1. Objective
2. Introduction
3. Approach to Licensing
4. Schedule
5. Roles and Responsibilities
5.1 CNSC Governance Structure
5.2 AECL Governance Structure
6. Organization Representatives
7. Statement of Work
7.1 NRU Relicensing technical scope
7.2 Activities and Deliverables
7.2.1 Document Deliverables
7.2.2 Other deliverables
7.2.2.1 Common Deliverables
7.2.2.2 AECL Additional Deliverables
7.2.2.3 CNSC Additional Deliverables
7.3 Conflict Resolution Process
8. Future Revisions of the Protocol
9. Extended Outage Impact on the NRU ISR
10. References
11. Glossary of Terms
| Section | Change |
|---|---|
| 1.0 | Health directive for disruption of isotopes modified as “…taking into account the directive from the Governor in Council to consider the health of Canadians as it relates to the production of medical isotopes as an input for evaluating various options, without compromising safety”. |
| 3.0 | Inclusion of the remaining high relevance activities from restart protocol indicated. |
| 5.1 | Formation of CNSC NRU ISR Core Group added. |
| 6.0 | AECL and CNSC Organization Representatives revised. |
| 7.0 | Remaining high relevance activities from restart protocol included in “Statement of Work”. |
| 7.1 | High relevance remaining activities from restart protocol included in “Technical Scope”. Title “Table 1: Phases of Integrated Safety Review and Global Assessment for licence renewal” inserted as the title for the table showing the phases of ISR and Table 1 updated. Statement “The scope and schedule for Phase IV is established by the CNSC accepted IIP” included. “Table 2: Additional remaining tasks after the termination of the Restart Protocol” added. |
| 7.2.1 | Title “Table 3: Protocol deliverables, target dates and responsible organizations” added as the title for the table defining the Protocol deliverables. “Preliminary draft GAR and IIP”, “Final draft GAR and IIP” and Supplemental CMD-NRU IIP results and proposed LCH addendum” are added as new deliverables. Following deliverables in Table 3 updated:
|
| 7.2.2.1 | AECL participants of working and executive level meetings revised. |
| 9.0 | Extended outage impact on the NRU ISR updated. |
| 10.0 | References updated |
| 11.0 | Glossary updated |
| Section | Change |
|---|---|
| Title “Extent of the Protocol” added and the purpose of revision defined | |
| 5.2 | AECL Governance Structure revised by AECL |
| 6.0 | AECL Organization Representatives revised by AECL |
| 7.1 | NRU Relicensing Technical Scope updated and modified to show completions Periodic press releases not included in the scope for Phase I to III |
| 7.2.1 | Document Deliverables Table updated and the status of deliverables shown |
| 7.2.2.1 | “Working Level Meetings” updated to indicate changes by both Organizations “Quarterly Reports” revised toindicate the role of each organization |
| 7.2.2.2 | AECL’s responses to actions from meetings between AECL and CNSC and submission of supporting documents modified to include AECL’s acceptance and agreement |
| 7.2.2.3 | CNSC Additional Deliverables on EA updated |
| 9.0 | A section titled “Extended Outage Impact on the NRU ISR” added |
| 10.0 | References updated |
| 11.0 | Glossary updated |
This protocol is essentially administrative in nature. Nothing in this protocol or any statement in this protocol is to be construed or interpreted as affecting the jurisdiction and discretion of the Commission in any assessment of any application for licensing purposes under the Nuclear Safety and Control Act (NSCA). It is not intended to constitute a deviation or inference to a proposed amendment to the current licence for the National Research Universal (NRU).
This revision reflects that developments in NRU Integrated Safety Review (ISR) management and process that have occurred since the initiation of the original protocol [1].
The objective of this protocol is to provide a framework within which AECL and CNSC staff will work to prepare the necessary information for the Commission to assess the continued operation of the NRU reactor beyond the current licence period. NRU is operated under the Nuclear Research and Test Establishment Operating Licence for Chalk River Laboratories[2]that expires October 31, 2011. Licensing activities for NRU will take place within the wider context of licence renewal for Chalk River Laboratories, taking into account taking into account the directive from the Governor in Council to consider the health of Canadians as it relates to the production of medical isotopes as an input for evaluating various options, without compromising safety.
The legal framework for licence renewal is derived from the Nuclear Safety and Control Act (NSCA) [3] and supporting Regulations.
Following the Directive [4] from the Governor in Council, in considering all the risk to Canadians, the AECL and CNSC staff are coordinating their effort for the licensing of the NRU, to meet the mandates and accountability responsibilities of both organizations.
In engaging in this coordinated effort and working responsibly in the public interest, the CNSC maintains its independence as the Canadian Nuclear regulator and AECL continues to be solely responsible for the safe operation of the NRU reactor.
