NK38 Corr 00531 17096 R00

RETENTION: P
Dietmar Reiner
Senior Vice President
Nuclear Projects
1855 Energy Drive, Courtice, ON, L1E 0E7 Tel.: 905-623-6670 x 5400
Email address: d.reiner@opg.com
November 11, 2014
File No.: NK38-00531 P

CD#.: NK38-CORR-00531-17096
MR. F. RINFRET
Director
Darlington Regulatory Program Division
Canadian Nuclear Safety Commission
P.O. Box 1046
280 Slater Street
Ottawa, ON
K1P 5S9
Dear Mr. Rinfret:
Darlington NGS Global Assessment Update
The purpose of this letter is to submit, for information, five revised Global Assessment
Report (GAR) support documents and an addendum to the Global Assessment Technical
Basis Document (Reference 1). This submission supports Revision 001 of the Integrated
Implementation Plan (IIP) (Reference 2). This submission completes Regulatory
Management Action (REGM) 28164836 as committed in Reference 3.
The following two OPG submissions prepared after the December 2, 2013 submission of
the GAR and GAR support documents (Reference 4) resulted in the identification of new
Integrated Safety Review (ISR) gaps.
The submission of the Emerging Issues Report (Reference 3) which included the
identification of 180 additional ISR gaps resulting from the code review refresh of
47 modern codes and standards.
The submission of the code review of CSA N289.3-10, Design Procedures for
Seismic Qualification of Nuclear Power Plants (Reference 5), which included the
identification of 12 additional ISR gaps.
In order to assess the aggregate risk of these new gaps, five GAR support documents
have been updated and an addendum to the Global Assessment Technical Basis
Document has been prepared. The addendum, included in this submission as Enclosure
1, summarizes the impact of these new gaps and concludes that there is no impact on
Ontario Power Generation Inc., 2014. This document has been produced and distributed for Ontario Power Generation Inc. purposes only. No part
of this document may be reproduced, published, converted, or stored in any data retrieval system, or transmitted in any form by any means (electronic,
mechanical, photocopying, recording, or otherwise) without the prior written permission of Ontario Power Generation Inc.
Associated with OPG-STD-0031, Correspondence Standards

Mr. F. Rinfret November 11, 2014
NK38-CORR-00531-17096
References:
1. OPG Report, NK38-REP-03680-10203 R000, Darlington NGS Global

Assessment Technical Basis Document, November 2013
2. OPG Letter, D. Reiner and B. Duncan to F. Rinfret, Darlington NGS Request

for CNSC Acceptance of Updated Integrated Implementation Plan (IIP),
October 31, 2014, NK38-CORR-00531-16866.
3. OPG Letter, D. Reiner and B. Duncan to F. Rinfret, Darlington NGS Integrated

Safety Review Emerging Issues Report - NK38-REP-03680-10207 R000,
February 19, 2014, NK38-CORR-00531-16688.
4. OPG Letter, D. Reiner to F. Rinfret, Request for CNSC Acceptance of the

Darlington NGS Global Assessment Report (GAR) and Integrated
Implementation Plan (IIP), December 2, 2013, NK38-CORR-00531-16568.
5. OPG Letter, , D. Reiner to F. Rinfret, Darlington NGS Integrated Safety Review

- Submission Of Code Review Of CSA N289.3-10 (NK38-REP-03680-10151),
April 14, 2014, NK38-CORR-00531-16736.
6. OPG Report, NK38-REP-03680-10186 R000, Darlington NGS - Global

Assessment Report (GAR), November 2013.
Page 3 of 4
ONTARIOPiiiiiER Report
Document Number:
NK38-REP-03680-10203
Usage Classification:
N/A
GENERATION Sheet Number: Revision :
ADD-001 ROOO
Title:
DARLINGTON NGS GLOBAL ASSESSMENT - TECHNICAL BASIS DOCUMENT

ADDENDUM
Ontario Power Generation Inc., 2014. This document has been produced and distributed for Ontario Power Generation Inc.
purposes only. No part of this document may be reproduced, published, converted, or stored in any data retrieval system, or
transmitted in any form or by any means (electronic, mechanical, photocopying, recording, or otherwise) without the prior written
permission of Ontario Power Generation Inc.
Darlington NGS Global Assessment -

Technical Basis Document
Addendum 001
NK38-REP-03680-10203-ADD-001-ROOO
Accepted by:
--4T~--~~----~~~~~
tl l. I. oj I 1'1- Authorized by:
Pae Date tiaz Malek
Manage Director, Nuclear Safety
Integration Nuclear Refurbishment
Nuclear Refurbishment
Associated with OPG-PROC-0019, Record and Document Management OPG-TMP-0003-R003 (Microsoft 2007)
Document Identification
<Project #> <Type> <Division> <Serial> <Revision>
0235 TBD DNGSGA 0002 00
Addendum to the Darlington NGS Global Assessment - Technical Basis

Document
Addendum to the Darlington NGS

Global Assessment - Technical
Basis Document
0235-TBD-DNGSGA-0002 R00
2014-05-29
Prepared by: 2014 05 29

Peter Wiebe Date
Consultant, CPUS Ltd.
Reviewed by: 2014 05 29

Ramesh Arora Date
Approved by: 2014 05 29

M.J. Jansen, P. Eng. Date
VP Engineering, CPUS Ltd.
0235-FORM-ENG-0010 Rev 00
This document is the property of CPUS Limited and OPG. This document may be distributed by OPG to a 3rd party (including but
not limited to the CNSC) for the purposes of validating the work including a review of the estimate, costs, scheduling and technical
components. Expressed written agreement from CPUS Limited or OPG is required for any other distribution or transfer.
Page 1 of 11
0235 TBD DNGSGA 0002 00

Document
Revision Summary
Revision
Number Date Comments
00 2014 05 29 Addendum to the Darlington NGS Global Assessment - Technical Basis Document to
address new or revised ISR Issues. This includes ISR Issues requiring resolution and
acceptable deviations.
Page 2 of 11
0235 TBD DNGSGA 0002 00

Document
Table of Contents
Page
Revision Summary ...................................................................................................................... 2
1.0 INTRODUCTION .......................................................................................................... 4
2.0 ASSESSMENT ............................................................................................................. 5
3.0 SUMMARY ................................................................................................................... 6

Appendix A References .......................................................................................................... 7
Appendix B Nomenclature....................................................................................................... 9
Appendix C Definitions ...........................................................................................................10
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0235 TBD DNGSGA 0002 00

Document
1.0 INTRODUCTION
The Global Assessment (GA) is a systematic review of the extent to which Darlington meets
the codes and standards of a new nuclear generating station. The Darlington Global
Assessment Report (GAR) was submitted to the Canadian Nuclear Safety Commission
(CNSC) in November 2013. The GAR is a requirement of CNSC regulatory document RD-
360, Life Extension of Nuclear Power Plants [R-1].
The technical basis for the Global Assessment of the refurbishment activities and continued
operation of Darlington NGS is provided in OPG Report, NK38-REP-03680-10203,
Darlington Global NGS Assessment - Technical Basis Document, 2013 [R-8]. The results
of the Global Assessment (GA) from this document are summarized in OPGs Global
Assessment Report (GAR) [R-9]. The GAR is produced with the objective of providing an
overall risk judgment on the acceptability of continued operation.
This addendum provides a summary of assessments performed on the seventy-seven (77)

new ISR Issues identified since Revision 00 of the Technical Basis Document (TBD) [R-8],
to determine if there is an impact on the conclusions of this report. The new ISR Issues are
listed in Revision 01 of the ISR Adequacy Report [R-4]. The majority of these Issues
resulted from a review of new and revised codes and standards Issued since the original
ISR was completed. The scope of this assessment includes ISR Issues being resolved by
actions being taken and those classified as acceptable deviations.
This addendum does not provide a review of the suite of Component Condition
Assessments (CCAs) nearing completion as part of the CCA Recovery Project. The
Integrated Implementation Plan (IIP) [R-2] will be updated, as required, to address the CCA
deliverables of this project [R-15].
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0235 TBD DNGSGA 0002 00

Document
2.0 ASSESSMENT
Adequacy of Actions to Address Open ISR Issues
Fifteen (15) new ISR Issues requiring resolution, i.e. open ISR Issues, were added to the ISR
Adequacy Report [R-4]. These ISR Issues consisted of 55 individual gaps against a review of
modern codes and standards. The assessment of the resolutions for these Issues did not
change the conclusion of this report. The adequacy of the planned Safety Improvements to
address these new ISR Open Issues confirmed that in the Safety Improvements identified in the
resolutions to the ISR Issues were appropriately developed using procedures and, when
implemented, the improvements will bring Darlington NGS into higher degree of compliance with
the requirements of the clauses against which the constituent ISR Gaps were originally
assessed. Also, the assessment of these 15 new Issues did not result in any changes to the
previously proposed actions.
The assessment is documented in Revision 01 of the ISR Adequacy Report [R-4].
Assessment of Acceptable Deviations
Sixty-two (62) new ISR Issues were classified as Acceptable Deviations (ADs) since Revision
00 of the TBD [R-8] was Issued. An interaction assessment was performed on these additional
Acceptable Deviations, together with the original 146 ADs documented in the Revision 00 of the
ISR Adequacy Report [R-4]. It was performed consistent with the methodology outlined in
section 4.3 of the TBD [R-8].
The new Acceptable Deviations fall into all of the significant barriers defined in the interaction
assessment, namely:
Seismic
Pressure Boundary
Accident Management
Special Safety Systems
Fire Protection
Human Performance
The updated interaction assessment determined that the interaction among the ADs within each
of the significant barriers was negligible.
The detailed aggregate assessment of Acceptable Deviations is provided in the following

supporting documents:
Page 5 of 11
0235 TBD DNGSGA 0002 00

Document
- Evaluation of Seismic, Pressure Boundary and Accident Management ISR

Acceptable Deviation Issues for Aggregate Effects between Issues [R-10].
- Evaluation of Human Performance ISR Acceptable Deviation Issues for Aggregate

Effects between Issues [R-11].1
- Evaluation of Special Safety Systems ISR Acceptable Deviation Issues for

Aggregate Effects between Issues [R-12].
- Evaluation of Darlington NGS Fire Protection ISR Acceptable Deviation Issues for
Aggregate Effects of Combinations of the Gaps [R-13].
- Acceptable Deviations Aggregate Review [R-14].
3.0 SUMMARY
This addendum provides a summary of assessments performed on new Open ISR Issues and
Acceptable Deviations raised since Revision 00 of the Technical Basis Document (TBD) [R-8].
The conclusions of the Technical Basis Document are not changed in consideration of these 77
new ISR Issues.
In assessing the adequacy of the actions being taken, it was determined that the ISR Gaps
would be adequately addressed resulting in enhanced safety and reliability of the plant. In
addition, it was concluded that the ISR Gaps determined to be Acceptable Deviations would
collectively have negligible, if any, impact on safety.
Also, the conclusions of the detailed assessment of Darlingtons Defence in Depth provisions
against regulatory requirements are not affected in consideration of these new ISR Issues.
Overall, the Global Assessment concludes that following execution of the Integrated
Improvement Plan and the timely completion of the CCA Recommendations for safety related
SSCs, Darlington NGS will continue to operate safely for the extended life, with acceptably low
risk to the public and the environment.
1
A revision to the Human Performance assessment was not required. The only new AD raised in this area was a
duplicate to one originally included in the scope of the R00 report.
Page 6 of 11
0235 TBD DNGSGA 0002 00

Document
Appendix A References
[R-1] CNSC Regulatory Document, RD-360, Life Extension of Nuclear Power Plants,
February 2008.
[R-2] OPG Report, NK38-REP-03680-10185 R000, Darlington NGS Integrated

Implementation Plan, 2013.
[R-3] OPG Procedure, N-PROC-LE-0005 R003, Nuclear Refurbishment Integrated Safety

Review Darlington.
[R-4] OPG Report, NK38-REP-03680-10201 R01, ISR Open Issues and Acceptable
Deviations Adequacy Review, 2014.
[R-5] OPG Report, NK38-REP-03680-10200, Adequacy Review of ISR Condition Component

Assessments (CCAs), 2013.
[R-6] OPG Instruction, N-INS-00770-10004 R001, Nuclear Refurbishment Gap Resolution

Process Darlington, 2011.
[R-7] OPG Report, NK38-REP-03680-10202 R000, Darlington NGS Defence In Depth

Assessment, 2013.
[R-8] OPG Report, NK38-REP-03680-10203 R000, Darlington Global NGS Assessment -

Technical Basis Document, 2013.
[R-9] OPG Report, NK38-REP-03680-10186 R00, Darlington NGS Global Assessment

Report (GAR), 2013.
[R-10] OPG Report, NK38-REP-03680-10197 R01, Evaluation of Seismic, Pressure Boundary

and Accident Management ISR Acceptable Deviation Issues for Aggregate Effects
between Issues, 2014.
[R-11] OPG Report, NK38-REP-03680-10198 R00, Evaluation of Human Performance ISR

Acceptable Deviation Issues for Aggregate Effects between Issues, 2013.
[R-12] OPG Report, NK38-REP-03680-10196 R01, Evaluation of Special Safety Systems ISR
Acceptable Deviation Issues for Aggregate Effects between Issues, 2014.
[R-13] OPG Report, NK38-REP-03680-10199 R01, Evaluation of Darlington NGS Fire

Protection ISR Acceptable Deviation Issues for Aggregate Effects of Combinations of the
Gaps, 2014.
Page 7 of 11
0235 TBD DNGSGA 0002 00

Document
[R-14] OPG Report, NK38-REP-03680-10195 R01, Acceptable Deviations Aggregate Review,

2014.
[R-15] OPG Correspondence, N-CORR-00531-16798, OPG Letter, B. Duncan to F. Rinfret,

Darlington NGS OPGs Updated Response to CNSC Type II Inspection on Plant
Condition Assessment, Action Item 201313-4428, May 14, 2014.
Page 8 of 11
0235 TBD DNGSGA 0002 00

Document
Appendix B Nomenclature
AD Acceptable Deviation
CANDU Canadian Deuterium Uranium
CCA Component Condition Assessment
CNSC Canadian Nuclear Safety Commission
CSA Canadian Standards Association
GA Global Assessment
GAR Global Assessment Report
IAEA International Atomic Energy Agency
IIP Integrated Implementation Plan
ISR Integrated Safety Review
NGS Nuclear Generating Station
OPEX Operating Experience
OPG Ontario Power Generation
QA Quality Assurance
RD Regulatory Document
SSC Systems, Structures and Components
Page 9 of 11
0235 TBD DNGSGA 0002 00

Document
Appendix C Definitions
Acceptable Deviation is an ISR Issue with a low or very low overall safety significance that has been
dispositioned as No further action required.
Aggregate Risk- is an overall judgment of the total risk of operation of a nuclear power plant taking into
account risks due to people, plant and processes.
Closed ISR Issue is an ISR Issue for which one of the following applies:
The ISR Issue has been addressed by changes in processes, programs, and/or system
modifications after the code review report was issued to OPG, or
An OPG review of processes and/or documents not reviewed as part of the initial code review
has demonstrated that the requirements of all the ISR Gaps that comprise the ISR Issue have
been met (are in compliance).
Component Condition Assessment (CCA) provides:
1. An assessment of the current condition of the safety system components

2. An assessment of component life, given the status of the current programs for inspection and
maintenance
3. Recommendation of actions required for the components to reach the target extended plant life.
Component Condition Assessment (CCA) Recommendations are recommendations that fall into one
of the following four broad implementation activity categories:
1. Improving the condition of components through replacement, refurbishment or repair.

2. Determining the condition of components through inspection or testing, followed by remedial
actions if the components are found to be aged.
3. Improving the aging management practices to mitigate the effects of future aging through an
adjustment to the Preventative Maintenance Program
4. Addressing obsolescence.
Defence in Depth (DID) consists of a hierarchical deployment of multiple levels of barriers between
radioactive materials and the environment using equipment and procedures that ensures no single
human error or equipment failure at one level of defence, nor even a combination of failures at more than
one level of defence, propagates to jeopardize Defence in Depth at the subsequent level or leads to harm
to the public or the environment.
Emerging Issues are changes or additions made after the ISR Code Effective Date to the modern
version of the codes and standards listed in Appendix B of N-PROC-LE-0005 [R-3], to assess the impact
of these changes on the IIP, as well as any new significant industry OPEX. Emerging issues shall be
considered up to December 31, 2013.
Page 10 of 11
0235 TBD DNGSGA 0002 00

Document
Global Assessment (GA) provides an overall risk judgment on the acceptability of continued plant
operation based on the significant ISR results and the EA results, and corresponding mitigation actions
and improvements. The assessment of risk includes consideration of plant strengths which are areas of
the refurbished plant design, condition and operation that generally meet or exceed new requirements
imposed on the nuclear industry over the last 10 years, including those for new plants. The Global
Assessment takes into account the Safety Improvements to address the issues identified in the EA and
the ISR and the Safety Improvements resulting from identified opportunities to reduce the overall plant
risk. The Global Assessment also incorporates the results of the Defence in Depth assessment.
Global Assessment Report (GAR) summarizes the results of the Global Assessment by providing a
high level summary of the ISR and EA and an overall judgement on nuclear safety.
Integrated Implementation Plan (IIP) is the integrated result of the EA and ISR, identifying all necessary
Safety Improvements, proposed plant modifications, safety upgrades, compensatory measures and
improvements to operation and management programs that will apply to the project and to long term
operation.
Integrated Safety Review (ISR) is a comprehensive assessment of an existing nuclear generating

station in order to determine:
1. Extent to which the plant conforms to modern high-level safety goals and requirements.
2. Extent to which Licensing Basis remains valid.
3. Adequacy and effectiveness of arrangements that are in place to maintain plant safety for long-
term operation.
4. Safety improvements to address gaps with respect to modern safety requirements identified
during the assessment.
ISR Gap is a clause for which a safety requirement in a code or standard is not met or for which the intent
of the clause is not met depending on the type of code or standard. ISR Gaps exist for:
1. PROL Codes and Standards the review finds that the safety requirement of a clause has not
been met.
2. Non-PROL Codes and Standards the review finds that it does not meet either the safety
requirement or the intent of a clause (or set of clauses).
3. Review Task the assessment of the Review Task finds that it does not meet either the safety
requirement or the intent of the Review Task.
ISR Issue is a compilation of ISR Gaps with similar scope. The categorization, prioritization and
resolution of an ISR Issue shall encompass all the included ISR Gaps.
ISR Open Issues is an ISR Issue requiring resolution.
Page 11 of 11
ONTARIOFiiiiiER
GENERATION Report
Document Number:
NK38-REP-03680-10197
N/A
Sheet Number: Revision:
N/A R001
Title:
EVALUATION OF SEISMIC, PRESSURE BOUNDARY AND ACCIDENT MANAGEMENT ISR

ACCEPTABLE DEVIATION ISSUES FOR AGGREGATE EFFECTS BETWEEN ISSUES
Evaluation of Seismic, Pressure

Boundary and Accident Management
ISR Acceptable Deviation Issues for
Aggregate Effects Between Issues
N K38-REP-03680-1 0197 -R001
Accepted by:
--~r-~~----~~--~~~
tJ ~-' -r. 2.b: ,,"" Authorized by:
Date mtiaz Malek
Mana , Nuclear Safety Director, Nuclear Safety
0235 AD AGGREG 0001 01

Title: Evaluation of Seismic, Pressure Boundary and Accident Management ISR
Acceptable Deviation Issues for Aggregate Effects between Issues
Date Effective: May 20, 2014
Retain Until: 7 Years after Superseded
Prepared By: 2014 05 28

P. Wiebe Date
Reviewed By: 2014 05 28

K.C. Garel Date
Technical Specialist
Approved By: 2014 05 28

M.J. Jansen, P.Eng. Date
VP Engineering
This document is the property of CPUS Limited and OPG. This document may be distributed by OPG to a 3rd party
(including but not limited to the CNSC) for the purposes of validating the work including a review of the estimate, costs,
scheduling and technical components. Express written agreement from CPUS Limited is required for any other
distribution or transfer.
Page 1 of 98
0235 AD AGGREG 0001 01

Record of Revisions
Rev Date Description Prepared by Reviewed by Approved by
No.
00 2013 09 30 Issued for Use Seismic Issues- K.G. Torr K.C. Garel M.J. Jansen
Pressure Boundary T.J.
Issues - R. McCutcheon Ravishankar
Accident Management
Issues - J.M. Cuttler
01 2014 05 20 Addition of 23 P. Wiebe K.C. Garel M. Jansen
Acceptable
Deviations from
Emerging
Issues Report
and additional
open issues
that were
converted to
ADs:
1 added to
Seismic
4 added to
Pressure
Boundary
18 added to
Accident
Management
Page 2 of 98
0235 AD AGGREG 0001 01

SUMMARY
The study documented in this report examines the aggregate effects of Acceptable
Deviations (ADs) that are related to the seismic, pressure boundary, or accident
management programs.
The purpose of this study is to determine whether there are aggregate effects of
these Acceptable Deviations.
This report concludes there are no aggregate effects from ADs associated with the
seismic, pressure boundary or accident management barriers and therefore, no
impacts on public safety.
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0235 AD AGGREG 0001 01

Table of Contents
SUMMARY ...................................................................................................................... 3
1 Introduction.............................................................................................................. 5
1.1 Scope .............................................................................................................. 5
1.2 Purpose ........................................................................................................... 5
2 Description .............................................................................................................. 6
2.1 General ............................................................................................................ 6
2.2 Methodology .................................................................................................... 6
3 Assessment ............................................................................................................. 8
3.1 Seismic ............................................................................................................ 8
3.2 Pressure Boundary ................................................................................................ 19
3.3 Accident Management ................................................................................... 50
4 Conclusions ........................................................................................................... 90
4.1 Seismic .......................................................................................................... 90
4.2 Pressure Boundary ........................................................................................ 90
4.3 Accident Management ................................................................................... 90
5 References ............................................................................................................ 91
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0235 AD AGGREG 0001 01

1 Introduction
1.1 Scope
An Integrated Safety Review (ISR) is being performed to support the refurbishment of
the Darlington Nuclear Generating Station (DNGS). To assess its level of safety
compared to that of modern Nuclear Power Plants (NPPs), Darlington NGS design
documentation, programs and policies are compared to an extensive set of modern
Codes and Standards. ISR Gaps were identified where compliance with modern
Codes and Standards could not be readily confirmed. As part of the resolution
process, identified Gaps were grouped into ISR Issues. The disposition of each ISR
Issue was assessed in an Issue Resolution Form (IRF) and documented in the Final
ISR Report. ISR Issues with a low or very low safety significance, where the
preferred resolution was no further action required, were classified as Acceptable
Deviations (ADs). The classification of an ISR Issue as an AD was assigned
considering the combined effects of the Gaps grouped in that ISR Issue. It was
recognized that Gaps in other ISR issues also classified as ADs could impact on the
same components, systems, programs or other factors, such as operator action,
which are referred to as attributes in this report. The combined effects of all Gaps
included in ISR Issues, classified as ADs, were not considered when ISR issues were
resolved. The scope of this report is to determine whether there is a combination of
ADs associated with the Seismic, Pressure Boundary, or Accident Management
barriers that could result in an aggregate effect and hence impact on public safety.
1.2 Purpose
The study documented in this report examines aggregate effects of all ADs in the
areas of seismic, pressure boundary and accident management to determine whether
there are any aggregate effects and hence any impact on public safety.
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0235 AD AGGREG 0001 01

2 Description
2.1 General
A barrier is a means of controlling energy sources and work process to protect
against events with undesirable public safety, worker safety, environmental or
economic consequences. Barriers can be physical hardware such as pressure
retaining components, engineered systems, or the containment envelope. Barriers
can also be administrative in nature such as training programs, operating and
maintenance procedures, and emergency response plans.
The Acceptable Deviations considered in this study are grouped depending on the
impacted components, systems or programs into the following barriers:
Seismic: All equipment and programs that are intended to limit the impact of a
seismic event at the plant.
Pressure Boundary: Components that contain high energy fluids and must remain
intact to ensure the safe, reliable operation of the reactor.
Accident Management: Equipment, systems, and programs that enable the
organization to respond to accidents effectively.
2.2 Methodology
The scope of the ADs analysed for aggregate effect covers the ADs associated with
the following barriers:
1. Seismic - 11 Acceptable Deviations
2. Pressure Boundary Components - 43 Acceptable Deviations
3. Accident Management - 51 Acceptable Deviations.
For each of the ADs in a particular barrier, the assessment seeks to determine
whether there is an aggregate effect with other ADs within the barrier. The review
consisted of the following steps:
1. Review each Acceptable Deviation to collect pertinent information for each
issue, e.g., technical justification, safety significance.
2. Determine whether the AD is applicable to the area (i.e., seismic, pressure
boundary and accident management) being reviewed. If not, it was screened
out from further assessment.
3. Identify whether the issue was dispositioned in the acceptable deviation form
(IRF) as having no impact on the area (i.e., seismic, pressure boundary and
accident management). If so, it was screened outno further assessment.
4. Review each remaining AD to identify the applicable attributes (e.g., same
system, component or program).
5. Identify the ADs that share these assessment attributes, i.e., those that are
similar and could have a compounding effect.
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0235 AD AGGREG 0001 01

6. For those remaining ADs, determine whether there is an aggregate impact

when considered together.
7. If there is an aggregate effect, this report would then recommend that such
ADs be evaluated further to assess and identify any practical remedial action.
Page 7 of 98
0235 AD AGGREG 0001 01

3 Assessment
3.1 Seismic
The eleven (11) Acceptable Deviations (ADs) that potentially impact the seismic
qualification of Systems, Structures and Components (SSCs), or the ability to meet
seismic design requirements, are summarized in Table 3.1.1 below. The attributes
considered in assessing the aggregate effect on the seismic barrier are identified in
Table 3.1.2 for each AD. These include Affected Components, Affected Systems and
Programs.
3.1.1 Review of 11 Seismic Acceptable Deviations

Table 3.1.1 summarizes the IRFs on the following 11 issues: D029, D064, D103,
D285, D014, D299, D366, D414, D415, D427 and D499. The table presents a
summary of the seismic gaps in each of the ADs listed above.
Table 3.1.1 Summary of IRFs for 11 Seismic ISR issues
Issue Title and IRF Record Summary

