September 24, Canadian Nuclear Safety Commission P.O. Box 1046, Station B 280 Slater Street Ottawa, Ontario K1P 5S9

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1 September 24, 2010 Canadian Nuclear Safety Commission P.O. Box 1046, Station B 280 Slater Street Ottawa, Ontario K1P 5S9 Re: Aging Management for Nuclear Power Plants - Draft Regulatory Document RD-334 The Power Workers Union ( PWU ) represents a large portion of the employees working in Ontario s electricity industry. Attached please find a list of PWU employers. The PWU is committed to participating in regulatory consultations to contribute to the development of regulatory direction and policy that ensures ongoing service quality, reliability and safety at a reasonable price for Ontario customers and to ensure transparency and robustness of the regulation. To this end, please find the PWU s comments on the Draft Regulatory Document RD-334 Aging Management for Nuclear Power Plants. We hope you will find the PWU s comments useful. Yours very truly, Don MacKinnon President Encl.

2 List of PWU Employers Algoma Power AMEC Nuclear Safety Solutions Atomic Energy of Canada Limited (Chalk River Laboratories) BPC District Energy Investments Limited Partnership Brant County Power Incorporated Brighton Beach Power Limited Brookfield Power Mississagi Power Trust Bruce Power Inc. Capital Power Corporation Calstock Power Plant Capital Power Corporation Kapuskasing Power Plant Capital Power Corporation Nipigon Power Plant Capital Power Corporation Tunis Power Plant Coor Nuclear Services Corporation of the City of Dryden Dryden Municipal Telephone Corporation of the County of Brant, The Coulter Water Meter Service Inc. CRU Solutions Inc. Ecaliber (Canada) Electrical Safety Authority Erie Thames Services and Powerlines ES Fox Great Lakes Power Limited Grimsby Power Incorporated Halton Hills Hydro Inc. Hydro One Inc. Independent Electricity System Operator Inergi LP Infrastructure Health and Safety Association Innisfil Hydro Distribution Systems Limited Kenora Hydro Electric Corporation Ltd. Kincardine Cable TV Ltd. Kinectrics Inc. Kitchener-Wilmot Hydro Inc. Lake Superior Power Inc. (A Brookfield Company) London Hydro Corporation Middlesex Power Distribution Corporation Milton Hydro Distribution Inc. New Horizon System Solutions Newmarket Hydro Ltd. Norfolk Power Distribution Inc. Nuclear Waste Management Organization Ontario Power Generation Inc. Orangeville Hydro Limited Portlands Energy Centre PowerStream PUC Services Sioux Lookout Hydro Inc. Sodexho Canada Ltd. TransAlta Generation Partnership O.H.S.C. Vertex Customer Management (Canada) Limited Whitby Hydro Energy Services Corporation

3 1 INTRODUCTION The Canadian Nuclear Safety Commission ( CNSC ) requests stakeholder comment on the August 27, 2010 draft regulatory document RD-334, Aging Management for Nuclear Power Plants ( Draft Regulation or RD-334 ). As noted in the Draft Regulation Aging management is the engineering, operational, inspection, and maintenance actions that control, within acceptable limits, the effects of physical aging and obsolescence of SSCs [structures, systems, and components] occurring over time or with use. An aging management program (AMP) is a set of policies, processes, procedures, arrangements, and activities for managing the aging of the SSCs for an NPP [nuclear power plant]. The Draft Regulation sets out the CNSC requirements to provide assurance that aging management is appropriately and proactively considered at each stage of a NPP s life cycle. Specific requirements are also provided for establishment, implementation, and improvements of AMPs through application of a systematic and integrated approach. The Power Workers Union ( PWU ) appreciates the opportunity to comment on the Draft Regulation. 2 PWU POLICY POSITION The PWU has been a key participant in public policy discussions in Ontario for over 60 years. The PWU is providing input on the issues raised in the Draft Regulation RD-334 to ensure transparency and robustness of the Draft Regulation in meeting its objective. The PWU s comments on the Draft Regulation are guided by our energy policy statement: Reliable, secure, safe, environmentally sustainable and reasonably priced electricity supply and service, supported by a financially viable energy industry and skilled labour force is essential for the continued prosperity and social welfare of the people of Ontario. In minimizing environmental impacts, due consideration must be given to economic impacts and the efficiency and sustainability of all energy sources and existing assets. A stable business environment and 1