It is understood that:
This protocol sets out the framework within which both organizations will work and establishes a high level estimate of the timeline.
To fully address the responsibilities for safety and accountability, and to serve the Canadian public, both the Canadian Nuclear Safety Commission and Atomic Energy of Canada Limited recognize the importance of a well-planned and coordinated working arrangement.
Both organizations recognize the complexity of the matter and agree to implement an Integrated Safety Review (ISR) of the facility. The ISR process for NRU will be fully defined at an early stage of the work process. It will rely on the guidance set out in the IAEA Safety Guide: Periodic Safety Review of Nuclear Power Plants [5], and the CNSC Regulatory Document: Life Extension of Nuclear Power Plants [6], recognizing that NRU is a research facility approaching licence renewal not a power plant undergoing life extension.
This Protocol also addresses the completion of remaining activities from the Restart Protocol considered of high relevance[7]
The schedule set out in the statement of work in this protocol is intended to align with the timeline for the site licence renewal in 2011 and the lead time notices required in the Canadian Nuclear Safety Commission Rules of Procedure.
It is recognized that the schedule includes a large amount of work and there may be execution risks that could cause delays. To preserve the completion of the objectives, the delay risks will be dealt with in a timely manner through adjustments of resources or the time line of this protocol. These adjustments will be made through the protocol revision process outlined below.
The CNSC has created the NRU Licensing Extension Steering Committee (NRULESC) to provide strategic level direction and senior management oversight and support to the programs associated with the NRU licensing extension beyond 2011.
The NRULESC is chaired by the Executive VP, Regulatory Operations Branch (ROB) and formed by all relevant executive directorates, including:
The objectives of the Steering Committee are to enable CNSC staff to fulfill its mandate of providing recommendations to the Commission regarding the re-licensing of the NRU in 2011. Its enabling function is fulfilled by ensuring that the NRU licensing activity:
The NRULESC is directly accountable to the CNSC President through the EVP ROB.
The NRULESC has created the NRU ISR Core Group to perform an advisory role.
AECL has established a Site Senior Management Review Team (SSMRT) to review and approve the recommendations from the NRU ISR. This team is led by the Senior Vice-President CRL and Chief Nuclear Officer, and includes representation from CRL Operations and Regulatory Affairs, as follows:
The Organization Representatives (ORs) for these activities are responsible for all matters concerning the work described in Section 7 of this Protocol and bring the matter to their respective governance bodies, should problems arise during the work that may affect the schedule or the scope of the work.
For the purposes of this Protocol, CNSC staff shall be represented by:
For the purposes of this Protocol, AECL shall be represented by:
Either Party hereto may, by written notice, change any of its appointees mentioned above.
This set of NRU ISR high level tasks / milestones are derived from the ISR process documented in RD-360. It is recognized that work performed in support of relicensing in 2005 and 2006 provides a basis for a comprehensive ISR. The work described in this protocol builds on that basis. This protocol defines the high-level structure of the ISR process that will be followed. An early activity was to gather the necessary information to form a complete Level I plan, with milestones and deliverables.
There were several items in the Restart Protocol considered of high relevance that require follow-up post return to service[7]. Given their high relevance, these items have been added to the Protocol for NRU Licensing Activities to provide a solid working framework for resolution.
The technical scope of the work includes:
| Phase | Scope | |
|---|---|---|
| Phase I | Definition and development of a specific ISR approach for NRU | Assessment of Status Quo– Complete |
| Level I project Plans– Complete | ||
| ISR scope and basis – Complete | ||
| Phase II | Integrated Safety Review execution | Level II Project Plan – Complete |
| Presentation to the Commission at mid-Term (CMDs) –Complete | ||
| Safety factors reports (production and assessment) | ||
| EA Screening Report Decision | ||
| Global Assessment Report production and CNSC assessment; and IIP production and CNSC assessment and acceptance | ||
| Phase III | Licence renewal | Production and submission of CMDs to the Commission for Licensing decision |
| Presentations to the Commission | ||
| Phase IV | Initiate CNSC accepted Integrated Implementation Plan | Scope defined by the IIP |
The time periods for each phase are shown in Section 7.2
The scope for Phase I to III include:
The scope and schedule for Phase IV is established by the CNSC accepted IIP.
| Additional Remaining Tasks after the Termination of the Restart Protocol | |
|---|---|
| High Relevance remaining tasks from the Restart Protocol | Dispositioning and assessment of condition assessment gap analysis (addressed by provision of Supplementary Report to Safety Factor Report 2) |
| Implementation of Voyageur 2 (AECL’s organizational Corrective Action Plan) | |
| Implementation of the In-Service Inspection program | |
| Implementation of extended outages, including periodic vessel fitness for service re-examination | |
7.2Activities and Deliverables
The deliverables in the following sections are divided in:
Document deliverables target dates and responsible organizations are given in Table 3.