D029 Compliance with CNSC Three (3) gaps are identified in D029, but only one gap - Gap 00402 - concerns
[R-1] R-8 seismic qualification. The gap is against Clause 3.9 of R-8, which in the
NK38-REP-00770- assessment was interpreted to mean that both SDSs must be seismically
0419196 R001 qualified to have complete functionality before and after a Design Basis
Earthquake (DBE). While SDS2 is fully qualified, the gap is declared against the
full functionality of SDS1, i.e. SDS1 only partially meets the functionality
requirement because while the rods can be dropped into the core, their
withdrawal to rearm the system is not a seismically qualified function.
D064 Seismic Monitoring Two (2) gaps are related to the lack of performing on-power testing and routine
[R-2] System Testing inspection and recalibration of the entire Seismic Monitoring System (SMS). No
scheduled testing or Predefined Maintenance Identifications (PMIDs) for the
NK38-REP-00770- Seismic Monitoring System were found to demonstrate conformance with testing
0421410 R001 requirements.
D103 ASME Section III Stress The eight (8) gaps included in this AD relate to new stress limits and stress
[R-3] Limits and Stress intensities for Service Levels C and D and new design requirements for the
Intensity Limit Factors design of bolted and welded joints on NF supports that have been incorporated
in the current ASME Section III code since 1980. This is considered a seismic-
NK38-REP-00770- related issue because seismic design specifications typically requiring computed
0421810 R000 stresses in components to not exceed Level C Service limits and Level D limits
for supports.
D285 Seismic Design The scope of this AD includes seismic design considerations for concrete safety-
[R-4] Provisions for Concrete related structures other than containment. Five (5) gaps identify non-compliance
Safety-Related Structures with CSA standard, all of which are related to requirements of CSA N291-08
which are more stringent than the corresponding requirements in the original
NK38-REP-00770- design code.
0426315 R000
D014 Anchorage System Twenty (20) gaps are identified against new prescriptive requirements in the
[R-84] Requirements in current edition of CSA N287.2-08, which concerns material specifications for,
Concrete Containment and testing of, anchors embedded in concrete containment structures. Two (2)
Structures gaps relate to new requirements in the CSA N287.3-93, which covers design
requirements of concrete containment structures. There are only three (3) gaps
Page 8 of 98
0235 AD AGGREG 0001 01


related specifically to seismic requirements, and these are among the 20 gaps
against CSA N287.2-08 concerning embedded anchors in concrete containment
structures.
D299 Anchorage Requirements The one (1) gap from the review of CSA N291-08 identifies that anchors in
[R-85] for Safety-Related DNGS safety-related structures do not comply with Clause 12 of CSA N287.2-
Structures 08, as required by Clause 5.7 of CSA N291-08. The 20 gaps against Clause 12
of CSA N287.2-08 are addressed in AD D014, above. However, AD D014
addresses only embedded anchorage systems for concrete containment
structures, whereas this AD addresses all other safety-related concrete
structures.
D366 Requirements for the Four (4) gaps are identified against the CSA N285.4-05 standard requirements to
[R-13] Supplementary Periodic perform supplementary periodic inspection of fuel channel feeder pipes. The
Inspection of Fuel standard specifies sample sizes of inlet and outlet feeder pipes to undergo
Channel Feeder Pipes thickness measurements. The only gap related to seismic is against the timing
specified for the inspection of feeder piping seismic restraints. The gap is due to
the pre-2005 schedule for feeder pipe seismic restraint inspections that does not
comply with the new inspection schedule requirement.
D414 Time Histories Two (2) gaps are identified against the CSA N289.3-M81 standard requirements
[R-86] for seismic qualification procedures. Both gaps are related to the lack of
evidence in the design reports that requirements in the standard pertaining to the
use of the time history analysis method were met. The first gap concerns the
seismic analysis of the fuelling machine and the lack of clear evidence in the
report that the frequency analysis required by the standard had been applied.
The second gap concerns the use of only one time history for both horizontal
directions in the analysis, but the report does not does not show evidence of
statistical independence of the three seismic inputs as required by the standard.
D415 Soil-Structure Interactions Eight (8) gaps are identified in two code reviews, one against the CSA N289.2-
[R-87] M81 standard requirements for ground motion determination, and the other
against the CSA N289.3-M81 standard requirements for seismic qualification
procedures. These gaps all relate to the lack of evidence in the seismic design
report of DNGS structures to explicitly account for effects due to
soil-structure interaction (SSI),
difference between modeling techniques and analysis approaches for
the evaluation of the site response analysis for the free-field case,
complete interaction versus the sub-structure technique for the
soil/foundation/structure system.
D427 Seismic Qualification The one (1) gap is identified against Clause 4.2.6 in the review of CSA N289.4-
[R-88] General 12. This is a new clause introduced in the latest edition of the standard and
reflects the lack of evidence to demonstrate that when existing seismically
qualified equipment is replaced, the effect that age degradation (due to
corrosion, erosion, thermal and radiation aging, elevated service temperature,
humidity and vibration) has on its seismic functionality must be taken into
account during testing that demonstrates its seismic qualification.
D499 Seismic Hazards in Site Seven (7) gaps related to the seismic hazard requirements of IAEA-SSG-9-2010,
Evaluation for Nuclear "Seismic Hazards in Site Evaluation for Nuclear Installations. These gaps all
[R-89]
Installations relate to either (i) the techniques for production or usage of time histories, and (ii)
equipment used to develop seismic hazards.
3.1.2 Discussion of the Eleven Seismic ADs

As noted in the methodology section of this report, this subsection documents the
initial screening of the ADs to determine which ADs will be screened out and the
remainder identified for aggregate assessment.
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As noted in Section 3.1.1, the eleven issues listed in Table 3.1.1 are seismic ADs
identified in compliance reviews of one or more of the following modern codes and
standards: CNSC R-8, ASME Section III, CSA standards N285.4-05, N287.2-08,
N289.2-M81, N289.3-M81, N289.4-12, N289.9-M91, N291-08, and IAEA-SSG-9-
2010.
Issue D029 [R-1]: The one gap related to seismic qualification is considered
acceptable, since the safety function (reactor shutdown) is not degraded by the issue.
The functionality of SDS2, and SDS1 to discharge the shut-off rods into the core are
qualified to the DBE level.
Although the combined safety significance category of the AD is 3, there is no

potential for this AD to aggregate to a higher level with another AD related to seismic
design because it pertains only to post-seismic re-arming of SDS1.
This AD is therefore excluded from further review in this aggregation assessment.
Issue D064 [R-2]: The gaps in this Issue have been designated ADs because the
finding triggered: (i) an immediate response to institute weekly walkdowns by the
System Responsible Engineer (SRE) to confirm the status of the Seismic Monitoring
System (SMS), and (ii) scheduled testing and routine maintenance activities in
accordance with the vendor manual recommendations were entered in the
Permanent Maintenance Living Program. The SMS is now expected to perform as
per design.
The combined safety significance category of the AD is 3; however there is no

potential for this AD to aggregate into a significant impact with another AD related to
seismic design because the SMS plays no role in dynamically influencing any seismic
safety barriers. It serves primarily to indicate the occurrence of low-level seismic
motions, and to record response levels in 9 locations of the station. The recorded
dynamic response measurements aid in evaluating the condition of SSCs after
seismic events that are less intense than the Design Basis Earthquake level, to
establish viability of continued operation.
With the implementation of surveillance and maintenance measures, the gaps are no
longer present so there is no potential for aggregation.
Issue D103 [R-3]: The 1980 Edition of the ASME Code Section III did not provide
specific analytic techniques or criteria for the evaluation of Level C and D service
conditions; however, the Code has always required the licensee to provide a Design
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Specification, including Service Levels A though D, and the designer has always been
required to consider all loadings contained in the Design Specification.
The designs of the DNGS type NF supports were registered by the manufacturer with
the Authorized Inspection Agency, in accordance with Clause 6 of CAN3-N285.0-
M81, and their designs were reviewed and inspected for compliance with ASME
Section III or the Code philosophy based on a technical basis. NF supports were
registered only after confirming that the design met the philosophical and technical
requirements of the Code.
Hence, NF supports at DNGS constructed to the 1980 Edition of the code are
considered to be of the same or equivalent level of safety as NF supports constructed
to the 2007 Edition; and furthermore, OPGs governing process ensures that these
NF supports continue to comply with ASME Section III. Consequently the gaps are
considered an AD from the requirements of the 2007 Edition of the ASME BPV
Section III Code. The gaps in this AD are therefore considered to have no impact on
the seismic resistance of existing NF supports.
D103 shares attributes with other seismic ADs and therefore it is included in the
aggregate assessment in section 3.1.3.
Issue D285 [R-4]: The IRF identifies non-compliance with CSA N291-08 standard, all
gaps listed in D285 are related to requirements of CSA N291-08 that are more
stringent than the corresponding requirements in the original design code. Seismic
qualification requirements for DNGS safety-related concrete structures were defined
by several documents including Nuclear Safety Design Guide DG-38-03650-2B, CSA
Standards CAN3-N289.1-M80, CAN3-N289.3-M81 and CAN3-A23.3-M77, and also
the National Building Code of Canada, 1977 Edition.
The intent of CSA N291-08 as indicated in IRF D285 [R-4] is to ensure that safety-
related concrete structures will perform as required under design basis conditions,
including seismic events. Clause 6.1.2 of CSA N291-08 permits alternative methods
of design provided that the design ensures a level of safety and performance
commensurate with the requirements of this Standard. The alternative methods shall
be approved by the owner/licensee and shall be acceptable to the regulatory
authority. The AD shows that the requirements for using alternative methods for
design were met through the use of appropriate codes, standards and analysis. This
supports the claim that the DNGS safety-related concrete structures, other than
containment, have been designed to withstand design basis seismic events.
Consequently the gaps identified in assessment are considered Acceptable
Deviations.
The combined safety significance category of the AD is 4. The AD reflects that the
concrete safety-related structures as DNGS have been designed to withstand seismic
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loadings up to the DBE level, and that the safety margin in their design would be
more conservative if done to current code requirements due to the more stringent
requirements. However, the safety margins with the older code version are
acceptable. Consequently these gaps are considered to have no impact on the
seismic resistance of qualified structures.
Issue D014 [R-84]: The 3 seismic gaps are related to material and testing
requirements for embedded anchors and anchor systems in the DNGS concrete
containment system. The design and material requirements were per the
Construction Standard L-964-79, which was governed by CSA standards N287.2-
1977 and N287.3-1978. The Design Manual for Reactor Building Structures indicates
that anchorage specifications were to be used and that the accident scenario was to
be considered in the design of concrete containment structures. There was also a
requirement at that time to test representative samples of the various types of mass-
produced embedded parts and expansion anchors to demonstrate their load carrying
capacities, but this was to comply with National Building Code of Canada 1970 and
1977. Consequently, the gaps are considered an AD because the seismic design
standards of the day for embedded anchors were met, and the material specifications
adopted and testing performed, are consistent with the intent of the N287.2-08
standard. Furthermore, the condition of concrete containment structures is routinely
monitored by the periodic inspection program under CSA N287.7.
The combined safety significance category of the AD is 4. The AD has no impact on

the safety performance of the embedded anchors in concrete containment structures;
it merely shows that if they had been designed to the new code requirements in the
current code they would include increased conservatism in their seismic design
characteristics.
Issue D299 [R-85]: The gaps concern material and testing requirements for anchors
and anchor systems in the DNGS safety related concrete structures. The design and
material requirements that were followed were per the Construction Standard L-964-
79, which was governed by CSA standards N287.2-1977 and N287.3-1978. The
Design Manual for Reactor Building Structures indicates that anchorage
specifications were to be used and that the accident scenario was to be considered in
the design of concrete containment structures. There was also a requirement at that
time to test representative samples of all mass-produced anchors to demonstrate
their load carrying capacities, but this was to comply with National Building Code of
Canada 1970 and 1977. Thus the rationale for classifying this an AD is the standards
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of the day were met and these are consistent with the intent of the N287.2-08
standard.
The combined safety significance category of the AD is 4. As in AD D014, this AD

has no impact on the safety performance of the embedded anchors in safety-related
structures; it merely shows that if they had been designed to the new code
requirements in the current code they would include increased conservatism in their
seismic design characteristics.
Issue D366 [R-13]: The seismic restraints have been inspected per the periodic
inspection program since the startup of each DNGS reactor. The gap merely reflects
the change in the required inspection schedule that was introduced by CSA N285.4-
05. The inspection schedules were promptly revised in 2005 to comply with the
newly issued standard and have continued as required since then. After new feeder
piping is installed when the fuel channels are replaced, full compliance with N285.4
will be attained.
The combined safety significance category of the AD is 4. This AD has no impact on

safety related performance; it merely reflects a change in inspection schedule. The
inspections have always been performed and found to be in an acceptable condition.
Issue D414 [R-86]: In general, Floor Response Spectra were applied for DNGS
component seismic qualification. In some specific cases the time history method was
used, as permitted by the standard. The gaps relate to the application of time
histories and pertain to the lack of evidence that: i) time histories that were applied as
dynamic inputs at support points took into account frequency variations due to
uncertainties in structural soil properties; and ii) that the three directional seismic input
were statistically independent.
The rationale for considering these gaps as an AD is that the seismic analysis
method is conservative and adequate, which is confirmed by the DNGS Site
Probabilistic Seismic Hazard Assessment that concludes the seismic design of
systems and structures are sound. Consequently these gaps are considered to have
no impact on the seismic resistance of qualified structures.
The combined safety significance category of the AD is 4.
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Issue D415 [R-87]: The gaps were raised in response to CNSC comments about
whether Soil Structure Interaction effects had been adequately considered the DNGS
seismic analysis. The rationale for considering these gaps as an AD is that the
DNGS Site Probabilistic Seismic Hazard Assessment [R-62] confirms that DNGS
conforms to CNSC S-294 [R-63] and to various international guides on seismic PRA,
and that the results are considered acceptable. Consequently these gaps are
considered to have no impact on the seismic resistance of qualified structures.
Issue D427 [R-88]: The gap reflects a gap in evidence to demonstrate compliance
with a new clause in the standard that requires ageing effects be included in the
seismic qualification by testing of new replacement equipment. Original seismically
qualified equipment installed in the station continues to be considered qualified, and
is expected to remain so through the implementation of the Integrated Aging
Management Program. This program has been established to maintain the condition
of critical NPP equipment via routine monitoring and maintenance activities. These
measures are expected to ensure that degradation effects will not be permitted to
advance to the extent that seismic functionality is impaired, which meet the intent of
clause 4.2.6 of the CSA N289.4-12 standard. Consequently this gap is considered to
have no impact on the seismic resistance of equipment qualified by test.
Issue D499 [R-89]: This issue contains gaps that represent differences between the
methods, techniques, and analysis of seismic qualification used during the original
design and construction of the plant and modern codes and standards. The latest
version of IAEA-SSG-9-2010 mentions several methods that may be used by existing
plants to assess and confirm that their seismic safety case remains strong, despite
changes such as the ones identified in this issue. One of the methods which existing
plants may use is to perform a Seismic Probabilistic Safety Assessment (SPSA) (also
known as a Seismic Probabilistic Risk Assessment (SPRA)). The completion of the
DNGS SPRA provides compliance with CNSC Regulatory Standard S-294 and is
consistent with IAEA-SSG-9-2010 methods.
The rationale for considering these gaps as acceptable deviations is that the seismic
analysis method used in the original design is conservative and adequate. It
consisted at a high level with the Seismic Design Guide NK38-DG-03650-2B defining
the requirements to ensure relevant plant components were seismically qualified. It
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also provided guidance based on early versions of the CSA N289 series of standards.
Seismic qualification was demonstrated via analysis, testing, a combination of both,
or with use the experience data from the actual strong motion earthquakes for all
seismically qualified components.
Also, the conservatism in the original design method has been confirmed by the
DNGS Site Probabilistic Seismic Hazard Assessment, that concludes the seismic
design of systems and structures are sound. Consequently these gaps are
considered to have no impact on the seismic resistance of qualified structures.
3.1.3 Review of 8 Seismic ADs collectively for aggregate effects
The collective review of these eight (8) ADs for aggregate effects was performed
using the methodology outlined in section 2.2. Three of the 11 ADs, viz. D029, D064
and D366, listed in Table 3.1.1, have been eliminated from the aggregate
assessment as described in Section 3.1.2.
Table 3.1.2 below lists the attributes for each of the 8 ADs in the columns adjacent to
the AD column. The column on the far right identifies the Associated ADs, those that
have commonality with each AD.
The table shows there is no aggregation between D103 [R-32], regarding Type NF
supports, and D427 [R-33], regarding aging effects in seismic qualification testing.
Neither of these ADs share attributes with the other six and therefore they are
excluded from further aggregate assessment.
The remaining 6 ADs have the same attribute Seismic Design insofar as the gaps
are all related to the design program by which the qualified SSCs were designed1.
While this is a common factor, the seismic design of Darlington NGS has been shown
to be conservative such that all qualified SSCs are expected to withstand the affects
of a design basis seismic event [R-62].
ADs D014 and D299 concern requirements for new material and equipment testing of
anchorage assemblies, but they relate to different structures - concrete containment
structures and safety-related concrete structures (other than containment)
1
There are other shared attributes amongst the 6 ADs, e.g. safety-related concrete structures. However, the ADs
grouped together with these attributes are a sub-set of the six with the seismic design attribute being assessed together
and therefore these smaller grouped ADs do not need to be assessed separately.
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respectively. Also, it is judged that these two ADs would have negligible aggregate
impact with the other four ADs, since as per the IRFs for D014 and D299, their safety
impact is negligible.
AD D285 deals with design methods for safety related concrete structures (not
including containment). ADs D414, D415 and D499 all relate to the generation of
seismic loads on SSCs, including how time histories are generated and used, and
soil-structure interaction. Each of these four ADs is not expected to have any impact
on safety when considered individually (i.e. minimal reduction in safety margins). The
Seismic Probabilistic Risk Assessment (SPRA) [R-69] confirms that DNGS conforms
to CNSC S-294 [R-63] and to various international guides on seismic PRA, and that
the results are considered acceptable. The SPRA is the appropriate method to
examine the integrated impact of different variables affecting safety, including the
seismic hazards and SSC margin to failure. Therefore, the SPRA results support that
the combined impact of low safety significance acceptable deviations would not
impact on safety margins.
Therefore, it is concluded that the aggregate impacts of these 8 seismic ADs together
on OPGs seismic design integrity is negligible and hence have no impact on public
safety.
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Table 3.1.2 Aggregate Assessment of Combinations of the Eight Seismic ADs
Attribute
AD Affected Affected Program Associated
Component System/Structure ADs
D103 [R-3] New Type NF Structures and N/A None
Level C stresses bolted equipment reliant
& stress supports on NF supports
intensities
introduced for
Type NF bolted
supports
D285 [R-4] Non N/A Safety-related Seismic design D285, D014,
compliance with concrete D299, D414,
more stringent structures D415, D499
requirements in
current N291-08
standard
D014 [R-84] New anchorage concrete Seismic design D285, D014,
material and assemblies containment D299, D414,
equipment structures D415, D499
testing
requirements for
anchorage
assemblies in
concrete
containment
structures
D299 [R-85] New anchorage safety-related Seismic design D285, D014,
material and assemblies concrete D299, D414,
equipment structures D415, D499
testing
requirements for
anchorage
assemblies in
safety-related
concrete
structures
D414 [R-43][R- Fuelling Reactor building Seismic design D285, D014,
43] No evidence machine (input spectra) D299, D414,
Time History Feeders D415, D499
seismic analyses
applied (frequency)
frequency shifts
and independent
xyz input spectra
D415 [R-87] No No specific Seismically Seismic design D285, D014,
evidence soil component qualified D299, D414,
structure structures D415, D499
interaction
effects
considered in
seismic analysis
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Attribute
D427[R-88] No No specific N/A Seismic None
evidence seismic component qualification of
qualification equipment
testing of
replacement
equipment
includes aging
effects
D499 [R- No specific Reactor building Seismic design D285, D014,
89]Seismic component (input spectra) D299, D414,
Hazards in Site D415, D499
Evaluation for
Nuclear
Installations
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3.2 Pressure Boundary

As per the methodology outlined in section 2.2, the forty three (43) pressure boundary
related ADs were categorized into the following attributes:
o Periodic Inspection Programs -18 ADs
o ASME Section VIII Pressure Vessels - 2 ADs
o Reactor Components - 3 ADs
o Supports for Nuclear Class Piping and Components 2 ADs
o Nuclear Class 2 and Class 3 Pumps - 1 AD
o Nuclear Class 1 Valves 1 AD
o Safety Related Structures - 3 ADs
o Nuclear Class 1 Piping 1 AD
o Nuclear Class 2 and Class 3 Piping 1 AD
o Construction Concessions and Approvals 7 ADs
o Steel valves, Class 6 1 AD
o Pressure Relief Devices, Class 6 - 1 AD
o Pressure Boundary Program Governance 2 ADs
For the aggregate assessment, the effects of ADs related to Periodic Inspection
Programs (PIPs) were considered in combination with other ADs that are not PIP-
related.
The following subsections summarize the aggregate assessment of ADs with

common attributes.
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3.2.1 Review of Acceptable Deviations related to Periodic Inspection Programs
Table 3.2.1 below summarizes 18 IRFs related to Periodic Inspection Programs:

D151, D160, D360, D361, D362, D363, D364, D365, D366, D367, D368, D369,
D392, D393, D417, D418, D419 and D564.
Table 3.2.1 Summary of IRFs for Periodic Inspection Programs ADs
AD Title and IRF Record Summary

D151 Standard Requirements Forty three (43) gaps are identified against clause 12 of CSA N285.4-05,
[R-5] for Fuel Channel including UPDI (June 2007). These arise because the periodic inspection
Pressure Tube requirements for fuel channel pressure tubes have been modified in the 2005
Inspections version of CSA-N285.4 compared to the 1994 version of the standard.
NK38-REP-00770-
0425557
D160 Visual Inspection Three (3) gaps are identified against clauses 8.4.2.1, 8.4.2.2 and 8.6.5 of CSA
[R-6] Requirements in CSA- N285.5-M90 (2005). This standard requires visual examination of all component
N285.5-M90 supports, including those covered by insulation. The Darlington NGS PIP states
that supports are inspected to the extent possible without removal of insulation,
NK38-REP-00770- unless there is visible evidence that damage to the support.
0425566 R000
D360 CNSC staff comment on One (1) gap is identified against clause 3.7.1 of CSA N285.4-05. In some
[R-7] the CSA N285.4 Code locations there is insufficient access to permit the required inspections of the full
Review Report. extent of all the welds initially selected for periodic inspection.
D361 CNSC staff comment on Two (2) gaps are identified against clauses 7.4.3(a) and 7.4.4.3(a) of CSA
[R-8] the CSA N285.4 Code N285.4-05. In some case, the welds with highest fatigue usage factor or stress
Review Report. ratio that were originally selected for inspection are not inspected because they
are in areas where radiation fields are too high.
D362 CNSC staff comment on Two (2) gaps are identified against clauses 7.4.2.2 and 7.4.3 of CSA N285.4-05.
[R-9] the CSA N285.4 Code The standard requires visual examination of all component supports, including
Review Report those covered by insulation. The Darlington NGS PIP Plan states that supports
are inspected to the extent possible without removal of insulation, unless there is
visible evidence that damage to the support.
D363 CNSC staff comment on One (1) gap is identified against Clause 7.4.3(c) of CSA N285.4-05. Periodic
[R-10] the CSA N285.4 Code inspection of mechanical couplings requires disassembly. Darlington NGS does
Review Report not disassemble mechanical couplings specifically for periodic inspection
purposes.
D364 CNSC staff comment on One (1) gap is identified against Clause 7.6.1.2 of CSA N285.4-05. The CSA
[R-11] the CSA N285.4 Code N285.4-05 standard requires that all inspections be carried out over the last half
Review Report of the ten (10) year inspection interval. Darlington NGS spreads the periodic
inspections over the full 10 year period of each inspection interval.
D365 CNSC staff comment on One (1) gap is identified against Clause 8.3(b) of CSA N285.4-05. Where
[R-12] the CSA N285.4 Code unacceptable or significant service-induced indications are found, additional
Review Report inspection be performed on the identical components in other Units within two
years. It may not always be possible to perform the required follow-up
inspection, two years because DNGS operates on a 3-year planned outage
cycle.
D366 CNSC staff comment on Four (4) gaps are identified against clauses 13.2.2.2, 13.2.2.3(a), 13.2.3.1 and
[R-13] the CSA N285.4 Code 13.3.3.1 of CSA N285.4-05. This Acceptable Deviation is related to new
Review Report requirements for inspection of fuel channel feeder pipes. Inspections performed
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AD Title and IRF Record Summary

in accordance with earlier versions of the Darlington NGS PIP Plans did not meet
these new requirements.
D367 CNSC staff comment on One (1) gap is identified against clause 12.2.2.1(a) of CSA N285.4-05. The
[R-14] the CSA N285.4 Code standard requires the volumetric and dimensional periodic inspection of fuel
Review Report channel pressure tubes to include the full volume of the tube. The equipment
used at Darlington NGS cannot scan 100% of the pressure tube.
D368 CNSC staff comment on Eight (8) gaps are identified against clauses 12.2.2.1(d), 12.2.2.2, 12.2.2.3,
[R-15] the CSA N285.4 Code 12.2.2.4, 12.3.2.1, 12.3.2.2, 12.4.2.1 and 12.4.2.2.2 of CSA N285.4-05. This
Review Report Acceptable Deviation is related to new requirements for inspection of fuel
channel pressure tubes. Inspections performed in accordance with earlier
versions of the Darlington NGS PIP Plans did not meet these new requirements.
D369 CNSC staff comment on Three (3) gaps are identified against clauses 12.2.3.1, 12.3.3.1 and 12.3.4.1 of
[R-16] the CSA N285.4 Code CSA N285.4-05. This Acceptable Deviation is related to new requirements for
Review Report inspection of fuel channel pressure tubes. Inspections performed in accordance
with earlier versions of the Darlington NGS PIP Plans did not meet these new
requirements.
D392 CNSC staff comment on One (1) gap is identified against clause 12.2.2.1(b) of CSA N285.4-05. The
[R-17] the CSA N285.4 Code standard requires measurements to determine the pressure tube to calandria
Review Report tube (PT to CT) gap. One allowable method is to determinate annulus spacer
locations and tube deflection (sag). Darlington NGS uses the as-installed spacer
locations because identification of spacer locations by in-service inspection
methods is unreliable.
D393 CNSC staff comment on Two (2) gaps are identified against clauses 12.2.4.5.1 and 12.2.4.3.1(b) of CSA
[R-18] the CSA N285.4 Code N285.4-05. The standard requires recording criteria for laminar flaws to be
Review Report included in the inspection procedures and demonstration that the inspection
systems can reliably detect each of the various artifacts prescribed in the
standard for inclusion in the volumetric calibration specimen.
D417 ANI and/or CNSC does Three gaps are identified against CSA N285.4-09 all dealing with inspection
not approve procedures procedures and qualification. N285.4-09 including Update 1 and Update 2
[R-90] as required by N285.4-09 requires that inspection procedures be demonstrated to the satisfaction of
UPD2 the authorized inspector. OPG governance permits qualification of PIP
inspection procedures and personnel by the CANDU Inspection
Qualification Bureau (CIQB).
D418 Code Refresh Report of One (1) gap is identified against Clause 7.1.3.3 of CSA N285.4-09 UPD 2-2011.
[R-49] DNGS compliance with When Fatigue Usage Factors are not determined, Clause 7.1.3.3 of CSA N2854-
CSA N285.4-09 including 09 requires the fatigue classification to be designated high when operational
Update 1 and experience under similar conditions indicates susceptibility to fatigue cracking.
Update 2. Although feeder cracking has been observed at other CANDU NPPs, DNGS
Piping and Component PIP Plans do not set the fatigue usage factors feeders at
high for the feeders.
D419 Code Refresh Report of One (1) gap is identified against clause 7.1.4.1(b) of CSA N285.4-09 UPD 2-
[R-50] DNGS compliance with 2011. Confirmation was not readily available that primary and secondary
CSA N285.4-09 including stresses, including thermal expansion stresses, were used to calculate stress
Update 1 and ratios per CSA N285.4-09 for identifying preferred inspection areas.
Update 2.
D564 DNGS Governance OPG governance and PIP plans do not make reference to the latest version of
Documents and PIP CSA N285.5 (i.e. N285.5-13). The previous edition of the code is referenced.
[R-91]
Plans Reference Previous
Edition of Code
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3.2.2 Discussion of the Acceptable Deviations related to the Periodic Inspection

