Overview of the Canadian regulatory position on long term operation

In recent years, Canadian utilities have completed several refurbishment projects, notably restarts of reactors following a long term shutdown. The scope of these projects depended both on the age of the plant, and on the projected operating life following refurbishment. The projects to date have been carried out within the existing Canadian nuclear regulatory framework and the operating licenses issued by the Commission for each facility.

Key regulatory goals for LTO projects are obtaining assurance of the adequacy of the scope of life extension and safety upgrades proposed by the licensee and verifying the proper execution of that work by the licensee, prior to return of the unit to service.

In order to meet these goals, the CNSC specifies requirements for the LTO scope of work that is prepared by the licensee, assesses the proposed work scope, evaluates the licensee programmes for the control of all activities and evaluate engineering submissions, procurement, construction and commissioning carried out. The following steps will be required of licensees in establishing the scope of work:

• Perform an environmental assessment (EA) pursuant to the Canadian Environmental Assessment Act, which involves:

• An assessment of the environmental effects of the project, including the environmental effects of malfunctions or accidents that may occur in connection with the project and any cumulative environmental effects that are likely to result from the project in combination with other projects or activities that have been or will be carried out;

• The significance of these effects;

• Comments from the public;

• Measures that are technically and economically feasible and that would mitigate any significant adverse environmental effects of the project; and

• Any other matter that the CNSC requires to be considered.

• Carry out PSR activities, which is considered an effective way to obtain an overall view of actual plant safety, in order to determine reasonable and practical modifications that should be made in order to maintain a high level of safety and to improve the safety of older nuclear power plants to a level approaching that of modern plants.

• Develop an integrated implementation plan for safety improvements, which involves the development of an integrated implementation plan for the necessary corrective actions, safety upgrades and compensatory measures to ensure the plant will not pose an unreasonable risk to health, safety, security and the environment and will conform to Canada’s international obligations over the proposed life. All generic action items and station specific actions items will be reviewed and each will be resolved to the extent practicable.

In assessing the adequacy of the proposed LTO workscope, CNSC staff reviews the Environmental Assessment Study Report and the Periodic Safety Review report, and takes into consideration information gathered through its own regulatory oversight activities. The CNSC notifies the licensee of its assessment of the proposed workscope, either accepting it or requiring changes. Subsequently the licensee proceeds with execution of LTO activities.

Once LTO activities are underway, the licensee is required to have acceptable programmes for the control of all LTO activities. Regulatory verification of project execution includes assessment of engineering change submissions, and inspections of licensee procurement, construction, and commissioning activities. Engineering change, procurement, construction and commissioning are to be performed in accordance with CNSC requirements and appropriate industry standards.

During the refurbishment phase the licensee submits updated safety analysis that demonstrates the acceptability of the refurbished plant. The analysis must be submitted in time to allow for CNSC staff review prior to making recommendations on restart to the Commission.

The CNSC expects that the licensee carries out a thorough commissioning plan for a LTO project. The scope and depth of this plan need not be as extensive as it would for a new facility, however, the baseline and confirmatory data must exist. If relevant system baseline data is available from past commissioning, then it can be referenced. However, if commissioning baseline data is no longer available, it will have to be reconstituted.