| Document Deliverables | Target Dates | Status and Actioned Organization(s) |
|---|---|---|
| Phase I | ||
| Comprehensive list of issues produced for NRU, from ImpActs, fire hazard assessment, previous safety assessments, audits, licensing correspondence etc. | August 2008 | Complete AECL |
| Risk prioritization of outstanding issues in the current Licensing Strategy document [8] | August 2008 | Complete CNSC / AECL |
Discussions and agreement on the scope of key issues including: - Tritium issues in coolant and bays |
October 2008 | Complete CNSC / AECL |
| Discussions on whether EA is required and if so its scope | October 2008 | Complete CNSC / AECL |
| Complete Level I project plan | November 2008 | Complete AECL |
| Complete Level I review plan | November 2008 | Complete CNSC staff |
| Discussions and agreement on ISR scope and project plan | December 2008 | Complete CNSC / AECL |
| Document Deliverables | Target Dates | Status and Actioned Organization(s) |
|---|---|---|
Phase II |
||
| ISR Basis | March 2009 | Complete AECL |
| EA determination for the cumulative effects from the proposed extended long-term operation | March 2009 | Complete CNSC staff |
| Acceptance of ISR Basis Document[9] | April 2009 | Complete CNSC staff |
| Complete Level II coordinated project plans | May 2009 | Complete CNSC / AECL |
| EA Guidelines for relicensing to the Commission [10] and[11] | June 2009 | Complete CNSC staff |
| ISR presentation (mid-term report for CRL site licence) to the Commission for information | 2009 | Complete CNSC / AECL |
| Delivery of first set of Safety Factor Reports (8-17) | January 31, 2010 | Complete |
| Environmental statement report | January 2010 | Complete |
| Delivery of second set of Safety Factor Reports (1-7) | March 31, 2010 | Complete |
| EA Screening Report | December 2010 - January 2011 | CNSC staff |
| Complete CNSC Staff assessment of Safety Factors Report | October 2010 | Complete |
| Preliminary draft version of Global Assessment Report (GAR) and Integrated Implementation Plan (IIP). | December 1, 2010 (GAR) December 10, 2010 (IIP) |
AECL, Complete |
| Final draft version of GAR and IIP. | January 31, 2011 | AECL |
| CNSC decision on EA approval | February 2011 | CNSC Commission |
| Final submissions (Revision 0) of GAR for CNSC assessment and | February 28, 2011 | AECL |
| Assessment of final submissions of GAR and assessment and acceptance of IIP. | May 2011 | CNSC staff |
| Document Deliverables | Target Dates | Status and Actioned Organization(s) |
|---|---|---|
Phase III |
||
| CMDs for Hearing Day One | April 2011 | All |
| Licence renewal Day One | June 2011 | All |
| CMDs for Hearing Day Two | July-August 2011 | All |
| Licence renewal Day Two | September 2011 | All |
| CNSC licensing decision | October 2011 | CNSC Commission |
| Document Deliverables | Target Dates | Status and Actioned Organization(s) |
|---|---|---|
Phase IV |
||
If NRU operation continues under a renewed licence IIP starts as per ISR – Detailed Project Plan to be developed |
||
Follow-up Activities from the NRU Restart Protocol |
||
| Dispositioning and assessment of condition assessment gap analysis (addressed by provision of Supplementary Report to Safety Factor Report 2). | January 31, 2011 | AECL |
| CNSC assessment of gap analysis of condition assessment. | May 2011 (linked to CA under IIP) | CNSC staff |
| Implementation of Voyageur 2 [12]. | Plan in place, ongoing | AECL, semi-annual updates to the Commission for two years |
| Implementation of the In-Service Inspection (ISI) program (vessel) (See Note 1). | Plan in place, ongoing | AECL, update provided via CNSC’s routine compliance program |
| Implementation of the first extended outage. | March - May 2011 | AECL |
| Implementation of future extended outages. | Scheduled annually or more frequently if necessary based upon ISI findings | AECL, specific requirement to be included in the new licence |
Note:
Meetings
Working Level Meetings
Monthly AECL / CNSC review meetings will be held to review progress on the work and highlight any potential major issues or disputes. Attendance at these review meetings will be,
two or more of,
two or more of,
Technical Meetings
Meetings between technical experts at the CNSC and AECL will be arranged as the need arises. The organization representatives, or their designates, will participate in technical meetings to provide continuity across licensing activities.
Executive Meetings
To be arranged quarterly or more frequently to follow up progress and/or deal with the conflict resolution process. Minimum attendance at these Executive meetings will be the Executive VP ROB from CNSC; and SVP CNO from AECL.