Program
As noted in Section 3.2.1, the ADs listed in Table 3.2.1, are Periodic Inspection
Program ADs identified during compliance reviews of one or more of the following
modern codes and standards: CSA standards N285.4-05, N285.5-M90 (R2005), and
N285.4-09 UPD 2-2011.
Issue D151 [R-5]: The requirements of CAN/CSA N285.4-05 for periodic inspection
of fuel channel pressure tubes have changed. Issue D151 includes 43 Gaps related
to these changes. The combined safety significance category of the AD is 4. Forty
(40) of these Gaps are addressed and resolved by revisions to the Fuel Channel
Pressure Tube Periodic Inspection Plan. Actions to address the remaining three
gaps are in progress and remain open. Open gaps are not part of the Aggregate
assessment of Acceptable Deviations.
Issue D160[R-6]: CSA N285.5-M90 (R2005) requires visual examination of all

supports for containment boundary components, including those covered by
insulation. Issue D160 includes one Gap related to this requirement. The Darlington
NGS PIP states that supports are inspected to the extent possible without removal of
insulation, unless there is visible evidence that damage to the support. The current
inspection methods are justified by savings in time, effort and dose exposure to staff
and have been accepted by the CNSC.
Portions of supports for containment boundary components covered by insulation are

not inspected unless there is evidence of damage or when attachment welds require
inspection.
The effects of this Acceptable Deviation in combination with other ADs are
considered for aggregate assessment in section 3.2.25.
Issue D360 [R-7]: In some locations, there is insufficient access to permit inspection
of the full extent of all the welds initially selected for periodic inspection. Issue D360
includes one Gap related to the weld inspection requirements of CAN/CSA N285.4-
05. Access issues are addressed in the PIP Plans.
Obstructed welds are inspected to the extent possible or equivalent welds are
inspected.
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Some welds are not fully inspected.
Issue D361[R-8]: In some cases, the welds with highest fatigue usage factor or
stress ratio that were originally selected for inspection are not inspected because they
are in areas where radiation fields are too high. Issue D361 includes two Gaps
related to the weld inspection requirements of CAN/CSA N285.4-05. The weld in the
same pipe run that has the next highest fatigue usage factor is inspected. Typically
there are only small differences between the highest and next highest values.
Substituting the selected site for its alternate does not significantly diminish the
caliber of inspection.
Inspected welds may not be the ones with the highest fatigue usage factors.
Issue D362 [R-9]: CAN/CSA N285.4-05 requires visual examination of all component
supports, including those covered by insulation. The Darlington NGS PIP states that
supports are inspected to the extent possible without removal of insulation, unless
there is visible evidence that damage to the support. Issue D362 includes two Gaps
related to inspection of component supports. The current inspection methods are
justified by savings in time, effort and dose exposure to staff and have been accepted
by the CNSC.
Portions of piping supports covered by insulation are not inspected unless there is
evidence of damage or when attachment welds require inspection. .
Issue D363[R-10]: CAN/CSA N285.4-05 requires disassembly of mechanical

couplings for periodic inspection. Darlington NGS does not disassemble mechanical
couplings specifically for periodic inspection purposes. Issue D362 includes one
Gap related to inspection of mechanical couplings. All couplings do receive a visual
inspection only without disassembly, and a full inspection when disassembled for
maintenance or other reasons. The current inspection methods are justified by
Page 23 of 98
0235 AD AGGREG 0001 01

savings in time, effort and dose exposure to staff and have been accepted by the
CNSC.
Mechanical couplings are visually inspected only until they are disassembled for
maintenance or other reasons.
Issue D364[R-11]: CSA N285.4-05 requires that all inspections be carried out over
the last half of the ten (10) year inspection interval. Darlington NGS spreads the
periodic inspections over the full 10-year period of each inspection interval. Issue
D362 includes one Gap related to periodic inspection intervals. OPG requires the full
10-year period of each inspection interval to complete all of the selected periodic
inspections. The CNSC has accepted this practice. Darlington NGS PIP Schedules
comply with the conditional relaxation in N285.4-09 including Update 2, which allows
inspection during at any time during the inspection interval provided that the next
inspection is planned at approximately the same point in time during the next interval.
The combined safety significance category of the AD is Not Applicable.

This AD is excluded from the aggregation assessment.
Issue D365[R-12]: Where unacceptable or significant service-induced indications are

found, CSA N285.4 -05 requires additional inspection be performed on the identical
components in other Units within two years. It may not always be possible to perform
the required follow-up inspection, two years because DNGS operates on a 3-year
planned outage cycle. Issue D365 includes one Gap related to additional inspections
of identical components. The Darlington PIP has shown a very low incidence of
degradation indications.
The required maximum allowable interval to perform follow-up inspections has been
removed from N285.4-09 Standard. The combined safety significance category of
the AD is Not Applicable.
Issue D366[R-13]: Inspections of fuel channel feeder pipes performed in accordance

with earlier versions of the Darlington NGS PIPs did not meet the requirements of
CSA N285.4 -05. Issue D366 includes four Gaps related to inspection of fuel channel
feeder pipes. New PIPs have since been issued which comply with the new
requirements. The combined safety significance category of the AD is 4.
Page 24 of 98
0235 AD AGGREG 0001 01

Fuel channel feeder pipes will be replaced during Darlington NGS refurbishment.
Issue D367 [R-14]: CAN/CSA N285.4-05 requires volumetric and dimensional

periodic inspection of fuel channel pressure tubes to include the full volume of the
tube. The equipment used at Darlington NGS cannot scan 100% of the pressure
tube. Issue D367 includes one Gap related to inspection of fuel channel pressure
tubes. Fuel channel inspection is a sampling program. A <5% reduction in the
overall volume inspected has a minimal effect on assessment of the overall state of
the reactor core.
Small portions of the pressure tubes are not inspected.
Issue D368 [R-15]: Periodic inspection of fuel channel pressure tubes performed in
accordance with earlier versions of the Darlington NGS PIPs did not meet the
requirements CAN/CSA N285.4-05. New PIPs have since been issued which comply
with these requirements. Issue D368 includes eight Gaps related to inspection of fuel
channel pressure tubes.
Fuel channel pressure tubes will be replaced during Darlington NGS refurbishment.
Issue D369 [R-16]: Periodic inspection of fuel channel pressure tubes performed in
accordance with earlier versions of the Darlington NGS PIPs did not meet the
requirements CAN/CSA N285.4-05. New PIPs have since been issued which comply
with these requirements. Issue D369 includes three Gaps related to inspection of fuel
channel pressure tubes.
Fuel channel pressure tubes will be replaced during Darlington NGS refurbishment.
Page 25 of 98
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Issue D392 [R-17]: CAN/CSA N285.4-05 requires measurements to determine the

pressure tube to calandria tube (PT to CT) gap. One allowable method is to
determinate annulus spacer locations and tube deflection (sag). Darlington NGS
uses as-installed spacer locations because identification of spacer locations by in-
service inspection methods is unreliable. Issue D392 includes one Gap related
measurement of pressure tube to calandria tube (PT to CT) gap. Channels in
Darlington have a tight fitting spacer design. In-service data from all OPG and BP
reactors has confirmed no movement of tight fitting spacers.
Pressure tube to calandria tube (PT to CT) gap based on as-installed spacer
locations may not be accurate.
Issue D393 [R-18]: CAN/CSA N285.4-05 requires recording criteria for laminar flaws
to be included in the inspection procedures and demonstration that the inspection
systems can reliably detect each of the various artifacts prescribed in the standard for
inclusion in the volumetric calibration specimen. It has not been confirmed that fuel
channel inspection procedures and reporting criteria comply with these requirements.
D393 includes one Gap related to detection of laminar flaws in fuel channel pressure
tubes. The ability to detect and report the occurrence of laminar flaws has minimal
impact on flaw characterization and sizing capability.
Some laminar flaws in pressure tubes may not be detected.
Issue D417 [R-90]: N285.4-09 including Update 1 and Update 2 requires that
inspection procedures be demonstrated to the satisfaction of the authorized
inspector. OPG governance permits qualification of PIP inspection procedures and
personnel by the CANDU Inspection Qualification Bureau (CIQB).
The CNSC has recognized that the most appropriate organization to review and
approve the procedures and the qualifications of the staff that perform the inspections
using those procedures, resides within the CANDU Inspection Qualification Bureau
(CIQB), which is part of the CANDU Owners Group (COG). Given this, impact of this
Page 26 of 98
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Acceptable Deviation is negligible.
Issue D418 [R-49]: CSA N285.5-09 requires the fatigue classification to be

designated high when operational experience under similar conditions indicates
susceptibility to fatigue cracking. Although feeder cracking has been observed at
other CANDU NPPs, DNGS Piping and Component PIP Plans do not set the fatigue
usage factors feeders at high for the feeders. D419 includes one Gap related to
fatigue classifications for feeders.
The combined safety significance category of the AD is Not Applicable.
In September 2009, a new suite of PIP Plans dedicated to the inspection of feeders
was introduced, thereby rendering Section 13 in the Piping and Component PIP
Plans, which covered feeder periodic inspection, redundant. Consequently the fact
that the Piping and Component PIP Plans do not classify feeders as having `high`
fatigue usage factors is an acceptable deviation that has no safety significance. This
impact of this Acceptable Deviation is negligible.
Issue D419 [R-50]: CSA N285.4-09 UPD 2-2011 requires use of primary and
secondary stresses, including thermal expansion stresses to calculate stress ratios
per used to identify preferred inspection areas. Confirmation that stress ratio
calculations used primary and secondary stresses, including thermal expansion
stresses was not readily available. D419 includes one Gap related to calculated
stress ratios. Stress ratios listed in the DNGS PIP Plans were derived from
component stress reports that were all in compliance with ASME Section III (Summer
1980), which required designers to compute primary and secondary stresses,
including thermal expansion stresses. These design stress reports are not readily
available because they are stored in the DNGS vault. To confirm that primary and
secondary stresses (including thermal stresses) were used to compute the stress
ratios listed in the PIP Plans would require these documents be retrieved,
electronically scanned and reviewed.
This impact of this Acceptable Deviation is negligible. This AD is therefore excluded

from further review in this aggregation assessment.
Issue D564 [R-91]: OPG governance and PIP plans do not make reference to the
latest version of CSA N285.5, i.e. N285.5-13. The previous edition of the code is
referenced, N285.5-M90 (R2005). The safety significance category of the AD is 4.
Page 27 of 98
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The current Darlington Operating Licence makes reference to CSA N285.5-M90

(R2005), which is consistent with PIP program governance. Per normal practice,
when the new revision of the code is included in the PROL, the PIP governance will
be updated to reflect the new revision requirements. Therefore, there is currently no
impact associated with this gap.
3.2.3 Review of Acceptable Deviations related to ASME Section VIII Pressure

Vessels
Table 3.2.3 below summarizes 2 IRFs related to ASME Section VIII Pressure
Vessels: D001 and D003.
Table 3.2.3 Summary of IRFs for ASME Section VIII Pressure Vessels ISR issues

D001 Localized Discontinuity One (1) gap is identified against clause (e) in Section UG-23 of the 2002 Edition
[R-19] Stresses of the ASME BPVC, Section VIII, Division 1. This clause reduces the Stress
Limit at Localized Discontinuity from 4S to 3S.
NK38-REP-00770-
0417574 R000
D003 Mandatory Rules for Thirty eight (38) gaps are identified against the new Section UHX of the 2003
[R-20] Shell-and-Tube Heat Edition of the ASME BPVC, Section VIII, Division 1, which replaces Appendix
Exchangers AA. This section introduced new requirements for the design of shell-and-tube
heat exchangers, general conditions of applicability for tubesheets, and
NK38-REP-00770- tubesheet characteristics that differ from those that were used during the initial
0417576 R000 design of DNGS. These differences include changes to the detailed calculation
procedures for fixed and U-tube tubesheet designs. These gaps were identified
because there was no evidence that heat exchangers manufactured to conform
with the requirements of the earlier code met the new requirements.
3.2.4 Discussion of the Acceptable Deviations related to ASME Section VIII

Pressure Vessels
The two issues listed in Table 3.2.3 were identified in compliance reviews of ASME
Section VIII (July 2007).
Issue D001 [R-19]: ASME Section VIII (July 2007) reduced the stress limit at a
localized discontinuity from 4S to 3S. D001 includes one Gap related to stress limits
a localized discontinuity. Allowable Stress values (S) were increased at the same
time. Pressure vessels designed to the old code require greater wall thickness. The
net result of the changes to allowable stress values and stress limits at a localized
discontinuity is negligible
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Issue D003 [R-20]: The design rules for shell and tube heat exchangers in ASME
Section VIII (July 2007) were revised. D003 includes 38 gaps related to design rules
for shell and tube heat exchangers. Darlington NGS designs either meet the
requirements of the 2007 edition or the design is as safe as those provided by the
technical basis of this ASME Section. The net result of the changes to design rules
for shell and tube heat exchangers is negligible
3.2.5 Review of Acceptable Deviations related to Reactor Components
Table 3.2.5 below summarizes 3 IRFs related to Reactor Components: D021, D022
and D023.
Table 3.2.5 Summary of IRFs or Reactor Components ISR Issues

D021 Cleaning Solution Six (6) gaps were identified against clause 4.5 of N285.6-08; clause 3.5 of
[R-21] Composition Limits N285.6.2-08, N285.6.3-08 and N285.6.4-08; clause 3.6 of N285.6.10-08; and
clause 3.3 of N285.6.11-08. These clauses specify limits that are lower (i.e.
NK38-REP-00770- more restrictive) than those used when these components were produced for
0417587 R000 DNGS. They now align with high quality commercially available cleaning fluids.
Although some of the affected components will be replaced during the
refurbishment life extension outage, other components will remain in service.
The deviations from the specified limits for halogens and sulphur are not
considered to have any significant impact on the specified material properties for
the components listed.
D022 Non-destructive Testing Nineteen (19) gaps are identified against CSA N285.6-08 and CSA-N285.2-99.
[R-22] of Reactor Components Some of the specifications utilized for NDT of reactor components during
construction of DNGS differ from the current requirements of CSA -N285.6-08
NK38-REP-00770- and CSA-N285.2-99 standards. In some cases, records confirming non-
0417588 R000 destructive examination requirements that were utilized during the manufacture
and assembly of zirconium alloy reactor components could not be located and
may differ from those that would be applied under the current CSA standards.
D023 Material Properties of Seven (7) gaps are identified against CSA N285.6-08. These gaps relate to
[R-23] Reactor Components changes in material requirements for some reactor components.
NK38-REP-00770-
0417589 R000
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3.2.6 Discussion of Acceptable Deviations related to Reactor Components
The three issues listed in Table 3.2.5 were identified in compliance reviews of
CAN/CSA N285.6-08.
Issue D021 [R-21]: The cleaning solution composition limits in CAN/CSA N285.6-08
were changed to align with commercially available products. D021 includes 6 Gaps
related to cleaning solution composition limits. The deviations from the specified
limits for halogens and sulphur have been assessed and have no significant impact
on the specified material properties for the components listed.

The net result of the changes to cleaning solution composition limits is negligible.
Issue D022 [R-22]: The requirements of CAN/CSA N285.6-08 for non destructive
examination requirements for reactor components have changed. D022 includes 16
Gaps related to non-destructive examination requirements for reactor components.
Pressure tubes, calandria tubes, feeder tubes and end fittings will be replaced as part
of the refurbishment. The design, fabrication, examination, testing and inspection of
the replacement components will be in accordance with the latest versions of modern
applicable codes and standards. As a part of refurbishment, thorough inspection of
lattice tube welded joints will be carried out and any identified deficiencies will be
repaired. Other reactor components such as LISS nozzle tubes, reactivity
mechanism Guide Tube (GT) assemblies, and Liquid Zone Control Units, are
included in the life cycle management program.
During the Darlington NGS refurbishment, all affected reactor components will be
either replaced or inspected and repaired if necessary. The net result of the changes
to non-destructive examination requirements for reactor components is negligible.
Issue D023 [R-23]: The material requirements of CAN/CSA N285.6-08 for some
reactor components have changed. D023 includes 7 Gaps related to material
requirements for reactor components. Pressure tubes, calandria tubes, feeder tubes
and end fittings will be replaced as part of the refurbishment. The design, fabrication,
examination, testing and inspection of the replacement components will be in
accordance with the latest versions of modern applicable codes and standards. As a
part of refurbishment, a thorough inspection of lattice tube welded joints will be
carried out and any identified deficiencies will be repaired. Other reactor components
Page 30 of 98
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such as LISS nozzle tubes, reactivity mechanism Guide Tube (GT) assemblies, and
Liquid Zone Control Units, are included in the life cycle management program.
The AD notes that components that will not be replaced (e.g. Reactivity Mechanism
Guide Tubes), are subject to stringent aging management and inspection
requirements. Therefore, the impact of material requirements changes included in
the current revision of N285.6-08 for other reactor components that will not be
replaced during refurbishment is negligible.
3.2.7 Review of Acceptable Deviations related to Supports for Nuclear Class Piping
and Components
Table 3.2.7 below summarizes 2 IRFs related to Supports for Nuclear Class Piping
and Components: D085 and D103.
Table 3.2.7 Summary of IRFs for Supports for Nuclear Class Piping and
Components ISR Issues

D085 ASME Section III - New Twenty seven (27) gaps were identified against the ASME Boiler and Pressure
[R-24] Design Requirements Vessel Code, Section III (July 2007). These gaps reflect new design rules for
Single Angle member linear-type supports and the energy absorbing material of
NK38-REP-00770- linear-type pipe supports designed for Class 1, 2 and 3 piping and components
0421797 R000 that were introduced in Appendices NF-II and NFIII in 1995 and 1998. These
gaps were identified because there was no assurance that NF Supports at
Darlington NGS meet the new design rules.
D103 ASME Section III - Stress Eight (8) gaps are identified against the ASME Boiler and Pressure Vessel Code,
[R-3] Limits and Stress Section III (July 2007). The gaps relate to new stress limits for Service Levels C
Intensity Limit Factors and D and new design requirements for the design of bolted and welded joints
on NF Supports that have been incorporated in the current ASME Section III
NK38-REP-00770- code since 1980.
0421810 R000
Page 31 of 98
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3.2.8 Discussion of the Acceptable Deviations related to Supports for Nuclear Class
Piping and Components
The two issues listed in Table 3.2.7 were identified in compliance reviews of ASME
Section III, Subsection NF.
Issue D085 [R-24]: The requirements of ASME Section III, Subsection NF (2007) for
design of single angle component supports have changed. D085 includes 27 Gaps
related to design of single angle component supports. The combined safety
significance category of the AD is 4. These Gaps resulted from the relocation of the
rules of Appendix XVII -2000 to Subsection NF with only minor changes. The design
of NF supports for Darlington NGS did not include the use of energy absorbing
material.
NF supports constructed to the 1980 Edition are of the same or equivalent level of
safety, as NF supports constructed to the 2007 Edition of ASME Section III. OPG
governing process ensures that DNGS NF supports continue to comply with the
ASME Section III. The net result of the changes to design rules for single angle
component supports is negligible
Issue D103 [R-3]: New stress limits for Service Level C and D and new requirements
for bolted and welded joints were added to ASME Section III, Subsection NF (2007).
D103 includes 8 Gaps related to new stress limits for Service Level C and D and new
requirements for bolted and welded joints.
NF supports constructed to the 1980 Edition are of the same or equivalent level of
safety, as NF supports constructed to the 2007 Edition of ASME Section III. OPG
governing process ensures that DNGS NF supports continue to comply with the
ASME Section III. The net result of the new stress limits for Service Level C and D
and new requirements for bolted and welded joints is negligible.
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3.2.9 Review of Acceptable Deviations related to Nuclear Class 2 and 3 Pumps
Table 3.2.9 below summarizes IRF D092 related to Nuclear Class 2 and 3 Pumps.
Table 3.2.9 Summary of IRF D092 for Nuclear Class 2 and 3 Pumps ISR Issue

D092 ASME Section III - Pump Five (5) gaps were identified against the ASME Boiler and Pressure Vessel
[R-25] Design Rules Code, Section III (July 2007), Subsections NC and ND. The gaps identify
changes to the formulas for calculating the minimum wall that apply to the pump
NK38-REP-00770- casing wall thickness in the Class 2 and Class 3 Type A pumps and changes to
0421803 R000 the minimum transition radii dimensions of drilled holes in the pump casing for
Class 2 Type N pumps.
3.2.10 Discussion of the Acceptable Deviation related to Nuclear Class 2 and Class 3
Pumps
The issue listed in Table 3.2.9 was identified in compliance reviews of ASME Section
III, ASME Section III, Subsection NC and ND.
Issue D092 [R-25]: The requirements ASME Section III, Subsections NC and ND
(2007) related to pump design have changed. D092 includes 5 Gaps related to
design of Nuclear Class 2 and Class 3 pumps. The combined safety significance
category of the AD is 4.
Class 2 and 3 pumps at DNGS, designed to the 1980 Edition are of the same or
equivalent level of safety, as pumps designed to the 2007 Edition of the ASME
Section III. OPG governing process ensures that DNGS Class 2 and class 3 pumps
continue to comply with the ASME Section III. The net result of the changes to
design rules for Nuclear Class 2 and Class 3 pumps is negligible.
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3.2.11 Review of Acceptable Deviations related to Nuclear Class 1 Valves
Table 3.2.11 below summarizes IRF D089 related to Nuclear Class 1 Valves.
Table 3.2.11 Summary of IRF D089 for Nuclear Class 1 Valves ISR Issue

D089 ASME Section III - Two (2) gaps were identified against the ASME Boiler and Pressure Vessel
[R-26] Thermal Gradients in Code, Section III (July 2007), Subsection NB. The gaps identify changes to the
Valve Design equations used to calculate thermal secondary stresses in the crotch region of
Class 1 nuclear valves.
NK38-REP-00770-
0421801 R000
3.2.12 Discussion of the Acceptable Deviation related to Nuclear Class 1 Valves
The issue listed in Table 3.2.11 was identified in compliance reviews of ASME
Section III, Subsection NB.
Issue D089 [R-26]: The requirements ASME Section III, Subsection NB (2007)
related to thermal stress analysis of Nuclear Class 1 Valves have changed. D089
includes 2 Gaps related to stress analysis of Nuclear Class 1 Valves. The combined
safety significance category of the AD is 4.
Nuclear Class 1 valves, designed to ASME Section III, 1980 edition are of the same
or equivalent level of safety, as those designed to the 2007 edition of ASME Section
III. OPG governing process ensures that DNGS Class 1 Valves continue to comply
with the ASME Section III. The net result of the changes to design rules for Nuclear
Class 1 Valves is negligible.
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3.2.13 Review of Acceptable Deviations related to Safety Related Structures
Table 3.2.13 below summarizes 3 IRFs related to Safety Related Structures: D283,
D284 and D411.
Table 3.2.13 Summary of IRFs for Safety Related Structures ISR Issues

D283 Design Requirements for Two (2) gaps were identified against CSA N291-08. The gaps identify that the
[R-27] Steel Safety-Related required slenderness ratio values for structural steel members and load factors
Structures for piping support components have been changed in CSA N291-08.
NK38-REP-00770-
0426313 R000
D284 Load Factors for Metallic One (1) gap was identified against clause 6.7.3.2 of CSA N291-08. The gap
[R-28] Embedded Parts in identifies that available documentation could not confirm that the values for load
Safety-Related Building factors specified in Table 4 of the standard were applied in the DNGS design of
Structures metallic embedded parts used to support safety-related piping or equipment.
NK38-REP-00770-
0426314 R000
D411 CNSC comments on One (1) gap was identified against clause 4.3 (d) of CSA N291-08. The clause
[R-51] NK38-REP-03680-10111 requires the owner-licensee to establish requirements for in-service monitoring,
R000 surveillance and examination of safety-related civil structures other than concrete
containments. The gap reflects that the requisite examination requirements have
not been established and submitted for CNSC approval.
3.2.14 Discussion of the Acceptable Deviations related to Safety Related Structures.
The three issues listed in Table 3.2.5 were identified in compliance reviews of CSA
N291-08.
Issue D283 [R-27]: The slenderness ratios required by CSA N291-08 for structural
design have changed. D283 includes 2 Gaps related to slenderness ratios used for
design of safety related structures. The combined safety significance category of the
AD is 4. Safety related structures at Darlington NGS were designed using different
slenderness ratios from those currently required. The original designs accounted for
the uncertainty of the loading and variability of the material properties with
established and accepted factors that would result in an acceptable margin of safety.
The existing design is considered to meet the intent of N291-08. The impact of the
changes to slenderness ratios is negligible.
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Issue D284 [R-28]: The load factors required by CSA N291-08 for metallic imbedded
parts have changed. D284 includes 1 Gap related to load factors for metallic
imbedded parts used for the design of safety related structures. The combined safety
significance category of the AD is 4. Metallic imbedded parts in safety related
structures at Darlington NGS were designed using different load factors from those
currently required.
The original designs accounted for the uncertainty of the loading and variability of the
material properties with established and accepted factors that would result in an
acceptable margin of safety. As a result, the existing design is considered to meet
the intent of N291-08. The impact of the changes load factors for metallic imbedded
parts is negligible.
Issue D411 [R-51]: CSA N291-08 requires in-service monitoring, surveillance and
examination of safety-related civil structures other than concrete containments. D411
includes 1 Gap related to in-service monitoring of safety-related civil structures. The
combined safety significance category of the AD is 4. The requisite examination
requirements have not been established and submitted for CNSC approval.
OPG has developed an Aging Management Plan for non-containment structures.

