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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 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
Bru
ceP
ow
erco
mm
ents
onD
iscussio
nP
aper
DIS-17-O
1-
Fram
ewo
rkfor
Reco
very
inth
eE
ventof
aN
uclear
orR
adio
logical
Em
ergen
cy
(S
ectionQ
uestion(s)I
Resp
on
sesto
Questions
IA
dditionalC
omm
entsI
Qi
.Do
youconsider
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
paper’spurpose
isto
informfuture
regulatoryguidance.
How
will
adocum
entfocused
onthe
publicdom
ainapply
tolicensees
sinceC
NS
CR
egulatoryD
ocuments
donot
applyto
provincialand
municipal
authorities?W
illthe
partnershipw
ithH
ealthC
anada(H
C)
inthe
development
ofthis
framew
orklead
toan
HC
document
thatcould
applyto
thoseauthorities?
It’snot
clearon
howthis
document
andresulting
guidancewill
beused
inthe
future.
Itm
aybe
appropriateto
havea
linkto
theN
uclearInsurance
Association
ofC
anadaw
ebsite.
As
thisdiscussion
progresses,licensees
suggest:
•T
hereneeds
tobe
aclear
understandingthat
aregulatory
framew
orkdoes
notim
pedebusiness
decisionsa
utilitym
ightm
akew
ithinits
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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ceP
ow
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ents
on
Discu
ssion
Pap
erD
IS-17-O1
-F
ramew
ork
for
Reco
very
inth
eE
ven
tof
aN
uclear
or
Rad
iolo
gical
Em
ergen
cy
Section
Question(s)
IR
espo
nses
toQ
uestio
ns
IA
dditionalC
omm
entsI
add
ressedin
theC
SAstan
dard
.•
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
ese“safe
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
ness
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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ceP
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onD
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DIS-17-O
1-
Fram
ewo
rkfo
rR
ecovery
inth
eE
ven
tof
aN
uclear
orR
adio
logical
Em
ergen
cy
Section
Question(s)
IR
espo
nses
toQ
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
ick’sat:
http://w
ww
2.gnb.ca/co
nten
t/dam
/gnb
/Dep
artmen
ts/ps
sp/p
df/em
o/N
uclear/PointL
epreau-NO
EM
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21-CO
RR
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K29-C
OR
R-00531-14834
/N
K37-C
OR
R-00531-02910
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e3
of10
Bru
ceP
ow
erco
mm
ents
onD
iscussio
nP
aper
DIS-17-O
1-
Fram
ewo
rkfor
Reco
very
inth
eE
ven
tof
aN
uclear
or
Rad
iolo
gical
Em
ergen
cy
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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10
Bru
ceP
ow
erco
mm
ents
onD
iscussio
nP
aper
DIS-17-O
1-
Fram
ewo
rkfor
Reco
very
inth
eE
ventof
aN
uclear
orR
adio
logical
Em
ergen
cy
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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e5
of10
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ce
Pow
er
com
ments
on
Discu
ssio
nP
aper
DIS
-1
7-O
1-
Fram
ew
ork
for
Recovery
in
the
Ev
en
tof
aN
uclear
or
Rad
io
lo
gical
Em
ergen
cy
Sectio
nQ
uestion(s)
IR
espo
nses
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.”
NK
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Pag
e6
of
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ceP
ower
com
men
tson
Discu
ssion
Pap
erD
IS-17-O1
-F
ramew
ork
forR
ecovery
inth
eE
ventof
aN
uclear
orR
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
hichm
onitorhealth
alreadyexist.
Licensees
doprovide
counselling,psychological
andpsychosocial
supportw
henrequested,
butnot
medical
monitoring
forall
workers.
Medical
physician(s)w
ouldbe
soughtw
henthere
was
anyhealth
concern.Introducing
therequirem
entto
establisha
healthm
onitoringprogram
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ap
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-17-O
1-
Fram
ew
ork
fo
rR
ecovery
in
the
Ev
en
tof
aN
uclear
or
Rad
iolo
gical
Em
ergency
Section
Question(s)
IR
espo
nses
to
Qu
estio
ns
Add
ition
al
Com
ments
would
requirea
changein
thelegislative
framew
ork(e.g.
Nuclear
Safety
Control A
ct(N
SCA
),P
rivacyA
ct orpertinent
regulations.A
sthis
subjectpro
gresses,
industrysu
ggests
itis
appropriatefor
licensees
toprovide
counselling,psychological
andpsychosocial
supportfor
individual(s)w
hoparticipated
inthe
controlof
anem
ergencyupon
request.S
pecialattention
orfollow
-upw
ouldalso
beoffered
individual(s)w
hom
ayhave
receiveda
dose
exceeding50
mS
v(5
rem)
duringand
postem
ergen
cyresp
on
seactivities.
Managing
Q15.
Did
we
make
thecorrect
assum
ptio
ns
Yes.
Acceptable
as-leftlevels
ofcontam
inationcontam
inationregarding
decontamination?
Ifnot,
what
shouldbe
setah
eadof
anyem
ergency.T
hisare
we
missing?
shouldfollow
thesam
estrategy
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estedfor
dose.
Qi
6.D
idw
ecapture
thedecontam
inationY
es.D
econtamination
isad
dressed
,but
giventhe
elemen
tsaccurately?
