posepublic

    safetyrisks.

    T

    hefram

    ework

    shoulddevelop

    scopeto

    supporta

    CSA

    standardon

    recovery,not

    thecreation

    ofanother

    RE

    GD

    CC

    .D

    etailsaround

    rolesand

    resronsibilitiesof

    keystakeholders

    shouldbe

    Scope

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    Itwould

    bebeneficial

    toinclude

    aspecific

    reference

    tosafe

    dose

    referencelevels

    forthe

    liftingof

    protectiveactions.

    Having

    thresh

    old

    sfor

    habitabilityor

    returns(post

    evacuationand

    sheltering)clearly

    setin

    adv

    ance

    ofan

    accidentscen

    ario--

    with

    scientificbacking

    toth

    esesafe

    returnlim

    its--

    would

    helpease

    potentialconfusion.

    M

    oredetails

    couldbe

    add

    edon

    what,

    precisely,is

    insco

    pe

    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

    theresp

    on

    sep

    hase

    ofa

    nuclearor

    radiologicalem

    ergency,the

    CN

    SC

    couldconsider

    referringto

    Em

    ergencyM

    anagement

    asw

    asdone

    insection

    2.0.P

    repared

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    andR

    esponse

    areonly

    two

    corn

    erston

    es.

    Q2.C

    ouldw

    edefine

    ourassum

    ptionsm

    oreY

    es.T

    heassu

    mp

    tion

    sshould

    more

    clearlyidentify

    clearly?If

    so,how

    ?A

    uthoritiesH

    avingJurisdiction

    (AH

    Js)to

    beco

    nsisten

    tw

    ithCSA

    N1600.

    Also,

    there

    shouldbe

    anunderstanding

    thata

    CS

    Astan

    dard

    onrecovery

    would

    bethe

    preferredvehicle

    toad

    dress

    requirements.

    Inthis

    case,the

    leadprovincial

    agen

    cyis

    theA

    HJ

    with

    otherfederal,

    provincialand

    municipal

    agen

    ciesin

    asupporting

    role.

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    espo

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    uestionsI

    Additional

    Com

    ments

    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

    icksat:

    http://w

    ww

    2.gnb.ca/co

    nten

    t/dam

    /gnb

    /Dep

    artmen

    ts/ps

    sp/p

    df/em

    o/N

    uclear/PointL

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    EM

    .pdf

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    Question(s)

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    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

    ersp

    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 Section

    Question(s)

    IR

    espo

    nses

    toQ

    uestionsI

    Additional

    Com

    ments

    organizationsm

    aynot

    practicallybe

    ableto

    changeout

    allindividuals

    usedfor

    responseas

    theytransition

    torecovery.

    Partially.

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    dditional

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    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

    alseem

    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

    termcontam

    inatedland

    isunnecessarily

    alarmist

    andbetter

    describedas

    theR

    atherthan

    say...

    shouldbe

    allowed

    tolive

    affectedarea.

    incontam

    inatedareas,

    thedocum

    entshould

    state.

    ..shouldbe

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    Pap

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    Q19.

    Did

    we

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    waste

    Yes.

    acceptableas-left

    levelsof

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    Ifahead

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    inadvance

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    upthe

    waste

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    Fukushim

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    example

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    decontamination

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    soonas

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    Q21.

    Did

    we

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    Yes

    elements

    accurately?If

    not,w

    hatm

    odificationsor

    additionsdo

    youpropose?

    Q22.

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    levelof

    information

    providedis

    Yes

    adequate?If

    not,w

    hatsubject

    needsto

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    Q23.

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    As

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    15of

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    Q24.

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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

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    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 papers 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? Its 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.

  • 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 2 of 10

    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.

  • 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 3 of 10

    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 Brunswicks at:

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

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

  • 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 4 of 10

    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 Powers 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

  • 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 5 of 10

    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 120 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.

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    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.

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    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

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    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

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    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

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    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

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