The inspection of non-containment structures will be implemented as part of the
Integrated Aging Management program, which meets the intent of the code
requirement. As CSA N291-08 is not in the current operating licence the requirement
to submit plans to the CNSC has no impact on nuclear safety. The impact of the new
requirements for in-service monitoring, surveillance and examination of safety-related
civil structures is negligible
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3.2.15 Review of Acceptable Deviations related to Nuclear Class 1 Piping
Table 3.2.15 below summarizes IRF D090 related to Nuclear Class 1 Piping.
Table 3.2.15 Summary of IRF D090 for Nuclear Class 1 Piping ISR Issue

D090 ASME Section III - Two (2) gaps were identified against clauses NB-3653.7 and NB-3654 of the
[R-29] Thermal Stress Ratchet ASME Boiler and Pressure Vessel Code, Section III (July 2007), Subsection NB.
The gaps reflect new thermal stress ratchet requirements added to the code for
NK38-REP-00770- Class I piping products. The current edition requires all load sets, for which
0421802 R000 Level A and Level B Service Limits are to be evaluated, shall satisfy the thermal
stress ratchet requirements, whereas previously only load sets that exceeded
3Sm and operated in the plastic region required this analysis.
3.2.16 Discussion of the Acceptable Deviation related to Nuclear Class 1 Piping
Section III, Subsection NB.
Issue D090 [R-29]: New requirements for thermal stress ratchet analysis were added
to ASME Section III, Subsection NB (2007). D090 includes 2 Gaps related to thermal
stress ratchet analysis of Nuclear Class 1 Piping. The combined safety significance
category of the AD is 4. Nuclear Class1 piping at Darlington NGS was designed to
the 1980 Edition of ASME Section III, Subsection NB.
Class 1 Piping at DNGS, designed to the ASME Section III, Subsection NB 1980
edition, is of the same or equivalent level of safety, as piping designed to the 2007
Edition of the ASME Section III. The OPG CODECHK program verifies compliance to
the current codes and standards. The impact of the new requirements for on the
safety of Nuclear Class 1 piping is negligible.
Page 37 of 98
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3.2.17 Review of Acceptable Deviations related to Nuclear Class 2 and Class 3

Piping
Table 3.2.17 below summarizes IRF D099 related to Nuclear Class 2 and Class 3
Piping.
Table 3.2.17 Summary of IRF D099 related to Nuclear Class 2 and Class 3 Piping

D099 ASME Section III Eight (8) gaps were identified against clauses NC-3652, NC-3653, NC 3653.1,
[R-30] Analysis of Piping NC-3654, ND-3651(a), ND-3652, ND-3653.1 and ND-3654 of the ASME Boiler
Systems and Pressure Vessel Code, Section III (July 2007), Subsections NC and ND.
The gaps reflect new requirements for calculating allowable stresses due to
NK38-REP-00770- occasional loads (both reversing and non-reversing), thermal expansion, and the
0421806 R000 effects of pressure and weight on Class 2 and 3 piping systems that have been
added o the Code since the 1980 revision, which used for the original DNGS
piping design
3.2.18 Discussion of the Acceptable Deviation related to Nuclear Class 2 and Class 3
Piping
Section III, Subsections NC and ND.
Issue D099 [R-30]: The requirements in ASME Section III, Subsections NC and ND
for analysis of Nuclear Class 2 and Class 3 piping were changed. D099 includes 1
Gap related to stress analysis of Nuclear Class 2 and Class 3 Piping. The combined
safety significance category of the AD is 4. Nuclear Class 2 and Class 3 piping at
Darlington NGS were designed to the 1980 Edition of ASME Section III, Subsections
NC and ND.
Class 2 and 3 piping systems at DNGS, designed to the 1980 Edition are of the same
or equivalent level of safety, as designed to the 2007 Edition of ASME Section III.
The OPG CODECHK program ensures that DNGS piping systems continue to comply
with the applicable codes and standards. The impact of the new requirements on the
safety of Nuclear Class 2 and Class 3 piping is negligible.
This AD is therefore excluded from further review in this aggregation assessment
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3.2.19 Review of Acceptable Deviations related to Construction Concessions and

Agreements
Table 3.2.19 below summarizes 7 IRFs related to Construction Concessions and

Agreements: D483, D485, D486, D487, D488, D489 and D490. These Acceptable
Deviations pertain to AECB/CNSC and MCCR/TSSA Concessions and agreements
that were reached in instances where DNGS was not in full compliance with CSA
Standards B51 and N285.0. Compensatory inspections imposed by the concessions
resulted in the as-built condition being compatible with the design intent.
Table 3.2.19 Summary of IRFs for Construction Concessions and Agreements

ISR Issues

D483 One (1) gap was identified against Clause 7.1.1 the CSA B51-09 standard. The
[R-52] NK38-REP-00770- gap relates to an ASME Section VIII requirement to inspect all joints and
0465064-R000 connections during the initial hydrostatic test. During the hydrostatic test of the
shield tank inspection of all tank welds was not performed due to lack of access
to tank walls behind the feeders.
D488 Two (2) gaps were identified against clause 8.1 of the CSA B51-09 standard.
[R-53] NK38-REP-00770- The gaps relate to an ASME B31.1 requirement to inspect all joints and
0465060-R000 connections for leakage during the initial hydrostatic test. During the hydrostatic
tests of Turbine and Piping system drains and Main Steam system piping certain
welds could not be inspected due to construction sequence or lack of access.
D489 Three (3) gaps were identified against clause 8 of the CSA B51-09 standard.
[R-54] The required inspection of all welded joints in piping systems revealed defects in
NK38-REP-00770- the longitudinal seam weld of NPS 8 ASTM A312 SS pipe. Defective sections in
0465059-R000 the IFB Cooling/Purification and Active Plant Drainage systems were removed
and replaced, except where the piping was embedded in concrete. One piece of
the defective piping was used in a pipe hanger in the Breathing Air system.
These pieces of SS tube were left as is even though they were considered
defective.
D485 One (1) gap was identified against clause 9.3.1 of the CSA N285.0-12 standard.
[R-55] The gap relates to the concession NK38-QRF-381310-0002, which permitted a
NK38-REP-00770- weld misalignment in the Vault Vapour Recovery system that did not meet the
0465063-R000 applicable requirement of the ASME BPVC, Section III, and Div 1.
D486 One (1) gap was identified against clause 8.1.5.1 of the CSA N285.0-12
[R-56] standard. The gap pertains to a deviation from the requirement of CSA N285.0
NK38-REP-00770-0465- to conduct impact testing of pressure retaining plate used in the DNGS Vacuum
062-R000 Building. The material purchased for the fabrication of the Vacuum Ducts was
rolled plate, which was not impact tested.
D487 Two (2) gaps were identified against clauses 11.1.2 of the CSA N285.0-12
[R-57] NK38-REP-00770- standard. The gaps relate to concessions NK38-QNF-32519-0011 and NK38-
0465061-R000 QRF-31200-001, which permitted inspection by Liquid Penetrant of butt joint
welds in the Main Moderator and Auxiliaries system and the Calandria End
shield cover plate that could not be radiographed as required by ASME BPVC,
Section III, Subsection NC.
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D490 One (1) gap was identified against clause 8.1.2 of the CSA N285.0-12 standard.
[R-58] NK38-REP-00770- The gap pertains to two concessions concerning the (non-nuclear) Hansen Quick
0465058-R000 Connective couplings. One concession allowed the use of materials that do not
conform to ASME Section III, Division 1, ND-2000 for use in Nuclear Class 2 and
3 systems, provided they are limited to use in systems with pressures 200 psig
and temperatures 200F. The other concession permitted the use of Type 303
stainless steel instead of Type 316 stainless steel in the body of the coupling,
provided the Type 303 material is not welded.
3.2.20 Discussion of the Acceptable Deviations related to Construction Concessions

and Agreements
As noted in Section 3.2.19, the seven issues listed in Table 3.2.19 pertain to
AECB/CNSC and MCCR/TSSA Concessions and agreements that were reached in
instances where DNGS was not in full compliance with CSA Standards B51 and
N285.0.
Issue D483 [R-52]: ASME Section VIII requires inspection of all joints and
connections during the initial hydrostatic test. D483 includes one Gap related to
inspection during hydrostatic testing. During the hydrostatic test of the shield tank,
lack of access to tank walls behind the feeders prevented inspection of all tank welds.
The combined safety significance category of the AD is 4. Obstructed welds were
inspected to the extent possible. A MCCR/AECB concession was granted to allow
inspection of only the highest stressed welds at the bottom corners of the end walls.
The alternate inspection demonstrated the pressure boundaries of the shield tank had
been properly constructed. No failures in the shield tank pressure boundary have
been reported. The impact of the concession on reactor safety is negligible.
Issue D485 [R-55]: Concession NK38-QRF-381310-0002 permitted a weld

misalignment in the Vault Vapour Recovery system that did not meet the applicable
requirement of the ASME BPVC, Section III, Div 1. D485 includes one Gap related to
weld misalignment. The combined safety significance category of the AD is 4. The
inside diameter of the weld was not accessible for rework, but the integrity of the weld
was demonstrated by successfully performing a pneumatic pressure test. The design
and operating pressures for this system are low (100 kPa(g)/-53 kPa(g) and 3.1
kPa(g) respectively.)
Page 40 of 98
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Integrity of the subject welds was demonstrated by alternate inspection methods. No

leaks have been reported since. The impact of the concession on reactor safety is
negligible.
This AD is therefore excluded from further review in this aggregation assessment
Issue D486 [R-56]: CSA N285.0 required impact testing of pressure retaining plate
used in the DNGS Vacuum Building. The material purchased for the fabrication of
the Vacuum Ducts was rolled plate, which was not impact tested. D486 includes one
Gap related to impact testing. The combined safety significance category of the AD
is 4. The intent of the code requirements is to enhance the fracture toughness of the
ferritic steel plate.
An analysis of the application using fracture mechanics and conservative material

data concluded that brittle fracture was not a concern in this case. Adequate fracture
toughness of the subject material for the design conditions was demonstrated by
analysis. The impact of the concession on reactor safety is negligible.
Issue D487 [R-57]: Concessions NK38-QNF-32519-0011 and NK38-QRF-31200-

001 permitted inspection by Liquid Penetrant of butt joint welds in the Main Moderator
and Auxiliaries system and the Calandria End shield cover plate that could not be
radiographed as required by ASME BPVC, Section III, Subsection NC. D487 includes
two Gaps related to Liquid Penetrant of butt joint welds that could not be
radiographed. The combined safety significance category of the AD is 4.
The root and cap of the welded joint in the Main Moderator and Auxiliaries system
that was located inside a penetration was inspected using Liquid Penetrant. This joint
was made under bench conditions, which typically produce higher quality welds than
field welds. The line outside the EP was radiographed. Each pass of the subject butt
welds in the Calandria End shield cover plate was inspected using Liquid Penetrant,
in lieu of RT.
Welds integrity was successfully demonstrated by a combination of Liquid Penetrant

inspection and pressure testing. The impact of the concession on reactor safety is
negligible.
Issue D488 [R-53]: ASME B31.1 requires inspection of all joints and connections
during the initial hydrostatic test. During the hydrostatic tests of Turbine and Piping
system drains and Main Steam system piping certain welds could not be inspected
due to construction sequence or lack of access. D488 includes two Gaps related to
Page 41 of 98
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inspection during hydrostatic testing. The combined safety significance category of

the AD is 4. MCCR/AECB concessions were granted to allow inspection of the
affected by alternate methods to ascertain their integrity.
The alternate inspection demonstrated the pressure boundaries of the piping subject
piping systems had been properly constructed. No failures of those welds have
occurred since initial commissioning. The impact of the concession on reactor safety
is negligible.
Issue D489 [R-54]: CSA B51-09 requires inspection of all welded joints The required
inspection revealed defects in the longitudinal seam weld of NPS 8 ASTM A312 SS
pipe. Where possible, defective sections in the IFB Cooling/Purification and Active
Plant Drainage systems were removed and replaced. , MCCR/AECB concessions
were granted to allow piping embedded in concrete and one piece of the defective
piping was used in a pipe hanger to be left as is. D489 includes three Gaps related
to defects in the longitudinal seam welds. The combined safety significance category
of the AD is 4.
The internal pressure in embedded piping sections is negligible; the pipe is

completely supported by the surrounding concrete. The wall of pipe was assessed to
have adequate safety margin to withstand seismic events. No failures have been
reported in the embedded sections of SS tube parts and the pipe hanger that
included a piece of the defective SS piping. The impact of the concession on reactor
safety is negligible.
This AD is therefore excluded from further review in this the aggregation assessment.
Issue D490 [R-58]: This Issue is related to (non-nuclear) Hansen Quick Connective
couplings. A concession allowed the use of materials that do not conform to ASME
Section III, Division 1, ND-2000 for use in Nuclear Class 2 and 3 systems, provided
they are limited to use in systems with pressures 200 psig and temperatures
200F. A second concession permitted the use of Type 303 stainless steel instead
of Type 316 stainless steel in the body of the coupling, provided the Type 303
material is not welded. D490 includes two Gaps related to Hansen Quick Connective
couplings. The combined safety significance category of the AD is 4.
The supplier of the couplings has demonstrated good quality assurance practices in
material procurement, product modification and product testing. Integrity of the code
deviant materials included in the subject couplings has been demonstrated in service.
Failures with these couplings documented in SCRs have been due to device damage
or aging of elastomeric seals, and are not connected to the use of non-ASME
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materials or Type 303 stainless steel. The impact of the concession on reactor
3.2.21 Review of Acceptable Deviations related to Class 6 Steel Valves
Table 3.2.21 below summarizes IRF D340 related to Class 6 Steel Valves.
Table 3.2.21 Summary of IRF D340 for Class 6 Steel Valves ISR Issue

D340 NK38-03680-10134 R000 Two (2) gaps were identified against clause 107.1(A) of the ASME B31.1
[R-82] standard. These gaps relate to new requirements for pressure testing of steel
valves that were added to ASME B31.1
3.2.22 Discussion of the Acceptable Deviation related to Class 6 Steel Valves
The issue listed in Table 3.2.21 was identified in compliance reviews of ASME B31.1.
Issue D340 [R-82]: New requirements for pressure testing of steel valves relief
devices were added to ASME B31.1. D340 includes 2 Gaps related to valve pressure
testing. The combined safety significance category of the AD is 4. These
requirements did not exist in the 1980 Edition of the ASME B31.1 Code used for
DNGS construction.
Steel valves used in DNGS Class 6 piping either meet the new testing requirements
or had other processes in place equivalent to the current requirements of the 2012
edition of ASME B31.1. The changes in the above-mentioned Code requirements do
not impact the safe operation of Class 6 piping constructed to the 1980 Edition of the
ASME B31.1 Code.
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3.2.23 Review of Acceptable Deviations related to Class 6 Pressure Relief Devices
Table 3.2.23 below summarizes IRF D341 related to Class 6 Pressure Relief Devices.
Table 3.2.23 Summary of IRF D341 for Class 6 Pressure Relief Devices IRF
Issue

D341 NK38-03680-10134 R000 One (1) gap was identified against clause 107.8.3 of the ASME B31.1 standard.
[R-83] The gap relates to new requirements for pressure relief devices that were added
to ASME B31.1
3.2.24 Discussion of the Acceptable Deviation related to Class 6 Pressure Relief

Devices
The issue listed in Table 3.2.23 was identified in compliance reviews of ASME B31.1.
Issue D341 [R-83]: New requirements for pressure relief devices were added to
ASME B31.1 by references to the ASME B&PV Code, Section VIII, Division 1. D341
includes 1 Gap related to requirements for Class 6 pressure relief devices. The
combined safety significance category of the AD is 4. These references did not exist
in the 1980 Edition of the ASME B31.1 Code used for DNGS construction.
Pressure relief devices used in DNGS Class 6 piping either meet the new
requirements or had other processes in place equivalent to the current requirements
of the 2012 edition of ASME B31.1. The changes in the above-mentioned Code
requirements do not impact the safe operation of Class 6 piping constructed to the
1980 Edition of the ASME B31.1 Code.
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3.2.25 Review of Acceptable Deviations related to Pressure Boundary Program

Governance
Table 3.2.25 below summarizes IRFs related to Pressure Boundary Program

Governance.
Table 3.2.25 Summary of IRFs for Pressure Boundary Program Governance
IRF Issues

D614 DNGS Governance The OPG Pressure Boundary Program Manual does not make reference to CSA
Documents and the PB N285.0-12 and Update 1. The previous edition of the code is referenced.
[R-92]
Program Manual
Reference Previous
Edition of Code
D615 OPG Pressure Boundary The current Darlington Application for License Renewal states in part that for the
Document Darlington Refurbishment Project, OPG has to comply with CSA N285.0-08 and
[R-93] Update 2 (includes Update No.1 and Annex M). The Code Effective Date of the
currently implemented OPG Pressure Boundary Program Manual is CSA
N285.0-08 with Update 2, Annex K, Annex M. Darlington Application for License
Renewal also requires that as part of the Transition Plan for CSA Standard
N285.0-12 OPG will develop a PB Program document based on Annex N of CSA
N285.0-12 and Update No. 1.
The current OPG Pressure Boundary Program and Pressure Boundary Program
Manual do not conform to the format and Table N.1- Index to pressure boundary
program elements.
3.2.26 Discussion of the Acceptable Deviation related to Pressure Boundary Program

Governance
The issues listed in Table 3.2.25 were identified in compliance reviews of CSA
Standard N285.0.
Issue D614 [R-92]: The OPG Pressure Boundary (PB) Program Manual does not
make reference to CSA N285.0-12 and Update 1. The previous edition of the code is
referenced. The safety significance category of the AD is 4.
The current Darlington Operating Licence makes reference to CSA N285.0-08, which
is consistent with PB program governance. Per normal practice, when the new
revision of the code is included in the PROL, the PB program governance will be
updated to reflect the new revision requirements. Therefore, there is currently no
impact associated with this gap. This AD is therefore excluded from further review in
the aggregate assessment.
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Issue D615 [R-93]: The current Darlington Application for License Renewal states in
part, that for the Darlington Refurbishment Project, OPG has to comply with CSA
N285.0-08 and Update 2 (includes Update No.1 and Annex M). The Code Effective
Date of the currently implemented OPG Pressure Boundary Program Manual is CSA
N285.0-08 with Update 2, Annex K and Annex M. Darlington Application for License
Renewal also requires that as part of the transition plan for CSA Standard N285.0-12,
OPG will develop a PB Program document based on Annex N of CSA N285.0-12 and
Update No. 1.
The current OPG Pressure Boundary Program and Pressure Boundary Program
Manual do not conform to the format and Table N.1- Index to pressure boundary
program elements. The safety significance category of the AD is 4.
The current Darlington Operating Licence makes reference to CSA N285.0-08, which
is consistent with PB program governance. Per normal practice, when the new
revision of the code is included in the PROL, the PB program governance will be
updated to reflect the new revision requirements, including format requirements.
Therefore, there is currently no impact associated with this gap.
This AD is therefore excluded from further review in the aggregate assessment.
3.2.27 Review of Pressure Boundary ADs collectively for aggregate effects
As indicated in Sections 3.2.2 3.2.26 above, the following ADs have been
eliminated from further aggregate assessment:
Periodic Inspection Programs (8 ADs): D151, D364, D365, D366, D368, D369, D417,
D418, D419 and D564
ASME Section VIII Pressure Vessels (2 ADs): D001 and D003
Reactor Components (2 ADs): D021 and D022
Supports for Nuclear Class Piping and Components (2 ADs): D085 and D103
Nuclear Class 2 and 3 Pumps (1 AD): D092
Nuclear Class 1 Valves (1 AD): D089
Safety Related Structures (3 ADs): D283, D284 and D411
Nuclear Class 1 Piping (1 AD): D090
Nuclear Class 2 and Class 3 Piping (1 AD): D099
Construction Concessions and Agreements (7 ADs): D483, D485, D486, D487,
D488, D489 and D490
Class 6 Steel Valves (1 AD): D340
Class 6 Pressure Relief Devices (1 AD): D341
Pressure Boundary Program Governance (2 ADs): D614 and D615
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A total of 34 pressure boundary related ADs have thus been excluded from further
review in this aggregation assessment. The following assessment documents the
aggregate assessment as outlined in section 2.2 for the remaining 9 ADs.
Table 3.2.27 below lists the attributes for each of the remaining 9 ADs in the columns
adjacent to the AD column. The column on the far right identifies the Associated
ADs, those that have potential aggregate affect with each AD.
The table shows that there is no potential aggregate affect for the following ADs
because each of these ADs is applicable to unique components:
D160
D362
D363
D023
The table shows the following combinations with potential for aggregate affects:
D360 and D361.
D367, D392 and D393
Table 3.2.27 Aggregate assessment of combinations of the nine Pressure

Boundary ADs
Attribute
D160. [R-6] Supports for Containment Darlington NGS None
Inspection of Containment boundary PIP
supports. CSA- Boundary components
N285.5-M90 Components reliant on NF
supports
D360. [R-7] Welds Nuclear Class Darlington NGS D361
Weld Inspection. Piping PIP
CSA N285.4-05.
D361. [R-8] Weld Welds Nuclear Class Darlington NGS D360
Inspection CSA Piping PIP
N285.4-05.
D362. [R-9] Component Structures and Darlington NGS None
Inspection of supports, equipment reliant PIP
supports. CSA other than on NF supports,
N285.4-05. containment other than
boundary containment
boundary
D363. [R-10] Mechanical Nuclear Class Darlington NGS None
Inspection of Couplings Piping PIP
mechanical
couplings. CSA
N285.4-05.
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Attribute
D367. [R-14] Pressure Reactor Darlington NGS D392, D393
Inspection of Tubes PIP
pressure tubes.
CAN/CSA
N285.4-05
Measurements of Tubes PIP
pressure tube to
calandria tube
gap. CAN/CSA
N285.4-05
Recording Tubes PIP
criteria for
laminar flaws.
CAN/CSA
N285.4-05
D023. [R-23] Reactivity Reactor Reactor None
Material mechanism Components &
requirements for guide control Structures Life
reactor tubes Cycle
components. Management Plan
CAN/CSA
N285.6-08
D360 [R-7] and D361 [R-8] are both related to inspection of welds in nuclear class
piping. D360 identifies that access limitations prevent the full inspection of some
welds. D361 identifies that the welds with highest fatigue usage factor or stress ratio
may not be inspected because they are in areas where radiation fields are too high.
Both of these Issues are addressed in the Darlington NGS Periodic Inspection
Program (PIP) Plans. The PIP Plans consider aggregate effects and ensure the
acceptability of the inspection program as a whole. Thus, there is no potential for
D360 and D361 to interact in such a way as to have a negative impact on the
Darlington NGS PIP. Hence the aggregate effect is negligible and therefore there is
no impact on public safety.
D367 [R-14], D392 [R-17] and D393 [R-18] are all related to inspection of fuel
channel pressure tubes. D367 identifies that the equipment used at Darlington NGS
cannot scan 100% of the pressure tube. D392 identifies that Darlington NGS uses
as-installed spacer locations to determine pressure tube to calandria tube gap
because identification of spacer locations by in-service inspection methods is
unreliable. D393 identifies that the ability of inspection procedures to detect of
laminar flaws in fuel channel pressure tubes has not been confirmed. All three of
these Issues are addressed in the Darlington NGS Periodic Inspection Program (PIP)
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Plans. The PIP Plans consider aggregate effects and ensure the acceptability of the
inspection program as a whole. Thus, there is no potential for D369, D392, and D393
to interact in such a way as to have a negative impact on the Darlington NGS PIPs
capability to detect degradation for fuel channel pressure tubes. Hence the aggregate
effect is negligible and therefore there is no impact on public safety.
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3.3 Accident Management
As indicated in Section 2.2, fifty-one (51) Acceptable Deviations (ADs) related to

Accident Management are reviewed here for aggregate effects.
Eighteen (18) of the ADs pertain to the Safety area and are reviewed in Section 3.3.1.
The remaining thirty-three (33) ADs pertain to the Fire Protection area and are
reviewed in Section 3.3.2. The issues in each category are reviewed for aggregate
effects. In Section 3.3.3, all the Accident Management related ADs are reviewed for
aggregate effects, that is, the results of both categories are examined for
commonality.
To establish the AD status of each ISR issue, OPG carried out a comprehensive
review that is documented in an Issue Resolution Form (IRF). The IRF for each ISR
issue in Safety area is summarized in Table 3.3.1.1, and OPGs actions/clarifications
to address the gaps against modern codes and standards are identified. The ADs
that were not closed in the IRFs are reviewed collectively for aggregate effects in
Section 3.3.1.3. Likewise, Table 3.3.2.1 summarizes the IRFs in the Fire Protection
area, and the unclosed ADs are reviewed in Section 3.3.2.3 for aggregate effects.
Not all Fire Protection ADs are applicable to the Accident Management barrier. Only
those which could impact the effectiveness in managing an accident involving a fire
having a direct impact on nuclear safety are addressed. The criteria used consists of
selecting ADs that deal with:
Fire detection
Communication and Mobilization
Access to critical locations
A System Important to Safety (SIS)
Some aspects of fire suppression capabilities (those judged to have an impact
on critical nuclear safety functions following a fire). For example, D479 about
the means of disconnecting electrical power to fire pumps is not included,
since it can have no measurable impact on nuclear safety.
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3.3.1 Review of 18 Acceptable Deviations in Safety Area
3.3.1.1 IRFs that established the AD status of 18 Safety ISR issues
Table 3.3.1.1 summarizes the IRFs on the following 18 issues: D040 [R-31], D061 [R-
32], D062 [R-33], D064 [R-2], D067 [R-34], D261 [R-36], D270 [R-37], D277 [R-37],
D278 [R-39], D281 [R-40], D286 [R-41], D289 [R-42], D290 [R-43], D291 [R-44],
D293 [R-45], D327 [R-94], D329 [R-95] and D608 [R-96]. These address 84 gaps
against clauses in modern codes and standards. Three of these ADs are duplicates
(D327, D329 and D608 addressed by D062, D061 and D040 respectively). These
three ADs address the same code review gaps as the ADs shown, but arose from a
different code or code version. Therefore, since these are already addressed via the
associated AD, these were excluded from the assessment. The IRFs for 9 issues
indicate that OPG carried out actions and/or provided clarifications that address the
gaps in order to consider them closed, so there is no need to review the following
nine (9) ADs: D040 [R-31], D062 [R-33]; D064 [R-2], D067 [R-34], D270 [R-37], D277
[R-37], D278 [R-39], D281 [R-40] and D290 [R-43] because they have no impact on
accident management.
The remaining six (6) ADs, D061 [R-32], D261 [R-36], D286 [R-41], D289 [R-42],
D291 [R-44] and D293 [R-45], are Human Factors (HF) related and are acceptable
deviations from the following codes and standards: IAEA NS-R-1, CNSC RD-337,
CAN/CSA N290.6-M82 and USNRC NUREG 0700. These are discussed in Section
3.3.1.2 and reviewed collectively for aggregate effects in Section 3.3.1.3.
Table 3.3.1.1. Summary of IRFs for 18 Safety ISR issues