Ifnot,
what
complexities
associated
with
anevent,
itm
odificationsor
additionsare
youw
ouldbe
difficultto
gointo
more
depthof
proposing?options
or“w
hatifs.”
Q17.
Are
thereother
typ
esof
clean-upN
o.It
iscritical
thatthe
referencelevels
be
activitiesb
esides
decontamination
thatpredeterm
ined,using
asolid
scientificb
asis
need
tobe
discu
ssedin
more
detail?If
andthat
basisbe
transparent.
so,w
hatactivities
andw
hatinform
ationis
required?In
general,industry
supp
orts
theoverall
objectiveas
indicatedin
thepaper
toreturn
occu
pan
tsto
theirhom
esas
soonas
possible.W
asteQ
i 8.D
idw
em
akethe
correctassu
mp
tion
sY
es.F
orlarge
releases,the
majority
ofthe
waste
man
agem
ent
regardingw
astem
anag
emen
t?If
not,could
besoil,
which
isnot
easilyv
olu
me
what
arew
em
issing?reduced.
This
isw
hyit
isim
portantto
define
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on
Discussion
Pap
er
DIS
-17-O
1-
Fram
ew
ork
fo
rR
ecovery
in
the
Event
of
aN
uclear
or
Radiological
Em
erg
ency
Section
Question(s)
IR
esp
on
ses
to
Qu
estio
ns
IA
dd
itio
nal
Com
ments
Q19.
Did
we
capturethe
waste
Yes.
acceptableas-left
levelsof
contamination
managem
entelem
entsaccurately?
Ifahead
ofany
emergency
andthat
therebe
not,w
hatm
odificationsor
additionsdo
resourcesand
plansdeveloped
inadvance
toyou
propose?clean
upthe
waste
assoon
aspossible.
Fukushim
ais
agood
example
ofthis,
where
decontamination
effortshave
resultedin
largeam
ountsof
contaminated
soilas
waste.
Protecting
theQ
20.D
idw
em
akethe
correctassum
ptionsY
esR
esourcesshould
beidentified
andplans
publicduring
regardingthe
keyrecovery
elements?
Ifdeveloped
inadvance
toclean
upthe
waste
recoverynot,
what
arew
em
issing?as
soonas
possible
Q21.
Did
we
capturethe
keyrecovery
Yes
elements
accurately?If
not,w
hatm
odificationsor
additionsdo
youpropose?
Q22.
Isthe
levelof
information
providedis
Yes
adequate?If
not,w
hatsubject
needsto
bedescribed
inm
oredetail?
Or
what
arethe
elements
thatw
edid
notdescribe_(if_any)?
Protecting
Q23.
What
additionaldetails
would
beIndustry
would
liketo
seedetails
aroundthe
useof
As
previouslystated,
itis
preferredthat
anyrecovery
valuableon
thistopic
inthe
framew
ork?personal
protectiveequipm
ent(PPE
)for
recoveryfram
ework
forrecovery
bedeveloped
throughw
orkersw
orkersduring
thisphase.
This
isa
keypart
ofresponse,
theC
SAprocess,
nota
RE
GD
OC
.T
heuse
butneeds
tobe
carriedover
andgiven
thesam
erigor,
ofa
CSA
standardw
ouldassist
inthe
harmonizing
ofgovernm
entsupport
agenciesD
osesreceived
bypersons
involvedin
thecontrol
ofan
andthe
development
ofa
singleconsolidated
emergency
aretreated
separatelyfrom
thosereceived
guidelinefor
alljurisdictions
andsupport
thefrom
plannedoccupational
exposures,w
hichinclude
definitionof
accountabilitiesfor
allparties
recoveryefforts.
Similarly,
adistinction
shouldbe
made
with
respectto
radiationexposures
receivedby
workers
duringrecovery
effortsas
aconsequence
oftheir
occupationand
thosereceived
asa
resultof
exposuresdue
toenvironm
entalconditions
resultingfrom
theem
ergency.S
ucha
statement
shouldalso
beincluded
in
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-17-O
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Fram
ew
ork
fo
rR
ecovery
in
the
Ev
en
tof
aN
uclear
or
Rad
io
log
ical
Em
ergency
Section
Question(s)
IR
esponses
to
Questions
IA
dditio
nal
Com
ments
Section
15of
theR
adiationP
rotectionR
egulations;S
OR
2000/2003(published
Sept
22,2017).
Public
Q24.
Did
we
captu
rethe
comm
unicationY
es,though
it would
helpfulto
saythat
comm
unicationsIn
thisarea,
itis
veryim
portantthat
the
comm
unicationconsiderations
duringrecovery
needto
becom
pletedin
atim
elym
annerand
beA
uthorityH
avingJurisdiction
(AH
J)have
considerationsaccurately?
Ifnot,
what
modifications
orconsistently
updated.oversight
oncom
munications
being
duringadditions
doyou
propose?distributed
outby
supportingagencies.
The
recoveryQ
25.Is
thelevel
ofinform
ationprovided
Yes
statemen
ton
consistentm
essages
is
adeq
uate?
Ifnot,
what
subjectneed
sto
paramount
forpublic
confidence.
bedescribed
inm
oredetails?
Or
what
arethe
elements
thatw
edid
notdescribe_(if_any)?
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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.
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 Brunswick’s at:
http://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 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
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 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.
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 6 of 10
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.
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 7 of 10
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
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 8 of 10
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
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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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
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 10 of 10
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