4 predictable and fair regulatory framework will promote investment in technical innovation that results in efficiency gains. 3 COMMENTS OF THE POWER WORKERS UNION The PWU provides general comments on the Draft Regulation followed by input on specific sections of RD GENERAL COMMENTS The PWU supports the CNSC s Draft Regulation as providing robust requirements for integrated aging management programs and for component aging management programs. The PWU believes that implementing the proactive procedures outlined in the Draft Regulation will improve the net value of nuclear assets over their lives as well as improve safety. It is not acceptable to move from outage to outage conducting a fitness for service evaluation in each outage and taking actions only when the projection of component condition indicates a probability of failure before the next outage. The PWU agrees with the CNSC that it is necessary to plan ahead, to document those plans and to monitor their implementation. 3.2 COMMENTS ON SECTION INTRODUCTION In the PWU s view a more complete rationale for the CNSC s interest in aging management programs and integrated aging management programs should be provided in the Introduction. Doing so will enhance the understanding by policy makers at nuclear facilities of the objectives of the requirements of RD-334. The introduction therefore should include explicit reference to safety as an objective of RD-334. As the CNSC is aware safety is not an absolute concept. The concept of what is acceptably safe relates to societal costs and benefits that can be influenced by a proactive approach to the design, commissioning, operating procedures, inspection techniques, inspections schedules, and surveillance activities for maintaining safe 2

5 operation over the life of the plant. As such a proactive approach involving an aging management plan will influence the definition of what is acceptably safe. 3.3 COMMENTS ON SECTION 2 - GENERAL REQUIREMENTS FOR AGING MANAGEMENT The PWU believes that, given the necessity to plan ahead and to implement the plan, regulation is needed to ensure that owners of nuclear facilities and the CNSC are not put in the position of making unacceptable compromises involving safety against other social impacts (e.g. supply cost). Economic operation of plants can be enhanced by integrated aging management programs and it is in the interests of nuclear power plant owners and their customers to ensure that these plans are put in place and implemented. The PWU s interest, similar to that of the CNSC, is in regulation that ensures that plants are acceptably safe in all circumstances and as safe as reasonably achievable. The PWU is pleased that the CNSC is proposing this regulation which requires the submission to the CNSC of aging management programs that will provide the insurance that planning will be conducted and implemented on a reasonable time line. 3.4 COMMENTS ON SECTION METHODS TO DETECT AND MONITOR AGING Surveillance programs are mentioned in the document with no elaboration. The PWU believes that the regulation would benefit from elaboration on what the CNSC expects owners of nuclear plants to consider in developing surveillance programs. While inspections to deal with known deterioration mechanisms may incidentally result in the discovery of unexpected deterioration, there is no assurance that unexpected deterioration will always be detected. Surveillance programs involving the removal of items (e.g. pressure tubes) are essential to assist in the discovery of deterioration mechanisms that are not known with the information in hand. 3

6 As the CNSC is aware, given the large number of components, deterioration mechanisms, and drivers involved, building a complete understanding of deterioration requires a rigorous surveillance program. Measurements of known deterioration made on specific components demonstrate a large variation in accumulated deterioration among the population of that component, even for similar items. While the reasons for the variation are not always understood, among the influencing factors in the case of pressure tubes and feeders is their location within a quadrant, the quadrant they are located in and the specific unit invo lved. Surveillance programs therefore must be designed to take into account the need for an appropriate level of statistical assurance that significant deterioration does not go undetected, particularly as it relates to a simultaneous defence of failure of multiple parts. The PWU notes that the discovery of new deterioration mechanisms late in the life cycle of a plant reduces the solution set of options to address them and the ability to obtain adequate inspection data in a timely manner. Such surprises have the potential to result in either unplanned and/or significant outage extensions of units, or perhaps even unplanned retirements. Appropriately designed surveillance programs are essential to reduce the probability of such events. Therefore the PWU recommends the addition of requirements on the design of surveillance programs to the RD COMMENTS ON SECTION REVIEW AND CONTINUOUS IMPROVEMENT The aging management plans for SSCs should specify what range of outcomes can be reasonably accommodated within them and take into account the ability to adjust the plans in response to outcomes lying outside of that range. The life cycle plans need to be adjusted as appropriate in response to new information. Lead times to plan and implement options can be a significant factor in aging management planning. Therefore, the PWU recommends that the aging management plans identify when work should be started on critical options needed to manage the range of uncertainties. 4

7 3.6 CSNC AUTHORITY TO ENSURE COMPLIANCE While it is implicit in the statement made in section 4.10 that the licensee shall submit an annual report on the review of the integrated AMP effectiveness and improvements to the CNSC fo r review and assessment the document should explicitly identify the authority it has under the proposed and related regulations in the event that the aging management plans or their implementation are judged to be deficient. The PWU also suggests adding reporting requirements related to safety as follows: the licensee shall submit an annual report on the review of the integrated AMP and safety related SSCs effectiveness and improvements 4 SUMMARY The PWU supports the Draft Regulation and believes that compliance with it will improve both the safety and life cycle economics of nuclear power plants. The PWU makes recommendations on the Draft Regulation that the PWU believes will add to the completeness and robustness of the regulation. All of which is respectfully submitted. 5