D040 Human Factors Design Five (5) gaps from a review of IAEA NS-R-1 and two gaps from a review of
[R-31] NK38-REP-00770- CNSC RD-337 on lack of written Human Factors Engineering (HFE)
0421330 R001 requirements during the DNGS design, emphasizing the main control room
(MCR), secondary control area (SCA) panels --- These are all considered
closed. There is much evidence that the original designers considered the man-
machine interface. Subsequent initiatives have addressed human factors in
design. The safety systems were designed to comply with Regulatory
Documents that required clear and unambiguous indication to support operator
action within 15 minutes. This required HFE work. The probabilistic risk
assessment required human reliability analysis and implementation of measures
to reduce and mitigate human errors. Ergonomic issues are addressed through
the N-PROG-HR-0004 program. DNGS is largely compliant with US NRC
NUREG 0700 standard on HFE.
NS-R-1 Clause 5.48 on operator friendly design to limit human error. The gap is
the lack of evidence of the DNGS HFE program during design and construction.
NS-R-1 Clause 5.49 on lack of HF and ergonomic standards, and on deficiencies
in MCR annunciation.
NS-R-1 Clause 5.50 on lack of documents about functions between operators
and automatic systems for human factors and the human-machine interface
Page 51 of 98
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(HMI).
NS-R-1 Clause 5.51 on designs of the MCR and SCA not being based on current
HMI standards and expectations, to be compatible with necessary decision and
action times.
NS-R-1 Clause 5.52 on lack of HF verification and validation during stages of the
design, for all operator actions
RD-337 Clause 7.21 on lack of a HFE program plan to identify, reduce and
mitigate human error.
RD-337 Clause 8.10.1 on lack of standards for layout of MCR controls, displays
and general environment to be user friendly, to support operator actions.
D061 Special Safety System One (1) gap from a review CAN/CSA N290.6-M82 on CANDU monitoring and
[R-32] Design display of status in the event of an accident --- Since ECI and containment each
NK38-REP-00770- have three redundant, independent channels that are reliable and protected, it is
0421407 R000 very likely that at least two of the three information chains will provide inputs to
the Critical Safety Parameter Monitoring instrumentation even when ECI or
containment is assumed to be unavailable to act.
Clause 5.2.2 requires at least one redundant information chain to be provided,
outside of assumed unavailable safety system. There is no evidence that DNGS
complies.
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D062 Post-Accident Monitoring Four (4) gaps from a review of CAN/CSA N290.6-M82 on CANDU monitoring
[R-33] Availability and display of status in the event of an accident --- The availability of PAMS is
NK38-REP-00770- acceptable. It is assured by: 1) reliability of safety systems; 2) redundancy and
0421408 R000 independence of PAM signals in process systems; 3) in systems important to
safety, reliability of PAM signals is governed by N-PROG-RA-0016; 4) in other
systems, PAM signals are less significant, but monitored and tested; 5)
surveillance, including frequent panel checks of critical safety parameters related
to PAM, forms the minimum set of PAM activities; 6) N290.6-M82 was
considered in PAMS design.
Clause 5.3.1 requires indication of each plant characteristic to be available 99%
of the time. No documentation to confirm PAM System availability.
Clause 5.3.2 requires a design target for PAMS availability of 99.9%. No design
availability assessments were found.
Clause 5.3.3 requires the availability of PAM for the most demanding DBE.
Mission time requirements are identified for some Group-1 and -2 PAM
instrumentation, but no availability determinations are found.
Clause 7.2.3 lists information to be included in the PAMS design manual. The
design is generally compliant, but this information is not in the design manual.
D064 Seismic Monitoring Two (2) gaps from a review of CAN/CSA N289.5-M91 on CANDU seismic
[R-2] System Testing instrumentation requirements --- A SCR and change request were completed
NK38-REP-00770- to close these gaps.
0421410 R001 Clause 6.2.2 requires that all components of the seismic monitoring system to be
subject to on-power testing. No scheduled testing and surveillance PMID
Clause 6.2.5 requires routine checks and recalibration and annual operation on
standby power for at least 25 minutes.
D067 Provisions for Post- Two (2) gaps from a review of IAEA safety guide NS-G-1.13 (2005) on radiation
[R-34] Accident Sampling protection aspects of NPP design and one gap from CNSC guide G-225 (2001)
NK38-REP-00770- on emergency planning. (Liquid effluent monitoring and sampling in the
0421412 R001 environment are dealt with in issue D209.) The DNGS ECIS and post-accident
radiation monitoring system (PARMS) have the required capability for post-
accident sampling; however, monitoring capability for iodine does not provide the
design accuracy. OPG response to the CNSC resulted in acceptance of the
iodine accuracy. Action item was closed; D067 is acceptable.
NS-G-1.13 Clause 10.8 requirements and means to sample gases and liquids
after an accident and provisions for shielding the employees.
NS-G-1.13 Clause 12.9 means of taking representative samples of the gas and
water within containment for lab measurements.
G-255 Clause 5.8 expects the emergency plan to describe the services,
equipment, supplies and facilities to be available to cope with emergencies.
D261 Human Factors ECI & Thirty four (34) gaps from a Human Factors Engineering review of DNGSs
[R-36] ANN System Display Emergency Coolant Injection (ECI) and Annunciation systems of the Common
NK38-REP-00770- Secondary Control Area, the Unit Secondary Control Area, the MCR interfaces
0425838 R001 and field interfaces (for ECI only) against the requirements of the US NRC
NUREG 0700 HFE standard. Of these 34 gaps, 13 are considered closed.
DNGS is largely compliant with NUREG 0700 requirements. The gaps pertain to
design enhancements, the lack of which will not likely impair the capability of the
highly trained and experienced operating staff to manage accidents. An operator
survey and SCR reviews did not identify any significant events related to these
gaps. OPG employs rigorous error reduction techniques to prevent the type of
Human Errors relevant to this issue. All plant modifications comply with best
practice HFE requirements.
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D270 Analysis and Validation of Four (4) gaps from a review of CNSC G-323 on ensuring the presence of
[R-37] Minimum Staff sufficiently qualified staff minimum staff complement --- OPGs governance did
Complement not have requirements to perform systematic analysis to determine minimum
Requirement shift complement; validation of the minimum complement does not consider the
NK38-REP-00770- inputs identified in G-323. The CNSC has accepted OPGs documents on
0425844 R001 minimum shift complement. Because the minimum shift complement is
adequate, this AD does not affect accident management. OPG raised
Initiative Plan MA-08 to close these gaps. Action Item AR# 28112704 was
completed.
Clause 5.1.1 expects the licensee to determine the minimum staff complement
through a systematic analysis. OPG governance has no explicit requirement for
this analysis.
Clause 5.1.2 requires validating minimum staff requirement under all operating
states, design basis accidents (DBAs) and/or emergencies. OPGs HF validation
planning and methods manual does not provide details of the inputs needed.
Clause 5.1.2.1 identifies validation scenarios that should include the most
resource-intensive events. OPGs manual does not provide details for validation.
Clause 5.1.2.2 specifies that the validation exercises should demonstrate that
relevant procedures can be implemented in a timely manner. OPGs manual
does not provide details of the inputs required for validation.
D277 Primary Heat Transport One (1) gap from a review of RD-337 regarding the HTS coolant inventory
[R-37] Coolant Supply for Multi- required for multi-unit events --- OPG implemented a procedure change to
Unit Shutdown close this gap.
NK38-REP-00770- Clause 8.2.2 requires the design to provide control of coolant inventory and
0426307 R000 pressure, when taking volumetric changes and leakage into account.
D278 Turbine Orientation One (1) gap from a review of RD-337 on turbine orientation and over-speed
[R-39] NK38-REP-00770- protection --- DNGS does not comply with the orientation requirement; however,
0426308 R001 the postulated impact would not impair the capability of these SCCs. OPG
clarified that the SCCs are protected from turbine missiles.
Clause 8.3.3 requires protection against turbine disk failure (missile ejection) and
turbine orientation that would direct potential missiles away from SCCs.
D281 Seismic Qualification Four (4) gaps from a review of CAN/CSA N289.1-2008 on seismic design
[R-40] Post-Event Response qualification on CANDU NPPs --- OPG procedures require reactors to be placed
and Actions and maintained in a Guaranteed Shutdown State, if required, following a seismic
NK38-REP-00770- event. The critical functions of cool, control and contain are established. OPG
0426311 R000 clarified that this issue is applicable only for post-seismic operation.
Clause 6.5.6.1 requires preparation of a report after an earthquake close to or
exceeding the design basis to assess damage to SCCs. OPG has no procedure.
Clause 6.5.6.2.2 requires an inspection of seismically-qualified SSCs for
evidence of overstressing and analysis to quantify the effects of the motion on
SQed SCCs. OPG requires that the damage be identified; however, there is no
requirement for analysis to quantify the effects.
Clause 6.5.6.4 requires comparison of the measured seismic data with the
design floor response spectra and plant shut down for inspection if the measured
spectra exceed the design spectra. OPGs Abnormal Incidents Manual provides
the criteria to shut down if required, but does not specify the need to compare
measured spectra with the design spectra.
Clause 6.5.7.3 specifies no plant restart without ensuring the design stresses of
SQ SCCs did not exceed Service Load Level C as specified in ASME BPVC Sec
III. A detailed inspection approved by a qualified engineer is required, to assure
the life expectancies of the SQ SCCs are adequate with adequate margin for
further operation. No evidence was found in OPG documents requiring a
detailed inspection report on the remaining life expectancy of SQ SCCs.
It is noted that the definition of DBE has been changed. The probability is now
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10-4 per year (greater acceleration) instead of 10-3 per year, which was used in
the design of DNGS.
D286 Human Factors One (1) gap from a HF operational experience review against US NRC NUREG
[R-41] Implementation 0700, which included surveys of staff and a review of the SCR database
NK38-REP-00770- regarding the ECI and ANN systems.
0426316 R001 The surveys and review identified a variety of HFE-related deficiencies of low
risk significance. Many of them have been resolved, completed and closed.
This issue demonstrated that improvements to operational performance were
warranted. This activity demonstrated an adequate safety culture. The DNGS
design is largely compliant with the requirements of the NUREG 0700 HFE
standard.
OPG prevents human errors related to this issue by employing rigorous error
reduction techniques, in compliance with N-PROG-AS-0002.
D289 Human Factors ECI & Nine (9) gaps from a HFE review against US NRC NUREG 0700 point out
[R-42] ANN System Labels differences in the convention used by OPG regarding labels that identify
NK38-REP-00770- components. They pertain to label position, cleaning, tag position, grouping, and
0426319 R001 redundant labels for cabinet doors, fuse labels and annunciators. These gaps
are of low risk significance; one is closed. DNGS largely complies with NUREG.
D290 Human Factors ECI One (1) gap from a HFE review against US NRC NUREG 0700 on ECI, including
[R-43] System Dynamic the common SCA and the unit SCA, the MCR interfaces and the field interfaces,
Indication related to dynamic equipment status indication. The gap can be considered
NK38-REP-00770- closed because valve status is provided above the MCR hand switches, by
0426320 R001 indicating lights, which originate from limit switches on the ECI valves. DNGS is
largely compliant with NUREG 0700.
Clause 1.1-5 requires that changes in the display should have a one-to-one
relation with the plant state; however, the CRT display for the ECIS doesnt
indicate valve status for injection, isolation, and inter-tie valves (20 MVs).
D291 Human Factors ECI Four (4) gaps from a HFE review against US NRC NUREG 0700, regarding the
[R-44] System Ergonomics ECI and annunciation systems, identified that the consoles are not in precise
NK38-REP-00770- compliance. Based upon operator survey and SCR reviews, there is no impact
0426321 R001 on operational performance and safety culture. DNGS is largely compliant with
the NUREG HFE standard.
Clause 3.2.1-9: the keyboard should have an adjustable slope; however, it is
fixed into the DNGS MCR panel.
Clause 3.2.1-10: the user should be able to reposition the keyboard; however, it
is mounted into the DNGS MCR panel.
Clause 11.1.1-2 specifies minimum and maximum elevations of the controls on
the console. In DNGS the upper controls are located 8 inches above the
maximum elevation.
Clause 11.1.1-6 specifies 45 degrees as the minimum angle between the line of
sight and the display face in the MCR. Some DNGS annunciation windows have
a 41 degree angle.
D293 Human Factors ECI & Eight (8) gaps from a HFE review against US NRC NUREG 0700, regarding the
[R-45] ANN System Controls ECI and annunciation systems. They are of low risk significance because there
NK38-REP-00770- are adequate barriers in place to reduce the likelihood of error; DNGS is largely
0426323 R001 compliant with NUREG 0700.
Annunciation System Gaps:
Clause 4.3.5-2 requires a confirmation if a significant alarm system configuration
change is to be made by user selection. In DNGS, a selector switch is used to
suppress minor alarms with no confirmation required.
Clause 4.3.7-4 there should be a different set of controls for alarm tiles and for
video alarm displays. DNGS has only one set of controls for both.
ECI System Gaps:
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Clause 2.1-72 the user should not be required to enter data separators or
delimiters (dashes and slashes); however, DNGS users enter data separators.
Clause 3.1.1-4 design should prevent accidental manipulation of control and
input devices; however, the test and activation buttons for DNGS ECI are
identical and located close to each other.
Clause 3.1.2-7 controls should be located so as to be easily related functions
and functional groupings. DNGS PHT headers on the ECI panels are in the
reverse order.
Clause 3.2.1-2 keyboards to be equipped with a numeric keypad, which is not
the case in DNGS.
Clause 3.2.1-5 requires the orientation of the cursor control keys to be
compatible with the cursor motion they produce. In DNGS, these keys are
arranged in a row (no intuitive layout).
Clause 3.3.2.3-5 requires a switch be turned to the OFF or Safe position before
the user can remove the key from the lock. In DNGS, the ECI blocking switch
key can be removed with the switch in the blocked position.
D327 Post Accident Monitoring One (1) gap from a review of CSA N290.6-2009 on CANDU monitoring and
Availability display of status in the event of an accident --- This issue covers availability
Documentation requirements, including calculations and documentation for the PAMS.
Requirements on availability of the PAMS are not included in OPG
NK38-REP-00770- documentation as required by CSA N290.6-M82.
0490443
The justification for this gap is that the availability of PAMS is acceptable. It is
assured by: 1) reliability of safety systems; 2) redundancy and independence of
PAM signals in process systems; 3) in systems important to safety, reliability of
PAM signals is governed by N-PROG-RA-0016; 4) in other systems, PAM
signals are less significant, but monitored and tested; 5) surveillance, including
frequent panel checks of critical safety parameters related to PAM, forms the
minimum set of PAM activities; 6) N290.6-M82 was considered in PAMS design.
This AD is a duplicate of D062, which addressed an earlier code version.
D329 Special Safety System One (1) gap from a review of CSA N290.6-2009 on CANDU monitoring and
Design display of status in the event of an accident --- Clause 6.3.2 requires at least one
redundant information chain to be provided, outside of assumed unavailable
NK38-REP-00770- safety system. There is no evidence that DNGS complies.
0490445 The justification for the acceptability of this gap is that the unavailability of a
special safety system does not imply that the monitoring equipment in that SSS
is also unavailable. Also, considering the redundancy provided in the design, the
existing post-accident monitoring capability is sufficient. This AD is a duplicate of
D061
D608 Human Factors Design One (1) gap from a review of CSA N290.0 on General Requirements for CANDU
NK38-REP-00770- Safety Systems, clause 4.14.10 dealing with human factors design. This gap is
0488753 addressed in D040 on human factors related gaps against IAEA NS-R-1.
3.3.1.2 Discussion of six HF-related Safety ADs

As noted in Section 3.3.1.1, the remaining six ADs: D061 [R-32], D261 [R-36], D286
[R-41], D289 [R-42], D291 [R-44] and D293 [R-45] are HF related and acceptable
deviations from one or more of the following modern codes and standards: IAEA NS-
R-1, CNSC RD-337, CAN/CSA N290.6-M82 and USNRC NUREG 0700.
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Issue D061 [R-32] considers one gap against the N290.6 post-accident monitoring
(PAM) requirement to provide at least one redundant information chain outside of the
assumed unavailability of a safety system. Each DNGS safety system provides three
redundant, independent, safety-grade and protected information chains. Some PAM
parameter signals are obtained exclusively from the ECI system or the containment
system. It is very likely that at least two of the three information chains would be
available in a postulated accident, even though some scenarios assume that ECI or
containment would be unavailable to act.
Issue D261 [R-36] covers 34 gaps from a HFE review of the ECIS and annunciation
(ANN) system displays against NUREG 0700 requirements. DNGS displays are
largely compliant with NUREG 0700 requirements; 13 of the 34 gaps can be
considered closed. These gaps pertain to design enhancements whose absence
does not significantly impair the ability of the highly trained and experienced DNGS
operators from recognizing and managing accidents.
Issue D286 [R-41] assesses one gap from a HF operational experience review
against NUREG 0700, which included surveys of staff and a review of the SCR
database regarding the ECI and ANN systems. The surveys and review identified a
variety of HFE-related deficiencies of low risk significance, and many of them have
been resolved, completed and closed. The DNGS design is largely compliant with
NUREG 0700 requirements. This activity on low-level events to improve operational
performance demonstrates a satisfactory safety culture.
Issue D289 [R-42] is for 9 gaps from a HFE review against NUREG 0700
requirements on the subject of labels (position, cleaning, tag position, grouping,
redundant labels for cabinet doors, fuse labels, annunciator labels). The DNGS
design is largely compliant with NUREG 0700 requirements; one gap is considered
closed.
Issue D291 [R-44] regarding 4 gaps from a HFE review against NUREG 0700
requirements has the following minor control console variances for ECI and ANN
systems. The keyboard is fixed into the DNGS MCR panel. It does not have an
adjustable slope and cannot be repositioned. Several controls are 8 inches above
the maximum elevation allowed for controls, and some annunciation windows have
an angle of vision slightly less than the minimum (41 degrees instead of 45 degrees).
Issue D293 [R-45] has 8 gaps for a HFE review against NUREG 0700 requirements.
The two ANN system gaps: 1) DNGS uses a selector switch to suppress minor
alarms with no confirmation required, and 2) uses the same set of controls for both
alarm tiles and video alarm displays. The six ECIS gaps: DNGS users enter data
separators (dashes and slashes); the test and activation buttons for ECI are identical
and located close to each other; the DNGS PHT header layout shown on the ECI
panel is in the reverse order; the DNGS keyboards are not equipped with a numeric
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keypad; the DNGS cursor control keys are arranged in a row instead of being
oriented to be compatible with the cursor motion, and the DNGS design allows the
ECI blocking switch key to be removed with the switch in the blocked position (a
requirement for CANDU reactors).
3.3.1.3 Review of six (6) Safety ADs collectively for aggregate effects
The collective review of these six (6) ADs for aggregate effects was performed by a
similarity analysis technique that assigns Attributes to each AD. Where an attribute
was observed to be common to more than one AD, the ADs were grouped together for
further analysis. The following attributes were considered:
Component or system affected
Potential impact of the AD on the component or system
Safety function, e.g., operator information
Technical area affected, e.g., human-machine interface
Mitigating barriers credited in the IRF against AD gaps.
Table 3.3.1.3 lists the attributes for each of the six ADs. D061 [R-32] applies to post-
accident monitoring, which is independent of the other five (5) ADs. ECIS is common to
the other five ADs, and none of these 5 ADs interact with the independence and/or
protection of the three ECIS information chains that are used in the PAM system.
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Table 3.3.1.3 Aggregate Assessment of Combinations of the six Safety ADs
Attributes
Acceptable Technical basis
Deviation (AD) Component or Potential Safety Technical Mitigating in the IRF for
system affected impact on function area barrier AD disposition
specific potentially credited in
component affected the IRF
D061 [R-32] Lack of No specific N/A Operator Post- SS channel Risk
a redundant PAM component information, accident displays are assessment
info chain outside of Post Accident post- monitoring independent Design
ECIS or Management accident and redundancy
containment for protected
some parameters
D261 [R-36] ECIS & Annunciations, Design Operator HMI Operator ANN, displays
ANN display vs. displays in MCR change information training and are mostly
NUREG ECIS and for control experience NUREG
enhancements annunciation action OPG error compliant
reduction OPG error
reduction
D286 [R-41] HF ops No specific Design Operator HMI Operator A variety of
experience review component change information training and HFE-related
of ANN and ECIS ECIS and for control experience deficiencies, low
human machine annunciation action OPG error risk significance,
interfaces vs. reduction many of which
NUREG 0700 were closed.
DNGS is mostly
NUREG
compliant
Error reduction
D289 [R-42] MCR labeling Change Operator HMI Operator No significant
NUREG 0700 label ECIS and label information training and events related to
requirements annunciation positions, and experience the 9 label gaps
modify maintce OPG error have occurred
procedures reduction
D291 [R-44][R-44] MCR ECIS panel Minor Operator HMI Operator Low risk
ECI & ANN keyboard, controls, changes in information training and significance
keyboard, controls window movement and control experience Largely NUREG
and windows vs. and position action OPG error compliant
NUREG reduction
D293 [R-45] ANN Switch, controls Design Operator HMI Operator Low risk
alarm switch, alarm ECIS changes control training and significance
controls, ECI actions experience Largely NUREG
controls vs. NUREG OPG error compliant
reduction
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The five ECIS ADs all affect the human-machine interface (HMI), which relates to
operator performance. They are all minor deviations from US NRC NUREG 0700.
D261 pertains to system display enhancements, and D286 is about a variety of
potential HF engineering improvements of low significance that were identified after
an operational experience review against NUREG 0700. D289 are minor gaps from
NUREG on enhanced component labeling (cabinet doors, fuses, annunciators).
D291 are minor ergonomic improvements to panel keyboards and the locations of
some panel controls and some annunciation windows. D293 identifies the DNGS
approach, which is different than that specified in NUREG 0700, to suppress minor
alarms in the annunciation system. The approach for the ECIS controls is different
from NUREG 0700 and appropriate for the CANDU design.
ECIS and operator performance are the common factors for these five ADs. The
aggregate effects of combinations of these ADs is negligible because: 1) they have
no effect on the automatic operation of ECIS, and 2) the operators are already very
accustomed to the HMI with the ECIS and annunciation displays in the DNGS MCR.
The IRFs for these five ADs include credit for the operators training, experience and
capabilities.
The Darlington NGS operators are highly trained and experienced with the existing
HMI features of the MCR and the SCA. The Darlington NGS policies and programs
ensure that Operators are well trained to perform their duties and remain qualified to
do so. The OPG Nuclear Training Program is defined in [R-46]. Finally, OPG has
ensured that rigorous error reduction techniques are used during normal operation
and accident management, as described in the OPG Nuclear Human Performance
Program [R-47] and the OPG Nuclear Operations Program [R-48].
Therefore, it is concluded that the aggregate impacts of combinations of the six

Safety ADs on OPGs Accident Management capability is negligible. Hence, there is
no impact on public safety.
3.3.2 Review of 33 Fire Protection ISR issues
3.3.2.1 IRFs that established the AD status of 33 Fire Protection ISR issues
Table 3.3.2.1 summarizes the IRFs on the following ISR issues: D041 [R-59], D044
[R-60], D045 [R-103], D052 [R-61], D222 [R-35], D226 [R-104], D233 [R-64], D298
[R-65], D437 [R-66], D438 [R-67], D440 [R-68], D447 [R-70], D451 [R-71], D453 [R-
73], D454 [R-74], D455 [R-75], D456 [R-76], D457 [R-77], D461 [R-105], D462 [R-79],
D463 [R-80], D464 [R-106], D472 [R-107], D506 [R-97], D507 [R-108], D514 [R-98],
D519 [R-99], D522 [R-109], D523 [R-110], D524 [R-111], D527 [R-100], D528 [R-101]
and D530 [R-102]. These address a number of gaps against clauses in modern
codes and standards.
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Table 3.3.2.1 demonstrates that for the following ADs, either actions have been
carried out or clarifications have been provided for all of the gaps in the ADs (e.g.
compliance has since been demonstrated) such that they no longer affect Accident
Management:
D226, D233, D298, D440, D447, D451, D456, D461, D462, D463, D464,
D507, D519, D522, D527 and D530
These ADs are excluded from the assessment. The remaining seventeen (17) ISR
issues contain at least one gap that has been classified as an acceptable deviation
from the applicable code. These ISR issues are discussed in Section 3.3.2.2 and
reviewed collectively for aggregate effects in Section 3.3.2.3.
Table 3.3.2.1 Summary of IRFs for 33 Fire Protection Acceptable Deviations

D041 Special Fire Two (2) gaps from the National Fire Code of Canada (NFCC) 2005 regarding CO2 fire
[R-59] Suppression System suppression system. Addressed by moving part of gap 00415 to Issue D045
Requirements (reviewed below) and crediting the remaining part of the gap to ERT training and
NK38-REP-00770- action. Gap 00475 is compliant and closed.
0421331 R002 Gap 00415 against NFCC Clauses 2.1.3.5 which states:
1) Where a special fire suppression system is required conform to one of standards in
(3) and (4).
2) If a water-based system is not compatible with the fire suppression requirements for
certain types of dangerous goods, a special system conforming to a standard in Sentence
(3) is permitted.
3) Standards for a special fire-suppression system that is not water-based.
4) Standards for water-based special fire-suppression systems.
5) Wetting agents for water-based systems shall conform to NFPA 18.
6) A hazard for which a system has been designed, is not permitted to be increased
unless the level of protection is increased.
7) Posting of operating and maintenance instructions.
8) Marking of valves and controls for a special fire suppression system.
CO2 suppression was originally installed as per NFPA 12 in several buildings. NFPA 12
requires suitable safeguards to ensure prompt evacuation and to prevent entry into
hazardous atmospheres. Gap 00415 identifies that safeguards (in Sentences 3 and 4)
have not been fully installed at DNGS to properly warn personnel of fire-related dangers.
Additionally, no documentation was found to indicate compliance with Sentences 7 and 8
for posting operating and maintenance instructions in proximity to the equipment and
controls, and marking the valves and controls to indicate their function.
The portion of this gap associated with 3) and 4) were identified in the gap analysis of
N293-07 as gaps 00547, 01286 and 01287, to be resolved under Issue D045 (which is
discussed below).
As per a specialist review, the CO2 systems were removed from all areas of DNGS
except the fuel pump room and the fuel storage rooms of the EPG Fuel
Management Building. Procedural controls have been implemented to achieve the intent
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of the required safeguards consisting of: gas supply isolation, maintaining communication
with personnel outside the areas protected by the CO2 systems, and wearing SCBA when
entering such areas. The safeguard requirements and intent have not changed since
1980, so the procedural measures remain valid for the extended life.
The portion of this gap associated with Sentences (7) and (8) are addressed by
Emergency Response Team (ERT) training and actions; no further action needed.
Gap 00475 against NFCC Clause 6.6.1.1 It requires that the special system be tested,
inspected and maintained in conformance with the appropriate requirements. The gap
identifies that the safeguards required by NFPA 12 in order to properly warn personnel of
fire-related dangers have not been fully installed in DNGS. The actions taken have
resolved this gap. After a third party review, IRF reclassified this gap as compliant
and closed.
This ISR issue is addressed in the assessment.