Quarterly Reports
Quarterly reports to the respective Governance (Sections 5.1 and 5.2) and Presidents are to be prepared by one organization and reviewed by the other with roles alternating for each submission.
Other Updates
Coordinated periodic updates to Government on progress will be prepared and presented by AECL. AECL and CNSC staff will review and contribute to third party updates.
In addition to the deliverables described in previous sections, AECL will deliver:
In addition to the deliverables described in previous sections, CNSC will deliver:
CNSC staff and AECL staff have agreed to coordinate licensing work related to NRU operation beyond 2011 under the Nuclear Safety and Control Act.Disagreements may arise during the execution of the work. Areview and dispute resolution mechanism will be used during the review to ensure fairness and assist timely completion.
Step 1: Identification of the Issue & Resolution at the staff level
Step 2: Resolution at the Senior Management Level
Step 3: Resolution at the Executive Level
A Step 2 issue, with documentation, will be sent to the Executive Vice President, Regulatory Operations Branch (CNSC) and the Senior Vice President and Chief Nuclear Officer (AECL) for resolution. A meeting will be called, normally within 30 days, to resolve the issue, and the resolution documented.
Revisions of this protocol will be coordinated by the organization representatives and must be approved by the organizations’ governance structures and Presidents.
Revisions may include:
The extended outage associated with repair of the NRU vessel leak and NRU return to service has had an impact on the NRU ISR. As part of the Extended Activities Program (EAP), some refurbishment work has been performed on NRU that otherwise would not necessarily have been completed prior to finishing the NRU ISR. As a result, some of the recommendations that would have come from the Global Assessment have already been addressed (e.g., vessel refurbishment, establishing a detailed vessel fitness for service program, heavy water moderator replacement, process water system refurbishment and heavy water system inspections).
[1] Protocol for National Research Universal Licensing Activities, July 15, 2008 [Return]
[2] Nuclear Research and Test Establishment Operating Licence, Chalk River Laboratories, NRTEOL-01.01/2011[Return]
[3] Nuclear Safety and Control Act , 1997, c.9 N-28.3[Return]
[4] Nuclear Safety and Control Act, Directive from Governor in Council to the Canadian Nuclear Safety Commission Regarding the Health of Canadians, SOR/2007-282[Return]
[5] IAEA Safety Guide, Periodic Review of Nuclear Power Plants, NS-G-2.10, 2003[Return]
[6] Regulatory Document Life Extension of Nuclear Power Plants RD-360, February 2008[Return]
[7]Letter from M. Santini to W. Pilkington, “NRU Return to Service Protocol Termination”, June 02, 2010 (E-DOCS-#3556389).[Return]
[8] Licensing Strategy for AECL’s NRU Licensability Extension project, Lamarre to McGee, 2006 February 28 (referenced by Condition 19 in the CRL Licence).[Return]
[9] NRU Integrated Safety Review (ISR) Basis Document, April 28, 2009 [Return]
[10] Scoping Information Document - NRU Reactor Long-term Management Project AECL CRL, June 30, 2009 [Return]
[11]Record of Proceedings - Atomic Energy of Canada Limited - Proposed Environmental Assessment Scoping Information Document for the National Research Universal Reactor Long-Term Management Project at Chalk River Laboratories, July 16, 2009 [Return]
[12] Record of Proceedings - AECL Request for the Approval of the Return to Service of the NRU Reactor, July 5, 2010 (E-DOCS-#3594641).[Return]
| 11. Glossary of Terms | |
|---|---|
| AECL | Atomic Energy Canada Limited |
| CMD | Commission Member Document |
| CNSC | Canadian Nuclear Safety Commission |
| CNO | Chief Nuclear Officer (AECL) |
| CRL | Chalk River Laboratories |
| CRLCLD | Chalk River Laboratories Compliance and Licensing Division (CNSC) |
| DNCFR | Directorate of Nuclear Cycle and Facilities Regulation |
| EA | Environmental Assessment |
| IIP | Integrated Implementation Plan |
| ISR | Integrated Safety Review |
| LE | Licensing Extension |
| NRU | National Research Universal reactor |
| NRULESC | NRU Licensing Extension Steering Committee (CNSC) |
| OR | Organization Representative (see Section 6) |
| PSR | Periodic Safety Review |
| ROB | Regulatory Operations Branch (CNSC) |
| SSMRT | Site Senior Management Review Team (AECL) |
| Original signed by: | |
|---|---|
| Hugh MacDiarmid President and Chief Executive Officer ATOMIC ENERGY OF CANADA LIMITED |
Date: December 13, 2010 |
Michael Binder |
Date: December 13, 2010 |