D044 Fire Alarm Systems Seventeen (17) gaps, 15 against CAN/CSA N293-07 and two against NBCC 2005. Gaps
[R-60] NK38-REP-00770- 00533, 00539 and 00542 are compliant; 00545 is not applicable; 00543, 01268, 1843 and
0421334 R001 1844 were moved to other issues. 00538, 00540, 00541 and 02070 will be made
compliant.
Gap 00533 against N293-07 Clause 7.2.1.1 requires that fire alarm systems using very
early warning fire detection technology be provided. Very early warning systems as per
NFPA 76 were not provided. The existing systems are not compliant with Clauses 3.3.1.3,
4.2.4, 4.2.10 and 5.8.3 of CAN/ULC-S524-06 relating to circuit wiring, data communication
links and duct-type smoke detectors. Additional analysis recommends retaining existing
duct detectors with sampling tubes in their current configuration. Cost for additional
sampling- tube duct detectors do not justify benefits gained when alternative standards
(i.e., NFPA 72) indicate protection goals met with the existing devices. Alternative
compliance
Gaps 00535, 00536 and 00537 against N293-07 Clause 7.2.1.6.1, .2 and .3 which require
a two-stage fire alarm system. The DNGS system is not a two-stage alarm; it is missing
the initial alert signal.
Gap 00538 against N293-07 Clause 7.2.1.6.4. It states that a building less than 5000 ft2
may use a single-stage alarm system, but none of the DNGS are smaller than 5000 ft2. A
further study of building size vs. alarm was carried out. The NBCC would require manual
pull stations and smoke detection in the water treatment plant (WTP) and the
pumphouses. The lack of pull stations is justified by the training of staff to report the fire
by dialing 911; the PA system speakers notify and instruct staff there in the event of fire or
other emergencies. The fire hazards in the pumphouses are the large pump motors that
have high temperature alarms in the MCR. Because occupancy is low in the WTP, it has
automatic fire detection within a pump room, the control room and the CER. The design
meets code intent
Gap 00539 against N293-07 Clause 7.2.1.7. It requires the alarm and voice
communication systems be equipped with back-up batteries for not less than 24 hours
supervisory functions. The six main Pyrotronics indicating panels in the CER do not have
back-up batteries. Direct compliance, supplied by Class II power, which is backed up
by batteries.
Gap 00540 against N293-07 Clause 7.2.1.9. It requires the MCR be the Central Alarm
and Control Facility and the display and control centre be in the MCR. In DNGS, it is in the
CER. Additional analysis proposes leaving the fire control panels in the CER instead of
moving the annunciator panels to the MCR; the potential convenience gained does not
justify the cost. A common signal is displayed in the MCR with details (visual and audible
alarm and trouble signals) on the panels in the adjacent CER. It requires the U0 operator
to leave his station in the MCR to view the full details of a fire alarm signal. The travel
distance and time is insignificant, and the operator is already accustomed to the
present design.
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Gap 00541 against N293-07 Clause 7.2.1.10.3. It requires capability to transfer control of
the alarm system from the MCR to the SCA. The SCA multi-zone local indicating panels
are incapable of full control of the station alarm system. This gap is being addressed by
A/R 28155463-16
Gap 00542 against N293-07 Clause 7.2.1.12.2. It requires all separate fire extinguishing-
agent-releasing panels or modules integrated into the fire alarm panel have a power
supply with an emergency power source. Most local releasing panels do not have this
source. Direct compliance, supplied by Class II or III power with battery backup.
Gap 00543 against N293-07 Clause 7.2.1.13.1. It requires that wiring in service spaces
containing other combustible materials and that are used for alarm and emergency
equipment shall be capable of performing for at least 1 h after a fire. No evidence that 1 h-
rated wiring has been used. This gap is being closed in ISR Issue D442 and therefore
is excluded from the assessment.
Gap 00545 against N293-07 Clause 7.2.3.3. It requires that where visual signals are
provided both visual and audible signals operate immediately and simultaneously upon
activation. MCR operators shall be capable of selectively stopping signals. No facility to
selectively stop signals. No DM evidence that visual signals meet NFPA 72 for synch and
minimum candela. Not applicable to DNGS (no visual alarm devices).
Gap 01268 against N293-07 Clause 5.7.3.1. It requires a fire alarm system be installed in
buildings in accordance with N293-07 and NBCC. Gaps were identified with the design
and suppression capabilities. This gap is being closed in ISR Issue D428 and
therefore is excluded from the assessment.
Gap 01880 against NBCC 2005
Clause 3.2.4.4.(1) It requires that a single-stage alarm system, upon the operation of any
manual station, water flow detecting device, or fire detector, cause an alarm signal to
sound on all audible signal devices in the system.
Clause 3.2.4.4.(2) It requires that a 2-stage alarm system
a) cause an alert signal to sound upon the operation of any manual station, waterflow
device or fire detector
b) automatically cause an alarm signal to sound, if the alert signal is not acknowledged
within 5 min
c) have manual stations, each of which is equipped so that the use of a key or other
similar device causes an alarm signal to sound that continues upon removal of the
key or device from the station.
Audible signal devices do not sound automatically 5 min after operation of an alarm
device
Gap 01882 against NBCC 2005 Clause 3.2.4.6. It requires that
1) a fire alarm system be designed so that when an alarm signal is actuated, it cannot
be silenced automatically before a period of time has elapsed that is not less than
a) 5 min for a building not required to be equipped with an annunciator, and
b) 20 min for any other building
2) Fire alarm system does not incorporate manual silencing switches other than those
installed inside the fire alarm control unit.
The systems were designed to ULC-S524 and commissioned and verified to ULC-S537
and are maintained to ULC S536, but the DM does not indicate the alarm silencing
requirements are met. The intent is to prevent alarms being prematurely silenced. Not
applicable to DNGS. Audible signal devices are not provided; there is no automatic
signal upon operation of an alarm initiating device. The U0 operator receives all alarm
initiating signals and is required to sound the ERT tone within one minute of being
informed of a fire.
Gap 01843 against N293-07 Clause 7.2.2.2. It requires very early warning detection
technology unless the FHA and FSSA permit otherwise. This gap is being closed in ISR
Issue D430 and therefore is excluded from the assessment.
Gap 01844 against N293-07 Clause 7.2.2.4. It requires that alternative fire detection
methods be considered where fire detectors cannot operate as per their design specs or
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where the detection method is not practical. This gap is being closed in ISR Issue D430
and therefore is excluded from the assessment.
Gap 02070 against N293-07 Clause 7.2.1.10.2. It requires that each display and control
centre in an SCA provide full display and control for all portions of the system that are
located within the area under the control of the SCA. Multi-zone local indicating panels are
in each SCA. The fire alarm system network panels are set up in a peer-to-peer system,
which permits control from each panel without the need for transfer. However, these
panels do not provide full display and control functions for the Pyrotronics system. This
gap is being addressed by A/R 28155463-16

D045 Fire Suppression Fifteen (15) gaps, against CAN/CSA N293-07. Gap 00553 is compliant; 00552 not
[R-103] NK38-REP-00770- applicable and 00546, 00548, 00554 and 01269 are being closed in ISR Issue D430
0421335 R001 and therefore are excluded from the assessment.
The remaining gaps have been addressed. Fire extinguishers, standpipes and the CO2
system are ADs.
Gap 00546 against Clause 7.3.1.1.1. It requires damage from the fire suppression agent
be considered during fire suppression system selection. No documents confirm this
requirement met. This gap is being closed in ISR Issue D430 and therefore is
excluded from the assessment.
In the following 7 gaps, there are eight deviations from NFPA and FM-7 101 standards.
The FHA documented multiple findings regarding portable fire extinguishers and fire hose
stations.
Gap 00547 against Clause 7.3.1.1.2. It requires the fire suppression system be provided
in accordance with (a) this Standard, (b) the NBCC, (c) the NFCC and (d) additional
applicable technical requirements specified in the documents of Clauses 7.3.1.1.3 and
7.3.1.1.4. Refer to summary below.
Gap 01270 against Clause 5.7.4.2.2. It requires the automatic suppression systems be
designed and installed in accordance with Clause 7 and inspected, tested and
maintained in accordance with Clause 8. Refer to summary below.
Gap 01286 against Clause 7.3.1.1.3. It requires the design to comply with the
requirements of the AHJ for pressure-retaining components and with the NFPA
standards. Refer to summary below
Gap 01287 against Clause 7.3.1.4.1. It requires the systems be designed and installed
in accordance with the applicable NFPA documents listed in Clause 7.3.1.1.3. Refer to
summary below.
Gap 01846 against Clause 7.3.1.2. It requires the suppression, required by Clause
5.7.4.2.1, to be provided using automatic sprinkler systems. Where not provided, the
FHA is required to demonstrate that all the fire protection goals are met. Refer to
summary below.
Gap 01850 against Clause 7.3.4.2. It requires that special extinguishing systems be in
accordance with NFPA standards. Refer to summary below.
Gap 02112 against Clause 7.3.1.1.3. It requires that sprinkler systems be installed in
accordance with NFPA 13. Some deflectors were located more than 16 inch maximum
distance below ceilings, floor decks or beams allowed by the code (up to ~ 20 inches).
The summary of the resolutions for these 7 gaps are:
- Fire Extinguishers---no action; the existing configuration is an acceptable deviation.
- Standpipes---no action
- CO2 System---no action
- Transformer Deluge Suppression System, Implement actions in E-3 of FHA report
- Foam Suppression System: Analysis points out that the system for protecting the SG
fuel tanks and dikes does not involve the use monitors and hand lines. Fixed nozzles
are positioned inside the tanks and around the perimeters of the dikes for delivering
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the foam-water. The existing system is acceptable and in direct compliance with the
requirements of NFPA 11 and CSA N293-07.
- Sprinkler System in Turbine Halls: Analysis on sprinkler discharge density concluded
that the benefit gained to modify this sprinkler to comply with FM 7-101 does not
justify the cost of the modification. The performance of the existing sprinklers average
discharge density meets and exceeds the code requirement.
- Sprinkler System in Storage Rooms S-119 and S-219 will be upgraded to meet NFPA
13. This gap is being addressed by A/R # 28155462-33
- Sprinkler System in Powerhouse Complex FFAA Fuel Storage Areas: Analysis
demonstrates that the existing sprinkler configuration satisfies the intent of the
standard.
Gap 00548 against Clause 7.3.1.3. It requires that the design of suppression systems
include means to mitigate hazards created by the operation of these systems. No
documentation in the DMs to confirm this requirement was met. This gap is being
closed in ISR Issue D430 and therefore is excluded from the assessment.
Gap 00551 against Clause 7.3.3.3. It sets requirements for sidewall sprinklers, where
used to protect structural steel columns. DM states that side sprinklers have been
installed between column rows T and B; however, the following requirements are not
confirmed:
- Vertical distance between sprinklers does not exceed 3 m
- Highest sidewall sprinkler located within 0.3 m of the bottom of the ceiling beams
- Sprinklers placed in an alternating pattern on opposing sides of the column
- Sprinklers discharge on the web
Analysis proposes to retain the existing column protection because it can provide effective
protection against structural failure when crediting the ceiling sprinklers. Single side
protection of column webs is an approved protection option in high challenge fires.
Calculations confirmed the steel columns can withstand high heat exposure for a time
without any protection. Existing column protection plus ceiling sprinklers and manual
ERT suppression to control postulated fires will prevent serious damage.
Gap 00552 against Clause 7.3.3.4. It sets requirements for cable tray locations below
sprinklers. Design manual does not specify that the following requirements be considered
in the design. Since there are no sprinkler systems provided for cable tray protection, this
gap is closed because this requirement is not applicable.
Gap 00553 against Clause 7.3.3.5. It sets requirements for trays located above
sprinklers. DM does not specify design requirement for sprinklers to be a maximum
distance of 0.15 m below the bottom of the cable tray. Gap is closed. Direct
compliance.
Gap 00554 against Clause 7.3.3.6. It sets requirements for containing water discharge for
water-based systems. DM does not mention requirements for diking and containment, to
limit the spread of flammable and combustible liquids, and to divert liquid from equipment
that becomes inoperable when wet and affects nuclear safety. This gap is being closed
in ISR Issue D430 and therefore is excluded from the assessment.
Gap 01269 against Clause 5.7.4.2.1. It requires suppression be provided for all buildings,
structures and equipment unless demonstrated by the FHA, etc. that the fire protection
goals can be met using other fire protection measures. This gap is being closed in ISR
Issue D430 and therefore is excluded from the assessment.
Gap 01288 against Clause 7.3.3.7. It requires oil-filled transformers, including their
adjacent non-absorbing ground areas, be protected with an automatic water-based spray
system, in accordance with NFPA 15 or NFPA 16. This gap is being addressed by A/R
# 28155463-13
- The non-absorbing ground areas adjacent to the transformers are not protected by
water-based spray systems, and
Transformers filled with silicone fluid and located within the main powerhouse are not
protected with water-based spray systems.
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D052 Identification Signs for One (1) gap from a review of NFPA-24 Standard for the Installation of Private Fire Service
[R-61] Fire Service Valves Mains and Their Appurtenances.
NK38-REP-00770- Gap 00838 against NFPA-24 Clause 6.6.1. It requires indication of function on labels for
0421404 R002 fire service valves. The intent is met. The valves at DNGS have adequate identifier
labels. The ERT is trained to identify and locate these valves.

D222 Public Address System Three (3) gaps from reviews of CAN/CSA N293-07 on performance requirements of public
[R-35] NK38-REP-00770- address system
0425804 R000 Gap 00534 against Clause 7.2.1.2. It requires integrated, supervised one-way voice
communication in all structures and exterior areas and in areas where SSCs directly
support the plant. The PA system does not meet requirements for circuit supervision,
speaker coverage or treatment for high noise level places. To comply, the IRF states that
DNGS implemented a monitoring program of periodic inspection, testing and maintenance
of the PA system to achieve the intended level of reliability. To maintain audibility, the
program requires employees to raise SCRs if they do not hear test announcements during
weekly testing. In addition, a speaker audibility walk down is performed monthly by
Emergency Response Maintenance. Visual signal strobes have not been installed in high
noise areas; the alternative approach of posting warning signs and limiting access to high
noise rooms is used. The intent of the requirements is met. No further action.
Gap 01285 against Clause 7.2.3.2 It requires fire alarm signals and voice announcements
to be audible and intelligible in interior areas as per NBCC-2005 and CAN/ULC S524-01.
Fire alarm signals and voice messages are not clear in some locations due to high noise
or poor speaker coverage. IRF indicates the Fire Protection Code Compliance Review
report states the alternative measures meet the intent of the codes provisions for circuit
supervision and speaker coverage for the PA systems. No further action.
Gap 01845 against Clause 7.2.3.1 It requires that accessible spaces be equipped audible
and/or visual fire alarm signal devices. However, some accessible areas of the station are
not covered. The resolution in the IRF for this gap is the same as the resolution in the IRF
for Gap 00534 above. No further action.

D226 Control Room Complex Seven (7) gaps, from reviews of CAN/CSA N293-07. Gaps 00498 and 00499 are ADs.
[R-104] Fire Protection Three ADs addressed in D430. Gap 01750 to be closed.
NK38-REP-00770- Gap 00497 against Clause 5.7.8.1 It requires that the safety measures in Clauses 5.7.8.2
0425808-R003 to 5.7.8.6 be complied with for the control room complex. Gaps identified for Clauses
5.7.8.2, 5.7.8.3 and 5.7.8.5. Gaps 00498 and 00499 are ADs. Gap 01750 (5.7.8.3) will be
closed.
Gap 00498 against Clause 5.7.8.2 It requires control room complex be separated from
adjoining areas by a fire separation. MCR is not separated from the CER with fire-
resistant rated separation. FHA determined design meets the 2 h requirement.
Gap 00499 against Clause 5.7.8.5 It requires that areas of the control room complex
outside of the MCR and CER and control computer room be protected by fire suppression
systems and be separated from the MCR and CER by a fire separation. The office areas
do not have suppression systems. This gap is being closed in ISR Issue D430 and
therefore is excluded from the assessment.
Gap 00544 against Clause 7.2.2.3 It requires the control room complex be equipped with
a fire alarm system that uses very early warning fire detection technology. The MCR has
state-of-the-art addressable smoke detectors, but not a very early warning fire detection
system. This gap is being closed in ISR Issue D430 and therefore is excluded from
the assessment.
Gap 01281 against Clause 6.7.1.1 It requires the control room complex be separated from
the rest of the building by a fire separation with a 2 h rating, unless greater rating required
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by the FHA. N-STC-27800-10000 requires barriers provide satisfactory level of fire

protection, but does not specify a separation with 2 h rating. This gap is being closed in
ISR Issue D430 and therefore is excluded from the assessment.
Gap 01282 against Clause 6.7.1.3 It prescribes air quality within the complex for a fire
occurring outside the complex. DM does not specify a maximum of 1% contaminated air.
This gap is being closed in ISR Issue D430 and therefore is excluded from the
assessment.
Gap 01750 against Clause 5.7.8.3 It requires special consideration be given to prevention
of fires in the control room complex. Section 6.8 provides the FP requirements. Some
clauses were determined to be gaps. This gap is being addressed by A/R # 28155462-
22.
This ISR issue is excluded from the assessment.
D233 Manual Fire Alarm Pull One (1) gap from CAN/CSA N293-07
[R-64] Stations Gap 01284 against Clause 7.2.2.1 It requires manual alarm pull stations be located at all
NK38-REP-00770- exits and along each main isle. DNGS has no manual pull stations along the main egress
0425813 R001 routes (powerhouse) to maintain the 30 m maximum travel distance requirement for
unsprinkled areas and 45 m for sprinkled areas. Powerhouse staff is familiar with the
building, egress routes and exits, and is trained in fire safety actions. The existing
pull station locations are adequate. No action required. Not applicable to DNGS

D298 National Fire Code Seven (7) gaps from NFCC 2005
[R-65] Storage Room Design Gap 00431 against Article 3.2.2.2 It specifies requirements for access aisles in storage
Requirements rooms, including firefighting access, minimum dimensions and obstruction restrictions. No
NK38-REP-00770- documentation that demonstrates compliance. Analysis of the CSA storage areas
0426328 R001 indicates the upper stores and control maintenance stores meet requirements. The
ERT confirmed the aisle widths in the lower stores are acceptable. Intent is met.
Gap 00432 against Article 3.2.2.3 It specifies clearance requirements for walls, ceiling,
sprinkler system and exhaust ventilation system in storage rooms. An additional
requirement is for clearance between stored products and ducts of the exhaust ventilation
systems. No documentation that demonstrates compliance. Gap is closed by direct
compliance.
Gap 00434 against Article 3.2.2.7 It specifies the maximum permitted height of storage in
an area to be according to base area, shape, stability and potential height limitations. No
documentation that demonstrates compliance. Gap is closed by direct compliance
Gap 00439 against Article 4.2.8.4 It species that, in general storage areas, the height of
storage of flammable and combustible liquids not exceed that permitted for unprotected
storage. No documentation that demonstrates compliance. The DNGS fire safety plan
limits the amount in the Central Service Area Stores. DNGS procedures provide
requirements for these liquids. Approved storage cabinets are used. Gap is closed
by direct compliance.
Gap 00441 against Article 4.2.9.2 It specifies that rooms for storing and dispensing
flammable liquids be liquid-tight where the walls join the floor. No documentation that
demonstrates compliance. Not applicable.
Gap 00442 against Article 4.2.9.3 It specifies 1 m minimum aisle width in rooms for
storing and dispensing flammable liquids. No documentation that demonstrates
compliance. Not applicable.
Gap 00443 against Article 4.2.9.5 It specifies requirements for venting of storage rooms
without critical structural and mechanical damage from an internal explosion. No
documentation that demonstrates compliance. Not applicable.
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D437 2hr Emergency Lighting One (1) gap from CAN/CSA N293-07
[R-66] Requirement Gap 01762 against Clause 6.6.1.3 It requires emergency lighting be provided with a
NK38-REP-00770- minimum 2-hour emergency power supply. In most locations, DNGS emergency lighting is
0462020 R000 fed by Class II power. In the locations not served by Class II power, the battery packs
provided are adequate for the required evacuation time, which is less than 2 hours. The
ERT and the Operators can perform their necessary actions using battery-powered
flashlights. The intent of this clause is met. No further action is required.
D438 Access for Fire Fighting One (1) gap from CAN/CSA N293-07
[R-67] NK38-REP-00770- Gap 01763 against Clause 6.6.3 which provides an exemption for a NPP, regarding
0462021 R000 NBCC requirements on window openings and access hatches, for plant security and
protection from external events, where compensatory measures acceptable to the CNSC
are provided. No documentation found to demonstrate compliance. DNGS has multiple
building interior access locations to fight fire and a full-time ERT, with ventilation to
manage smoke. The DNGS ERT has the necessary training and equipment to
perform its duties. Acceptable deviation. No further action.

D440 Combustible Material in Six (6) gaps, four from NBCC 2005 and two from CAN/CSA N293-07
[R-68] Electrical Equipment Gap 01865 against NBCC Clause 3.1.13.4 It permits the flame-spreading rating of
NK38-REP-00770- combustible light diffusers and lenses to exceed limits specified elsewhere in NBCC. No
0462023 R000 evidence found regarding DNGS compliance. Assessed to be compliant.
Gap 01765 against N293-07 Clause 6.8.4.2 It requires that electric and control cabinets
be designed to minimize flame spread across adjacent cabinets. This level of the design
was not inspected. FSSA analyzed failure of all credited cabinets and demonstrated
the fire safe shutdown goals are achieved. Complies with code.
Gap 01766 against N293-07 Clause 6.8.4.4 It requires electrical cables have low (1.5 m)
flame-spread rating and produce low smoke and corrosive gases. Cable systems DM
indicates all cables comply except for power cables 5 kV and above, which have a 2
m flame spread. Assessed to be acceptable compliance with code.
Gap 01857 against NBCC Clause 3.1.5.18 It permits optical fibre cables and electrical
wires and cables with combustible insulation, jackets or sheathes, but places limits on
their use. The exposed power cables do not conform. Assessed to be acceptable
compliance.
Gap 01858 against NBCC Clause 3.1.5.20 It permits use of totally enclosed non-metallic
raceways, not more than 175 mm in outside diameter or an equivalent rectangular area,
to enclose optical fibre cables and electrical wires and cables, provided their vertical char
is not more than 1.5 m. No documentation found to confirm DNGS compliance. Assessed
to be acceptable compliance.
Gap 01930 against NBCC Clause 3.6.4.3 It permits the materials in a concealed space
used as a plenum within a floor or a roof assembly not to conform to Sentence 3.1.5.15
(1) and article 3.6.5.1. It applies to Central Services Areas such as MCR and the
Cafeteria. Specified for a vertical char limit of 2 m, the DNGS power cables do not
meet the CSA C22.2 No. 0.3 FT4 rating of 1.5 m. Assessed to be acceptable
deviation. No action required.
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D447 Fire Separations Three (3) gaps from NBCC 2005

[R-70] Acceptable Deviations Gap 01859 against Sentence 3.1.7.5 (1) It requires load bearing walls, columns, and
and Alternate arches in the storey immediately below a floor or roof assembly to have an adequate fire-
Compliances resistance rating (FRR) for the supported floor or roof. Some DNGS buildings have
NK38-REP-00770- unprotected structural steel members that void the fire ratings of the assemblies
0462031 R000 they support. These DNGS buildings are suited to the Life Safety Code NFPA 101-
2012. This gap is closed because DNGS complies with the alternate code that
addresses this issue.
Gap 01861 against Sentence 3.1.8.5 (2) It requires every door, window assembly or glass
block used as a closure in a required fire separation be installed in conformance with
NFPA 80 on fire doors and other opening protectives. Not all doors required to be fire
rated doors are equipped with fire rating labels. The unlabeled doors were
assessed, and they comply.
Gap 01862 against Article 3.1.8.6 It limits the size of an opening in an interior fire
separation required to be protected by a closure. DNGS has openings through floors and
hatches that exceed the limits. Since resolution of this gap depends on CNSC
acceptance of the FHA this gap is being addressed in ISR Issue D431 and therefore
is excluded from the assessment.

D451 Building Classification Three (3) gaps from NBCC 2005
[R-71] and Sprinkler Gap 01870 against Clause 3.2.2.18 (1) It requires an automatic sprinkler system be
Requirements installed throughout a building regulated by one or more of Articles 3.2.2.20 to 3.2.81 and
NK38-REP-00770- as per Clause 3.2.2.18 (2). The Tritium Removal Facility (TRF) and the Powerhouse are
0462036 R000 not provided with automatic sprinkler protection throughout as required. This gap is
closed because of special considerations in the NFPA 101 code that address this
issue that DNGS complies with for these buildings.
Gap 01871 against Clauses 3.2.2.63 (1) and (2) It states that a building classified at
Group F Division 1 shall conform to Sentence 3.2.2.63 (2), provided it is not more than 4
stories in height and has an area not more than 2,250 sq m. It is required to be of non-
combustible construction, sprinkled throughout and floor assemblies constructed as fire
separations with 2 h or more rating. The mezzanines, walls, columns and arches are to be
fire resistant. The TRF is a high hazard F-1 building with area exceeding the limits of this
clause. It does not comply with these requirements. This gap is closed because of
special considerations in the NFPA 101 code that address this issue that DNGS
complies with for this building..
Gap 01872 against Clause 3.2.2.73 (1) and (2) It states that a building classified as F-3
shall conform to Sentence 3.2.2.73 (2) and be sprinkled throughout, noncombustible
construction with fire-resistant floor assemblies, walls, columns and arches. The
Powerhouse fits under this classification, but is not protected by sprinklers throughout.
This gap is closed because of special considerations in the NFPA 101 code that
address this issue that DNGS complies with for this building.

D453 Fire Department One (1) gap from NBCC 2005
[R-73] Notification Gap 01883 against Clause 3.2.4.7 It requires a fire alarm system and its water flow-
NK38-REP-00770- indicating devices be designed to notify the fire department when an alarm is initiated.
0462038 R000 The intent is to limit the probability that emergency responders will not be promptly
notified. The DM does not indicate automatic relay of a signal to local fire department. Fire
and emergency tones are initiated by Operator action. This is a single-stage system as
the ERT tones are sounded upon receipt of an alarm or notification via phone. All alarms
from local panels are received in the CER and are monitored by the Unit 0 Operator. The
fire location is announced and the ERT is instructed to respond over the PA system. In
addition, the Unit 0 Operator is required to call the Clarington Emergency and Fire
Services. The intent is met by prompt Operator action. This gap is reclassified as an
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acceptable deviation. No action required.

D454 Fire Alarm Annunciator One (1) gap from NBCC 2005
[R-74] NK38-REP-00770- Gap 01884 against Clause 3.2.4.8 It requires an annunciator in close proximity to a
0462040 R000 building entrance that faces a street or an access route for fire department vehicles. The
intent is to limit the probability that emergency responders will be delayed in locating the
annunciator and the area of fire. The main Powerhouse annunciator is in the MCR, not as
required by NBCC. The Unit 0 Operator monitors the station at all times and reports any
alarms to ERT and Clarington, including the location of the incident. The intent is met by
prompt Operator action. This gap is reclassified as an acceptable deviation. No
action required.

D455 Emergency Notification Three (3) gaps from NBCC 2005
[R-75] System Gap 01885 against Clause 3.2.4.9 It requires electrical supervision for a fire alarm system
NK38-REP-00770- and transmission of indication of a supervisory signal to the fire department. Open-circuit,
0462041 R000 short-circuit, ground faults and loss of data are signaled; however, voice system amplifier
and speakers are not supervised, so announcements may not reach all occupants,
including local ERT. Supervisory signals are not automatically relayed to the local fire
department. They are received at the main fire alarm control panel in the MCR. The
Operator tests the PA system speakers monthly and initiates repairs. Supervisory signals
in MCR lead to Operator action to determine the cause and initiate repairs. The intent is
met. This gap is reclassified as an acceptable deviation. No action required.
Gap 01888 against Clause 3.2.4.18 It requires audible signal devices that are audible
throughout the floor area. The sound pattern shall conform to the temporal pattern of ISO
8201. The sound pressure level shall not exceed 110 dBA. The sound pressure level shall
not be less than 10 dBA above the ambient noise level and not less than 65 dBA. Visual
signal devices shall supplement audible devices where required.
In DNGS: Emergency tone testing indicated numerous deficiencies relating to audibility of
the alarm signal. The audible signal does not meet ISO 8201. Emergency tone testing
identified locations where measurement exceeded 110 dBA. Many locations tested did not
meet the minimum audible requirement. There are noise areas of the Powerhouse where
strobes have not been provided. This gap is reclassified as an acceptable deviation.
The intent is met by the alternative measure of sounding emergency tones and
voice announcements over the PA system. No action required.
Gap 01889 against Clause 3.2.4.19 It requires visual signal devices be installed where
audible alarm is not effective. There are no visual signal devices. This gap is
reclassified as an acceptable deviation. The intent is met by the alternative measure
of posting warning signs and limiting access to high noise areas. No action
required.

D456 Requirements of Two (2) gaps from NBCC 2005. No combustible loads; closed.
[R-76] Janitors Closets Gap 01886 against Clause 3.2.4.10 It requires fire detectors in storage rooms, service
NK38-REP-00770- rooms, etc. where sprinkler protection is not installed. The janitors rooms at DNGS do not
0462042 R000 have fire protection. They are small and do not contain significant combustible loads.
Not applicable because no combustible loads.
Gap 01911 against Clause 3.3.1.21 It requires fire separation for janitorial rooms. Not
provided in DNGS. These rooms are non-combustible spaces. Not applicable.
D457 Smoke Recirculation One (1) gap from NBCC 2005.
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[R-77] NK38-REP-00770- Gap 01887 against Clause 3.2.4.12 It requires an air-handling system to prevent the
0462044 R000 circulation of smoke. The required prevention of smoke circulation between floors or fire
compartments in the Powerhouse is not satisfied, because fan shutdown is not provided
in some systems. Auto fan logic modification, if implemented, could result in decreased
system availability in response to FWLB/MSLB, due to the possibility of spurious smoke
detector signal shutting down fans credited for steam protection. These fans are credited
to operate following power restoration to pressurize and cool the associated steam
protected rooms. If the fans do not operate, excessive steam ingress and room overheat
could occur. The resultant harsh conditions could fail the critical equipment credited to
function in the safety analysis. Provision of fan shutdown would have a negative
impact on nuclear safety. This gap is reclassified as acceptable.

D461 Means of Egress Five (5) gaps from NBCC 2005. Acceptable; exclude these gaps.
[R-105] NK38-REP-00770- Gap 01908 against Clause 3.3.1.5.(1) It requires a minimum of two egress doorways ... in
0462050 R000 the room or suite .... The following rooms require two egress doorways: D-001, D-002, D-
003, D-025, R1-013/026, R4-014, S-141, S-510, SM-106, Tx-109 and Tx-111. Some
rooms have acceptable provisions; some require upgrades via This gap is being
addressed by A/R # 28156258-01.
Gap 01909 against Clause 3.3.1.6 It requires that if more than one egress doorway
required, the travel distance within the room or suite to the nearest doorway shall not
exceed ... The following rooms do not meet this requirement: SM-229, SM-301, VS-002,
VS-003 and W-001. The powerhouse and other building are special and unusual
structures, which are permitted to be protected via good fire protection engineering
practice. NFPA 101 used in these cases as it offers a more detailed analysis of fire and
life safety compliance on the basis of specific use. It permits travel distances up to 91 m.
Alternate compliance.
Gap 01910 against Clause 3.3.1.11.(2) It requires that, except as permitted by Article
3.3.1.12, a door that opens into a corridor or other facility providing access to exit
room/suite that is used ... shall swing in the direction of travel of travel to the exit. The
TRF building should be classified as a high hazard occupancy. There are 3 doors that do
not swing in the direction of egress travel. The swing direction of two doors will be
changed. This gap is being addressed by A/R # 28156258-02. The third door will not be
changed, as it would obstruct the exit corridor.
Gap 01913 against Clause 3.4.2.1 It requires that, except as ..., every floor area shall be
served by at least two exits. There are floor areas in the powerhouse which do not have
two exits, such as Elev. 93.5 in the TB (Tx-109). Rooms are sprinklered and grating floor
above, so no smoke or heat accumulation, allowing adequate time for egress. Building
complies with the intent of the requirement, which is to enable workers to evacuate
in a fire.
Gap 01914 against Clause 3.4.2.2 It requires that the space above a mezzanine shall be
served by means of egress leading to exits accessible at the mezzanine level on the
same basis as floor areas unless specific criteria are met. Egress from mezzanines is
required to be to be on the same basis as floor areas, but there are areas in the
powerhouse that do not comply, e.g., Rx-406, and Rx-407. These areas are for infrequent
access to equipment for inspection, testing and maintenance. Building complies with
the intent of the requirement, which is to enable workers to evacuate during a fire.
Page 71 of 98
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D462 Volatiles in Basements One (1) gap from NBCC 2005

[R-79] NK38-REP-00770- Gap 01912 against Clause 3.3.5.3 It requires that a basement shall not be used for the
0462051 R000 storage, manufacture or handling of volatile solids, liquids or gases that generate
explosive air-vapour mixtures or for processes that involve explosive dusts. The TRF
contains hydrogen processes, and the floor of the hydrogen compressor is 4 m below
grade. Other rooms that are part of the tritium removal process are also below grade.
Assessment determined that the design and arrangement are satisfactory. The intent of
the code to avoid explosions of volatile gas has been met by alternate means.

D463 Exiting Requirements Three (3) gaps from NBCC 2005
[R-80] NK38-REP-00770- Gap 01915 against Sentence 3.4.2.5 (1) It specifies maximum travel distances to an exit,
0462052 R000 where more than one exit is required from a floor area, Powerhouse areas are identified
that do not meet the 30 m limit for travel to an exit. The powerhouse and other building
are special and unusual structures, which are permitted to be protected via good fire
protection engineering practice. NFPA 101 used in these cases as it offers a more
detailed analysis of fire and life safety compliance on the basis of specific use. Areas
were assessed according to NFPA 101 and deemed compliant. Alternate
compliance.
Gap 01916 against Sentence 3.4.3.2 (1) It specifies minimum aggregate required width of
exits serving floor areas. Powerhouse areas with deficient exit capacities are identified.
The areas were assessed according to NFPA 101 and deemed compliant. Alternate
compliance.
Gap 01918 against Sentence 3.4.4.4 (1) It requires a fire separation that separates an exit
from the remainder of the building to have no openings, except as allowed. Unprotected
openings in exit stair enclosures are identified and an exit corridor that has openings that
are not exit doorways is identified. The openings (penetrations) in stair enclosures were
sealed. Assessment of the design indicates it complies with the intent of this
requirement.
D464 Signage Requirements Three (3) gaps, two from NBCC 2005 and one from NFCC 2005. Gaps to be closed.
[R-106] NK38-REP-00770- Gap 01919 against Clause 3.4.5.2 It requires a building of more than 2 storeys to have
0462053 R000 signs posted on an exit ramp or stairway that continues up or down past the lowest exit
level to indicate that it does not lead to an exit. No signs posted in powerhouse on
elevation 100 in exit stair indicating that level is the level of exit discharge. Same in D2O
bldg. Gap to be closed by This gap is being addressed by A/R # 28155459-10.
Gap 01922 against Clause 3.4.6.18 It requires numerals indicating assigned floor number
shall be mounted ... This sentence requires floor numbering within exit stair shafts. Floor
numbering is provided that conforms to contrast colour clause (d), but compliance to
position and size clauses (a), (b) and (c) varies by location. No visually impaired people
are in the buildings. Complies with intent, and compliance will improve when walls
are painted.
Gap 01941 against NFCC Clause 2.7.1.4 It requires signs of room/area occupant load ...
Cafeteria in Unit 0 has no sign posted. This gap is being addressed by A/R #
28155459-11.

D472 Oil Storage Tank and Eleven (11) gaps from review of NFCC 2005. Four gaps will be closed.
[R-107] Piping Requirements Gap 01945 against Clause 4.3.1.2. It requires atmospheric storage tanks be built in
NK38-REP-00770- conformance with 15 clauses in API and ULC standards. Although the storage tanks were
constructed in conformance with acceptable standards, the editions are older than those
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0462061 R000 referenced in NFCC 2005. No inspection reports found for EPG or Lube Oil storage tanks
indicating their compliance or suitability. The four SG tanks have had recent inspections
with repairs made as required; they are acceptable for continued use---AD. The EPG and
Lube Oil tanks are expected to be suitable, but will do complete assessment of tank
conditions for extended life of station. This gap is being addressed by A/R # 28155462-
18 (No documents found to indicate these tanks had met their 10-year inspection.)
Gap 01946 against Clause 4.3.3.1. It requires storage tanks be on the ground or
foundations, supports or piling made of concrete, masonry or steel as per API 650
Appendix B and API 620 Appendices C and D. ... The standards have been revised. EPG
tanks are supported by saddles more than 300 mm high. The present design does not
result in a significant reduction in the intended level of safety. The supports are not
combustible and will not contribute to a fire under the tank. Each tank storage room
and other features are well designed. The existing design meets the intent of the
code.
Gap 01947 against Clause 4.3.4.1 It requires storage tanks be provided with normal and
emergency venting as per API 2000 or standards listed in NFCC Sentence 4.3.1.2.(1).
The standards have been revised. Additional analysis in [R-95] Appendix A-14 states that
the normal vent sizes for the SG and EPG fuel oil tanks and the lubricating oil tanks meet
code requirements. The EPG tanks do not have emergency vents, but this is an
acceptable deviation because it does not result in a significant reduction in the intended
level of safety.
Gap 01948 against Clause 4.3.7.4 It requires no part of a secondary containment wall be
less than 1.5 m from a storage tank shell. To waive the distance requirement, the storage
tank must have a capacity of not more than 50,000 L and be protected by posts or
guardrails when exposed to collision damage. The EPG tanks are 1.4 m from their
containment wall, and the capacity is 25,000 Imp gal (113,450 L). The 10 cm difference is
not considered to have significant impact in either being able to see a spill under the tank
or in affecting firefighting efforts. There is a CO2 suppression system in each fuel tank
room that would discharge, so responders do not enter in a fire. Design meets code
intent.
Gap 01949 against Clause 4.3.12.8 It requires normal and emergency vents for storage
tanks in buildings. Weak roof-to-side shell seams, designed to rupture before allowable
design stress is reached, is not permitted as a means of emergency venting. The EPG
tanks have only a normal vent; no documents regarding emergency venting. Evaluate
normal venting and ensure compliance with current standards. Regarding EPG tank
emergency venting, the present arrangement does not result in a significant reduction in
the intended level of safety. See additional analysis in [R-95] Appendix A-14.
Gap 01950 against Clause 4.3.13.4 It requires that hose stations be provided for storage
tank rooms in buildings not required to be equipped with a standpipe and hose system.
Provide portable extinguishers for Class B fires. There are no hose stations near fuel
storage rooms. The only building with indoor storage tanks is the EPG fuel mgmt building.
It has sumps with level alarms in the fuel storage and pump rooms. The ERT has access
to hose stations in range of the building and to foam, which will be the most likely
suppression agent to fight a diesel fire.
Gap 01953 against Clause 4.5.6.7 It requires piping for flammable or combustible liquids
be located above ground where the piping enters a building and be fitted with inside and
outside shut-off valves and sleeves in wall penetrations (for pipe movement). The main
fuel line from the storage tanks enters the SG pump building below ground. The EPG fuel
management building has tanks inside, but no documents found to show how lines leave.
SG flow drawing shows valves at the SG tanks and in the SG pumphouse to shut off flow
in an emergency. The piping is deep under the building and encased in concrete
protection; further settlement will not occur. EPG flow drawing shows valves at both ends
to isolate the line. The piping line exits the EPG fuel building below ground and has a
swing joint to accommodate movement. The line enters the EPS generator building
sidewall through a 2.1 m long pipe sleeve that protects the pipe and accommodates
movement. AD.
Gap 01954 against Clause 4.5.7.1 It requires valves in piping systems for flammable or
combustible liquids be designed to ... ULC/ORD-C842 ... CAN/ULC-S620 ... ULC-S651.
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The OPG design and construction requirements manual refers to ANSI/ASME code for
valves, not to the ULC standards. The intent of this NFCC clause is to limit the probability
of valve failure. For oil service, the OPG manual requires valves to be class 600 or class
1500, and for all to meet system requirements, i.e., valves on the fuel systems are
designed for combustible liquid service. This alternate compliance meets the intent.
Gap 01957 against Clause 4.11.3.7 It requires before unloading a tank vehicle, .... If the
vents of the receiving or delivery tank are blocked, the transfer must be stopped. The tank
vehicle must not be parked .... The OMs do not discuss checking the vents. The SG tank
vent is on the roof; inspecting it would be a hazard. These tanks have both normal and
emergency vents. If the main vent is plugged, the emergency vent would open and
prevent tank failure or overflow. The EPG tanks are located in a below ground storage
room, and the vent is located on the building roof. There is no emergency vent. If a tank
burst and the fuel ignited, the fuel spill would be contained by the rooms secondary
containment walls. The fire would be contained. Not inspecting the receiving tanks vent
during filling is an AD.
Gap 02084 against Clause 4.3.12.4 It requires storage tanks ... be located in dedicated
storage rooms conforming to Subsection 4.3.13 and located in conformance with Table
4.3.12.4 except ... There are two tanks of 113,000 L each in the storage room of the Fuel
Management Building, so the 200,000 L limit for Class liquids in a protected storage room
of Table 4.3.12.4 is exceeded. The intent is to limit release of vapours in low areas of the
building and limit probability that a tank fire will spread outside of the storage room.
Clause is intended for rooms located inside other occupancies. The EPG Fuel
Management Building is a dedicated to storage and management of fuel. The rooms are
low and have containment for all of the liquid stored. The walls are rated for more than 2
h, and there is an on-site ERT. The excess amount of fuel will not result in a reduction of
safety. Design meets intent to limit release of vapours and limit spread of tank fire.
Gap 02085 against Clause 4.5.7.2 It requires shut-off valves be provided in all ... piping
and pumping systems. Where practicable, these valves shall be outdoors or be
immediately accessible from outdoors. Steel shut-off valves shall be provided at
connections to all aboveground storage tanks, on supply piping ... There are no shut-off
valves on the fill lines adjacent to the SG tanks. The intent is to be able to shut valves in
an emergency. This line at the top of the tank is normally unpressurized. Action to perform
an evaluation the possibility of fuel being siphoned out of the tank in the event of a line
rupture. Additional analysis in [R-95] Appendix A-14 indicates a siphon breaker at the top
of the fill line. The design meets the code.

D506 Control of the Fire Alarm One gap from a review of CAN/CSA N293-2012.
[R-97] System Gap 02134 against Clause 7.2.1.10.1. It requires a display and control centre be located
NK38-REP-00770- in the MCR and in each SCA. The panel operator is required to be able to control the fire
0489244 R000 alarm system without having to leave operators station. The Edwards EST3 display and
control units in the Unit 0 CER and in each of the 5 SCAs cannot be controlled without the
operator having to leave his station. There is annunciation of fire or trouble and zone of
signal origin in MCR. Travel distance and time is insignificant to reach full details on the
panels in the CER. Same for CSCA and USCAs. Design changes would add little or no
functional benefit.

D507 Automatic and Manual One gap from a review of CAN/CSA N293-2012
[R-108] Water-Based Fire Gap 02135 against Clause 7.3.3.5. It requires where automatic sprinkler protection is
Suppression Systems provided, and ... installed below cable trays, they should be ... 0.15 m (6) below bottom of
NK38-REP-00770- the cable tray. A passive heat barrier should be provided that protects the cables and
0489245 R000 remains in place until sprinklers activated. Cable tray protection in DNGS does not satisfy
the additional requirement of a passive heat barrier. Changes to add passive heat
barriers will trigger cost and safety issues. (The only areas that have sprinklers and
sheet metal barriers to protect cable trays are in Units 1 to 4 turbine halls adjacent to
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Column Line A.). The design of the existing cable tray protection meets the intent of
protecting the cables in a fire.

D514 Enclosed Passageways Two (2) gaps from a review of NFPA 20 2013
[R-98] NK38-REP-00770- Gap 02142 against Clause 4.12.1.1.1 It requires fire pump rooms that are not directly
0489252 R000 accessible from the outside be accessible through an enclosed passageway from an
enclosed stairway or exterior exit. New clause to ensure fire pump rooms and equipment
are accessible under actual fire conditions. There are no enclosed passageways leading
to the fire pumps; the DNGS pumps are not separated from the facility. They are backed
up by the adjacent unit fire pumps, and they are installed in areas with limited combustible
loading. The potential for a pump to be exposed to a fire in its unit is minimal. The booster
pumps are not necessary to meet flow and pressure requirements at the hose stations on
Elevation 122.500, where they are located, or below. The ERT can access the pumps.
Gap 02143 against Clause 4.12.2.1.2 It requires the fire-resistance rating of an enclosed
passageway that leads to a fire pump room not be less than the rating of the room. There
are no enclosed passageways and no separation of the pumps from the facility. Refer to
the resolution for gap 02142. Not applicable to DNGS.

D519 Fire Protection and Life Two (2) gaps one from a review of NFCC 2010 and one from NBCC 2010. Both comply.
[R-99] Saving System Gap 02153 against NFCC Clause 2.1.3.8 It states that the commissioning of life safety
Commissioning and fire protection systems must be performed as a whole to ensure the proper operation
NK38-REP-00770- and inter-relationship between the systems. No documents found to confirm integrated
0489257 R000 systems testing of FP and life safety systems. Fixed FP systems inspection, testing and
maintenance (ITM) code compliance report generally confirms that, in periodic testing of
fire alarm systems and FP systems, testing of the integrations between systems is
conducted, i.e.: water supply and distribution systems, deluge and sprinkler system, (foam
FP system is manual system), CO2 FP system, fire and smoke detection, and smoke
purge system. Therefore, while the originally fire protection system commissioning
documentation could not be located, the periodic ITM procedures do sufficiently
demonstrate that the various integrations between systems are routinely tested and
recorded. Complies.
Gap 02168 against NBCC Clause 3.2.4.6 It states that where life safety and FP systems
are installed to comply with NBCC, the commissioning of these integrated systems is
required to be performed as a whole, to ensure the proper operation and inter-relationship
between the systems. DM does not indicate commissioning of integrated systems was
performed as a whole to ensure proper operation and interrelationship between the
systems. Like gap 02153 the ITM procedures demonstrate that the integrations between
systems are tested and recorded. Complies.

D522 Tank Storage of Five (5) gaps from a review of NFCC 2010
[R-109] Combustible Liquids Gap 02156 against Sentence 4.3.1.2.(1) It requires atmospheric storage tanks to be built
NK38-REP-00770- according to a list of 13 codes. This sentence was revised (from 2005 to 2010) to update
0489260 R000 the references to the standards. The SG, EPG and Lube Oil tanks were all constructed to
acceptable standards; however, they are older than those now referenced. The four SG
tanks had recent inspections, with repairs made as required. The EPG and Lube Oil tanks
are deemed to remain fit for continued service with periodic inspection and maintenance.
The tanks comply with the intent of the code
Gap 02157 against Sentence 4.3.3.1.(3) It states that where the clearance below the
base of aboveground tanks exceeds 300 mm, the tank supports are required to have
minimum 2 h fire-resistance rating. The EPG tanks are supported by steel saddles that
are more than 300 mm high. Review of the clearance distances of EPS tanks indicates
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the clearance below the base of the EPS tanks also exceeds 300 mm. The intent is to
protect the tank supports to limit the probability of a premature collapse of tank supports
and spread of fire to adjacent areas. Each tank storage room in the EPS fuel
management building has containment walls 1.85.m in depth providing a volume of
400,000 L. The compartments are separated by 16 concrete walls rated for > 4 hr. The
existing arrangement meets the intent of the code.
Gap 02158 against Sentence 4.4.1.2.(1) It requires every storage tank, piping systems
and sump to be tested and monitored for leaks as per Table 4.4.1.2.A to 4.4.1.2.E, which
establish minimum requirements for the frequency and method for: commissioning testing,
in-service monitoring and testing when a leak is suspected. No documents found to
indicate periodic or any other inspections for any of the SG or EPG tanks, which meet
NFCC 2005. Present predefines and procedures for continuous and periodic in-service
monitoring of SG and EPG tanks and piping systems meet the intent of the latest code
and will be updated to comply with the code when the site operating licence is updated to
reference NFCC 2010.
Gap 02159 against Sentence 4.4.1.3.(2) It states when a leak detection test detects a
leak in a single-walled construction underground storage tank or piping system, the
leaking components or system are required to be replaced or taken out of service. The
SG and EPS fuel piping is single-walled CS pipe. The OPG procedure states a disposition
determines if a degraded buried piping or underground tank is accepted until the next
inspection, repaired or replaced. OPG will revise the procedure to require replacement of
leaking single-walled piping with double walled material. This gap is being addressed
by A/R # 28155459-37.
Gap 02160 against Sentence 4.4.4.1.(3) It requires action if inventory reconciliation for
liquid storage tanks indicates: a) a monthly loss of 0.5% or more from an underground
tank or 1% or more from an aboveground tank, b) three consecutive losses greater than
200 L/day, c) a water level (in the tanks) greater than 50 mm. No documentation indicates
this information is used for inventory reconciliation of the SG and EPG tanks; the
frequency for water tests does not comply, and no documents evaluate this sentence.
OPG inspects fuel level in the SG and EPG tanks weekly for fuel consumption but not
inventory reconciliation. Inventory system is needed to comply with NFCC 2005, as
documented in IRF for D119 gap 00455, and the specific criteria of this sentence will be
met by the system implemented for NFCC 2005.

D523 Piping System Four (4) gaps from review of NFCC 2010
[R-110] Requirements Gap 02161 against Sentence 4.5.4.1.(3) It requires transfer points in piping for flammable
NK38-REP-00770- and combustible liquids be identified as per CPPI 1990 (colour-symbol system). OPG
0489261 R000 colours are different from CPPI 1990 colours. Operations personnel are trained in station
colours, and they escort the vehicles that deliver the liquids and they transfer the liquids
from the tankers into the storage tanks. OPG identifies transfer points with different
colours, but meets intent.
Gap 02162 against Clause 4.5.6.1 It required underground piping be double-walled
except for vents, risers and vertical fill piping. New clause. SG and EPG piping is single-
wall CS. Revise OPG procedure. Require replacement of leaking pipe or components with
double-wall pipe or take them out of service. This gap is being addressed by A/R #
28155459-37.
Gap 02163 against Clause 4.5.7.1 It states: except for hose nozzle valves and emergency
valves, valves in piping systems for flammable or combustible liquids be designed for
temperatures and pressures of those systems and conform to ULC/ORD-C842; hose
nozzle valves conform to CAN/ULC-S620; emergency valves conform to ULC-S651. No
evidence that these standards followed. OPG design and construction manual and
practice specified that valves be to ASME Class 600 or Class 1500 and that all equipment
be designed for the expected service and conditions. Valves on the fuel systems are
designed for combustible liquids. AD.
Gap 02164 against Clause 4.5.7.6.(1) It requires all valves be identified as per CPPI
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1990. Walkdown confirm that ID tags or signs are attached to valves, but the tags are not
colour-coded and do not match the sizes and shapes of CPPI 1990. Like gap 02161,
meets intent.
D524 Fire and Smoke Two (2) gaps from review NBCC 2010.
[R-111] Characteristics of Gap 02165 against Sentence 3.1.5.18.(2) It states optical fibre cables and electrical wires
Electrical Wires and and cables with combustible insulation, jackets or sheathes that are not in totally enclosed
Cables non-combustible raceways may be installed in a plenum in a non-combustible building, if
NK38-REP-00770- their horizontal flame distance is not more than 1.5 m, and average/peak optical smoke
0489262 R000 density not more than 0.15/0.5, as per CAN/ULC-S102.4 (FT6 rating). No evidence the
cables and wires are so tested. Except for MCR, several areas have suspended ceilings,
and rooms are served by ducted supply and return ventilation; the spaces above ceilings
are not used as plenums. In MCR, cables and wires in the ceiling plenum are not in totally
enclosed non-combustible raceways and no documents confirm their fire performance. It
is unlikely that they satisfy FT6 rating. MCR has a manual smoke venting system and self-
contained-breathing-apparatus, so operators can see and breathe until the action to
identify and extinguish fire. Can also transfer plant control and evacuate to SCA. Gap is
acceptable.
Gap 02166 against Sentence 3.1.5.18.(3) It states where totally enclosed non-
combustible raceways are used in a plenum, exposed components of wiring systems with
combustible insulation, jackets and sheathes, including ... are permitted provided their
vertical char is not more than 1.5 m, when tested ... . No evidence that optical fibre cables
and electrical wires are so tested. Same disposition as Gap 02165. Gap is acceptable.

D527 Entrance Walkway One gap from a review of NBCC 2010
[R-100] Smoke Detector Gap 02171 against Sentence 3.2.4.12.(5) It states that smoke detectors in buildings
NK38-REP-00770- required to have a fire alarm system are to have detectors located near the entrance to
0489265 R000 walkways or vestibules. There are no buildings within the scope of this project that are
classified as high buildings, so the need for smoke detectors at vestibules is not
applicable. The only walkway is the bridge between the CSA and the Operations Support
Building. There is a smoke detector in the OSB end, but not in the CSA end. A fire in the
heavily travelled bridge would not go undetected and unreported. CSA area has many
alternate means of egress. Intent is met.

D528 Voice Communication Nine (9) gaps from a review of NBCC 2010
[R-101] Systems Gap 02172 against Sentence 3.2.4.22.(1) It requires voice communication system consist
NK38-REP-00770- of: a) 2-way communication between the central alarm and control facility and the
0489266 R000 mechanical control centre from each floor area, and b) loudspeakers operated from the
central facility. The 2010 revision specifies building with more than 1000 occupants; the
powerhouse PA system doesnt conform to this sentence in NBCC 2005. For the purpose
of life extension, the PA system is generally acceptable. Since, the devices and wiring will
not last 30 years, the replacement system will meet the applicable code requirements.
AD.
Gap 02173 against Sentence 3.2.4.22.(2) It requires the system be capable of
broadcasting prerecorded, synthesized, or live messages with voice intelligibility scale
score of 0.70. Same resolution as for gap 02172.
Gap 02174 against Sentence 3.2.4.22.(3) It requires the system be capable of silencing
the alarm in a single-stage fire alarm system after 30 seconds, while voice instructions are
transmitted. Same resolution as for gap 02172.
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Gap 02175 against Sentence 3.2.4.22.(4) Same capability as gap 02174 for a 2-stage fire
alarm system. Same resolution as for gap 02172.
Gap 02176 against Sentence 3.2.4.22.(5) It requires capability for alarm signal in a 2-
stage fire alarm system to be selectively transmitted to any zone or zones, while
maintaining an alert signal or selectively transmitting voice instructions to any other zone
or zones in the building. Same resolution as for gap 02172.
Gap 02177 against Sentence 3.2.4.22.(6) It requires a 2-way communication be installed
so that emergency telephones are located in each floor area near the exit stair shaft.
Same resolution as for gap 02172.
Gap 02178 against Sentence 3.2.4.22.(7) It requires that where a fire alarm system is
required, a voice communication system be installed where a 2-stage fire alarm system is
installed. Same resolution as for gap 02172.
Gap 02179 against Sentence 3.2.4.22.(8) It requires a voice communication system to
consist of loudspeakers that are: a) operated from the central alarm and control facility (or
a designated area), and 2) except in elevator cars, be designed and located so that
transmitted messages are audible and intelligible in all parts of the building. Same
resolution as for gap 02172.
Gap 02180 against Sentence 3.2.4.22.(10) A 2-way communication system is required to:
- include a means to silence the alarm signal in a single-stage fire alarm system while
voice instructions are being transmitted, but only after the alarm has initially sounded for
30 s.
- include a means to silence the alert signal and the alarm signal in a 2-stage fire alarm
system while voice instructions are being transmitted, but only after the alert signal has
initially sounded for 30 s
- be designed so that the alarm signal in a 2-stage fire alarm system can be selectively
transmitted to any zone or zones while maintaining an alert signal or selectively
transmitting voice communications to any other zone or zones.

D530 Exit Signage Two (2) gaps from a review of NBCC 2010.
[R-102] NK38-REP-00770- Gap 02182 against Sentence 3.4.5.1.(2) It requires every exit sign a) be visible on
0462052 R000 approach to the exit, b) consist of a green pictogram and a white or lightly tinted graphical
symbol meeting the colour specifications in ISO 3864-1, and c) conform to the dimensions
in ISO 7010 for the following symbols ... DNGS does not comply with these new
requirements. All staff is trained or familiar with the safety features; others are escorted by
staff that is trained. Introduction of new signs could introduce inconsistencies and
confusion. The benefit of a complete replacement of existing signs does not justify the risk
and cost. Existing signs adequately comply with the intent and are understood by all
employees.
Gap 02183 against Sentence 3.4.5.1.(3) It requires internally illuminated exit signs be
continuously illuminated, and a) where powered by an electrical circuit conform with CSA
C22.2 No. 141, or b) where illumination is not powered by an electrical circuit, conform
with CAN/ULC-S572. DNGS exit signs are mainly powered by Class II power. Some exit
signs are powered by battery pack units, but no documents confirm they comply with CSA
C22.2 No. 141-10. Some are tritium type exit signs, but no documents confirm they
comply with CAN/ULC-S572-10. Same resolution as for gap 02182.
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3.3.2.2 Discussion of Seventeen Applicable Fire Protection ADs

As noted in Section 3.3.2.1, seventeen applicable ISR issues contain gaps with
acceptable deviations and will be assessed for an aggregate impact.
Issue D041 [R-59] addresses two gaps against NFCC 2005 Clauses 2.1.3.5 and
6.6.1.1 on fire suppression. The gap against Sentences (3) and (4) of Clause 2.1.3.5
was moved for resolution under Issue Form D045. The gap against Sentences (7)
and (8) on CO2 fire suppression was justified by crediting ERT training and actions.
The gap against Clause 6.6.1.1 was reclassified compliant and closed by third party
review.
Issue D044 [R-60] addresses 17 gaps, 15 against clauses in CSA N293-07 and two
against clauses in NBCC 2005 on fire alarm systems. In the IRF, three of the N293-
07 gaps were reclassified as direct compliance and closed; one is not applicable to
DNGS; four were moved for resolution under different issue forms; four were closed
by changes to be completed before the start of refurbishment (tracked by A/Rs), and
three were justified by crediting DNGS design features and established processes
including U0 Operator and ERT training and actions. The two gaps against NBCC
clauses were justified by crediting DNGS design features and fire protection
procedures (U0 Operator and ERT training and actions).
Issue D045 [R-103] contains three gaps classified as ADs about limiting fire
extinguisher use to the ERT. It also identifies the lack of a pre-alarm for CO2
discharge in the EPG fuel building. Minor standpipe non-compliances are also
identified, which are mitigated by the ERT response.
Issue D052 [R-61] contains a gap on fire service valves. The justification credits
DNGS labeling and ERT training.
Issue D222 [R-35] contains three gaps classified as ADs requiring a public address
(PA) system that provides integrated, supervised one-way voice communication
throughout the plant. The alarm signals and voice announcements are to be audible
and intelligible in all accessible locations. This is achieved by a monitoring program
of periodic inspection, testing and maintenance of the PA system. The U0 operator
has a very important role and responsibility in complying with the requirements and
integrating the information on the panels in the MCR and the CER and notifying the
ERT.
Issue D437 [R-66] addresses the gap against N293-07, Clause 6.6.1.3 on 2-hour
emergency lighting for evacuation time. The justification in the IRF credits lights
supplied by Class II power and ERT and Operators being able to perform their
actions using battery-powered flashlights wherever Class II is not available.
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Issue D438 [R-67] addresses the gap against N293-07, Clause 6.6.3 about window
and hatch access regulatory exemptions for fire fighting. The IRF demonstrated that
DNGS complies by having multiple access locations in all buildings to fight fire. The
justification in the IRF credits the ERT, with the necessary training, to know how to
access all fires.
Issue D453 [R-73] is about the gap against NBCC Clause 3.2.4.7 on the lack of an
alarm signal from the fire alarm system for fire department notification. The
justification in the IRF credits ERT and Unit 0 Operator training and prompt action to
phone the Clarington Emergency and Fire Services in place of the NBCC requirement
for an alarm signal from the fire alarm system and water flow-indicating devices.
Issue D454 [R-74] concerns the gap against NBCC Clause 3.2.4.7. The justification
in the IRF credits the U0 Operator and the ERT to notify Clarington about any fire
alarms including the location of the incident.
Issue D455 [R-75] addresses three gaps against NBCC Clauses 3.2.4.9, 3.2.4.18
and 3.2.4.19. The justification in the IRF credits Operator action to: 1) determine the
cause of supervisory signals and make repairs, 2) sound emergency tones and make
voice announcements over the PA system, and 3) post warning signs and limit
access to high noise areas.
Issue D457 [R-77] contains one gap classified as an AD. It requires an air-handling
system to prevent the circulation of smoke. The required prevention of smoke
circulation between floors or fire compartments in the Powerhouse is not satisfied.
Complying with this would result in nuclear safety related requirements for steam-
protected rooms being challenged which is not acceptable.
Issue D472 [R-107] contains five gaps classified as ADs versus clauses of NFCC
2005. It deals with requirements for the Emergency Power Generator (EPG) and
Standby Generator (SG) fuel storage tanks. The justification in the IRF credits the
ERT in addressing of one of the gaps.
Issue D506 [R-97] addresses one gap against CAN/CSA N293-12 Clause 7.2.1.10.1
on control of the fire alarm system. The justification in the IRF credits Operator
action to travel the short distance from the MCR to the CER, CSCA and USCAs to
obtain the full details of the fire alarm system status available on those panels.
Issue D514 [R-98] addresses two gaps against NFPA-20 Clauses 4.12.1.1.1 and
4.12.2.1.2 on enclosed passageways. As per Table 3.3.2.1 the gap against clause
4.12.2.1.2 is not applicable to Darlington since there are no enclosed passageways
leading to fire pumps. For clause 4.12.1.1.1, the ERT is capable of accessing
adjacent unit fire pumps if required.
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Issue D523 [R-110] addresses one gap classified as an AD. It concerns code
requirements for valves in piping systems for flammable or combustible liquids,
including the EPG and SG fuel oil.
Issue D524 [R-111] contains two gaps classified as ADs versus clauses of NBCC
2010. It deals with requirements for optical fibre cables, electrical wires and other
cables with combustible insulation, including some instances in the MCR. The MCR
has other provisions for adequately deal with the presence of smoke and protecting
MCR staff.
Issue D528 [R-101] addresses nine gaps against various clauses in NBCC-2010
dealing with communication systems. For the purpose of life extension, the public
address (PA) system is generally acceptable. Since, the devices and wiring will not
last 30 years, the replacement system will meet the applicable code requirements.
3.3.2.3 Review of Seventeen Fire Protection ADs Collectively for Aggregate

Effects
Like the collective review for the eight Safety ADs in Section 3.3.1.3, the collective
review of the seventeen Fire Protection ADs for aggregate effects was performed by
a similarity analysis technique that assigns Attributes to each AD. Where an
attribute was observed to be common to more than one AD, the ADs were grouped
together for further analysis. The following attributes were considered:
Component or system affected
Potential impact of the AD on that specific component or system
Fire protection function
Technical area affected
Mitigating barriers credited in the IRF for AD disposition.
Table 3.3.2.3 lists the attributes for each of the 17 ADs.
D041 applies to the Emergency Power Supply (EPS) fuel management building and
the fuel storage room. A fire in the EPS is independent of a fire in other areas. This
gap relates to the CO2 fire suppression system, which is independent of the firewater
suppression systems employed in the other areas of the plant. It is related to D472
and D523 in that the Emergency Power Generators (EPGs) and Standby Generators
(SGs) are in the scope of all three. D523 is addressed as the subject valves in fuel
systems are designed for the conditions required and therefore the risk posed by this
AD is very small. Therefore there is no aggregate effect with any other AD. The
mitigation credited in D041 and D472 is via ERT training and actions which are
discussed separately below.
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D044, on the fire alarm system, is related to six other ADs: D045, D453, D454, D455,
D506 and D528, which also pertain to the fire alarm system. The gaps were justified
by crediting Darlington NGS design features and procedures, including U0 Operator
and ERT procedures. Although there are potential aggregate effects between these
five ADs, the effects are negligibly low as:
(i) The fire alarm system design features
(ii) The Darlington NGS fire protection procedures
(iii) The training and performance of the U0 Operator and the ERT
fulfill all of the requirements to prevent and fight fires.
D052 on lack of function information on the fire service valve labels has no effect on
the other sixteen ADs. Therefore it does not contribute to any aggregate effect.
D222 and D528 both deal with the voice communication system (PA) in the station.
The aggregate effect on safety of combinations of these two ADs is very small
because of the U0 operators training, experience and capabilities and the known
effectiveness of OPG governance with the existing fire alarm system and PA system.
D437 on emergency lighting duration being less than 2 hours in areas without Class II
power has no commonality with the other ADs. Therefore it does not contribute to
any aggregate effect.
D438 is about access by the local fire department into buildings to fight fires. D438 is
related to D453, D454 and D455 on notifying the local fire department about a fire
and its location in Darlington NGS. The aggregate effects of these four ADs are also
negligibly low. This assessment is based on the Darlington NGS fire protection
procedures, which require the U0 Operator to phone and notify the fire department
about the occurrence, location and significance of fires at the Darlington NGS site. It
is also based on the capabilities, experience and extensive training of the U0
Operator and the ERT.
D457 on prevention of smoke recirculation is included in the aggregate assessment

because of its potential impact on the steam protected room requirements. However,
these requirements are not affected by the mitigation credited for this issue. Also, this
AD has no commonality with any other AD from an Accident Management
perspective and therefore there is no aggregate impact.
D514 on enclosed passageways credits the ERT to access the firewater pumps and
has no effect on the other ADs. Therefore it does not contribute to any aggregate
effect.
D524 deals with the potential for smoke generation in the MCR and has nothing in
common with the other sixteen ADs. Therefore it does not contribute to any
aggregate effect.
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The following IRFs credit the Emergency Response Team (ERT) and/or the U0
Operator to prevent or extinguish fires:
ERT: D041, D044, D045, D052, D437, D438, D472, D514

Nuclear Operator: D044, D222, D437, D453, D454, D455, D506, D524
Reference [R-81] describes the OPG nuclear fire protection training and qualification
requirements for OPGN Fire Protection. ERT members carry out drills to practice
their emergency response skills, which include fighting fires. Furthermore, the DNGS
policies and programs in OPGs Nuclear Training program [R-46] ensure Operators
are well trained to perform their duties and remain qualified to do so. Finally, OPG
has ensured that rigorous error reduction techniques are used during normal
operation and accident management, as described in OPGs nuclear programs on
Human Performance [R-47] and Nuclear Operations [R-48]. Therefore it is judged
that there is no aggregate impact introduced by the ADs common with the ERT or
Operator action is credited.
In summary, it is concluded that the aggregate impacts of these seventeen Fire

Protection ADs together on OPGs Accident Management capability is acceptable
and, hence, there is no impact on public safety.
Table 3.3.2.3 Aggregate assessment of combinations of the 17 Fire Protection ADs
AD issue Basis in IRF

for
Attribute Accepting
ISR gap (AD)
Component Effect on Fire Technical Mitigation

or System Component Protection Area Credited in
Affected or System Function Affected IRF
D041 [R-59] Special CO2 fire Improper Extinguish Fuel fire ERT training ERT training
Fire Suppression suppression operation or fires EPS fighting and actions and periodic
System Requirements system valves maintenance fuel mgmt OPG error drills
Gap 00415, Item 7 & 8 and controls leading to bldg & fuel reduction OPG error
in EPS fuel fire fighting storage Emergency
No O&M instructions Power and reduction
mgmt bldg & failure room
posted; no marking of fuel storage Standby
valves and controls room Power
D044 [R-60] Fire All fire alarms Fire alarm Provides Fire DNGS DNGS design
Alarm Systems in reactor alert signals fire alert detection design and and fire
Gap: 00535 00536 units and the are delayed alarm processes, fighting
00537 require 2-stage powerhouse Design U0 Operator processes,
alarm; no initial alert changes. and ERT which include
signal in DNGS Operator and
ERT training
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0235 AD AGGREG 0001 01


for
Attribute Accepting
ISR gap (AD)

Gap 00538 requires and actions

small building to have
single-stage fire
alarms; none
Gap 00540 MCR to be
central alarm control
Gap 01880 requires
auto audible alarm
signal 5 min after fire
initiating device, if alert
not acknowledged
D045 [R-103] Fire Fire Small fires, Earlier Fire ERT trained ERT training
Suppression suppression not stopped action to suppression in effective and action
Gaps 00547, 01270, by extinguish use of
01286, 01287, 01846, occupants, fires; extinguisher
01850 and 02112 grow larger; human ERT arrives
identify extinguishers lack of CO2 factors; promptly
limited to ERT only, alarm is not effectivene
so important; ss of Existing
CO2 system in EPG CO2 and
fuel bldg has no pre- standpipe systems
configuration that standpipe
discharge alarm, and systems are
standpipes to be ADs is not a extinguish
concern fires acceptable
with credit
for ERT
action
D052 [R-61] Firewater Delay in Operate Fire fighting DNGS valve DNGS
Identification Signs for service valves identifying fire water labels and labeling of
Fire Service Valves and locating hoses ERT training firewater
Gap 00838 No firewater valves and
function info on valve valves ERT training
label
D222 [R-35] Public PA System Delay to Suppress N/A OPG OPG
Address System suppress fire (alert governance, governance
Gap 00534 for fire, delay to ERT), U0 operator and U0
integrated supervised, evacuate minimize implement a operator
one-way voice consequen monitoring implementatio
communication ces program of n of
periodic monitoring
Gap 01285 audible inspection, program and
and intelligible in all testing and maintenance
accessible areas of maintce of alarm
plant signals and
Gap 01845 audible voice
visual alarm signal messages
devices
Page 84 of 98
0235 AD AGGREG 0001 01


for
Attribute Accepting
ISR gap (AD)

D437 [R-66] 2-Hour Emergency No lighting in Evacuation Human- ERT and Class II
Emergency Lighting lights areas emergency Machine Operators & power, ERT &
Requirement without Interface flashlights Operator with
Gap 01762 Class II flashlights
Emergency lighting to power
have 2 h emergency
power supply
D438 [R-67] Access NPP buildings Modifications Access for Access for There are Full time,
for Fire Fighting for window fire fighting fire fighting multiple trained ERT
Gap 01763 provides openings access and multiple
exemption for NBCC and access locations & access
on window openings hatches; no ERT has locations
and access hatches to documents access to
suppress fire on bldg interior
exemptions
D453 [R-73] Fire Fire alarm Change fire Notify local Fire fighting U0 Operator U0 Operator
Department system and alarm fire dept for back-up phone call training &
Notification water flow to system and prompt prompt action
Gap 01883 send signal to water flow backup
local fire devices support
department Change fire
program
D454 [R-74] Fire Fire alarm Relocate Notify local Fire fighting U0 Operator U0 Operator
Alarm Annunciator annunciators annunciators fire service back-up phones fire training &
Gap 01884 in NPP to building about from local department prompt action
buildings entrances location of fire inform fire
fire department location
D455 [R-75] Fire alarm Design Electrical Fire U0 Operator U0 Operator
Emergency system, changes to supervision detection, actions training,
Notification System audible and fire alarm fire alarm evacuation supervise
Gap 01885 for visual alarm system system, fault detection
electrical supervision devices employee and repairs to
of devices & signals to warnings fire alarm
fire department system
Gap 01888 alarm
signals to be audible
Gap 01889 requires
visual signals where
audible signals are not
effective
Page 85 of 98
0235 AD AGGREG 0001 01


for
Attribute Accepting
ISR gap (AD)

D457 [R-77] Smoke Air-cleaning Smoke Minimize Steam Fan Fan shutdown
recirculation system recirculation consequen Protected shutdown would have
Gap 01887 requires not ces for Room would have negative
air-handling system to prevented employee Reqts negative impact on
prevent smoke safety impact on nuclear
circulation upon a nuclear safety.
Fan safety
signal from duct shutdown
smoke detector not provided
in some
systems
D472 [R-107] Oil Indoor oil EPG tank Prevention, Emergency No Analysis
Storage Tank and tanks could rupture suppress Power and significant confirms
Piping Requirements fire, limit Standby reduction in adequate
spreading Power tank safety safety
Gaps 01947 and Increase
01949 Normal and EPG tanks local fire Sumps and
emergency venting for have no fighting Sumps with leak detection
fuel storage tanks emergency capability level alarms provided
vents in tank and ERT
Gap 01950 Hose fuel pump responds to
stations near storage Reveal and rooms. ERT stop leaks
tank rooms; portable EPG fuel prevent will know and fight fires
fire extinguishers mgmt bldg piping and stop
has tank damage Design of
Gap 01953 Piping leaks before piping is
rooms a fire starts;
above ground where adequate for
enters bldg and shutoff EPG, SG Tank rupture ERT can risks
valves storage oil or overflow fight fire
Tank and
Gap 01957 OMs do tank piping Tank and vent design
not require tank vent vent design meets
Piping is copes with
checking Operating underground concerns
procedure concerns without
change checking
vents
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for
Attribute Accepting
ISR gap (AD)

D506 [R-97] Control of Fire alarm Display and Detection Detection U0 operator U0 operator
the Fire Alarm System system control Firefighting Firefighting can move can move
centre to be from MCR to from MCR to
located in Evacuation Evacuation CER and CER and
Gap 02134 requires a MCR and in Communic- back back
display and control each SCA Communic ation effortlessly effortlessly
centre be located in (not in CER) -ation
the MCR in and each
SCA
D514 [R-98] Enclosed Building Firewater Suppress Suppress Backup Have backup
passageways access to unreliability fire fire pump is in pump; low
Firewater adjacent pump
pump rooms reactor unit. exposure to
Gap 02142 Fire pump In area with fire; Pressure
rooms not directly Need access
to pumps low and flow are
accessible from combustible adequate at
outside be accessible during fire, but
no enclosed loading and pump
via an enclosed low elevation
passageway from passageways
to pumps exposure to without this
stairway or exit way fire. ERT pump. ERT
located inside
the facility can reach can reach
pumps pump during
fire
D523 [R-110] Piping Piping Firewater Prevention, Prevention, OPG OPG design-
System Requirements systems for failure suppress suppress design- construction
Gap 02163 Valves to liquids: for Flammable fire fire construction manual that
be designed for water and for liquid manual that water valves
temperatures and flammable leakage water valves be to ASME
pressures of system; and be to ASME Class 600 or
conform to ULC/ORD- combustible Class 600 or 1500.
C842, etc liquids 1500. Fuel systems
Valve on valves are
fuel systems designed for
are combustible
designed for liquids.
these
liquids.
Page 87 of 98
0235 AD AGGREG 0001 01


for
Attribute Accepting
ISR gap (AD)

D524 [R-111] Fire and Electrical Worker Prevention, Worker Evacuation Evacuation to
Smoke Characteristics wires and safety fire spread, safety in to SCA; SCA; MCR
of Electrical Wires & cables Smoke worker MCR due to MCR has has manual
Cables during safety smoke manual smoke
Gap 02165 Limits on combustion release smoke venting and
wire and cables in a of insulation during venting and self-contained
plenum combustion self- breathing
of insulation contained apparatus for
Gap 02166 Limits on breathing evacuating
wiring in a plenum. apparatus operators
Vertical flame test for
requirement evacuating
operators
D528 [R-101] Voice Voice PA system Evacuation Evacuation The present The present
Communication Communicatio doesnt meet Fire Fire fighting PA system PA system is
Systems n System this code fighting is acceptable for
Worker safety requirement acceptable life extension,
for a 2-way for life but it will not
Gaps 02172 to 02180 voice system extension, last 30 years.
require 2-way system but it will not Replacement
between central alarm last 30 system will
and control centre and years. meet all 9
each floor area Replacemen sentences of
t system will Clause 3. 2.
meet all 9 4. 22
sentences of
Clause 3. 2.
4. 22
3.3.3 Aggregation Between the Safety and Fire Protection ADs
The review in Section 3.2.1.3 identified ECIS and Operator performance as the
common factors for five Safety ADs that pertain to Accident Management. The
aggregate effects of combinations of these ADs is negligible because they have no
effect on the automatic operation of ECIS and the operators are already very
accustomed to the human-machine interface with the ECIS and the annunciation
displays in the MCR. The justifications for these ADs credit the operators training,
experience and capabilities.
Section 3.3.2.3 revealed a commonality of seven ADs regarding the fire alarm
system. The aggregate effects are negligibly low because the Darlington NGS fire
alarm system design features, the Darlington NGS fire protection procedures, the
Page 88 of 98
0235 AD AGGREG 0001 01

training and performance of the U0 Operator and the ERT, very effectively fulfill the
requirements to prevent and fight fires. The aggregate effects of four ADs regarding
the participation of the local fire department in Darlington NGS fire protection are also
negligibly low. This assessment is based on the Darlington NGS fire protection
procedures, which require the U0 Operator to phone and notify the fire department
about the occurrence, location and significance of fires at the Darlington NGS site. It
is also based on the capabilities, experience and training of the U0 Operator and the
ERT.
Given the above there are 13 ADs with Operator action commonality in the Safety
and Fire Protection aspects of Accident Management, namely: D222, D261, D286,
D289, D291, D293, D044, D437, D453, D454, D455, D506 and D524. Based on
OPGs policies and programs for Operator qualification, training and rigorous error
reduction, it is judged that the aggregate impacts of the common factors on OPGs
Accident Management capability is negligible. Hence, there is no impact on public
safety.
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0235 AD AGGREG 0001 01

4 Conclusions
4.1 Seismic
An assessment of the aggregate effects of Seismic-related Acceptable Deviations
was undertaken to determine whether there was a possible impact on the Seismic
Safety barrier. It was concluded that there are no aggregate effects and hence there
is no impact on public safety.
4.2 Pressure Boundary

The gaps considered in the Acceptable Deviations related to pressure boundary
requirements, basically meet the intent of the various code requirements. There is no
combination of pressure boundary-related Acceptable Deviations that shows a
potential for aggregation that could result in an adverse impact on nuclear or public
safety.
4.3 Accident Management

An assessment was undertaken of the Accident Management related Acceptable
Deviations to determine whether there are any aggregate affects. The assessment
concludes that the aggregate effects are acceptably low. Their impact on public
Page 90 of 98
0235 AD AGGREG 0001 01

5 References
[R-1] Issue Resolution Form D029, NK38-REP-00770-0419196 Rev 001,
Compliance with CNSC R-8, 2011 05 15.
[R-2] Issue Resolution Form D064, NK38-REP-00770-0421410 Rev 001, Seismic

Monitoring System Testing, 2011 04 12.
[R-3] Issue Resolution Form D103, NK38-REP-00770-0421810 Rev 000, ASME

Section III - Stress Limits and Stress Intensity Limit Factors, 2011 06 20.

Design Provisions for Concrete Safety-Related Structures, 2011 07 14.
[R-5] Issue Resolution Form D151, NK38-REP-00770-0425557 Rev 001, Standard

Requirements for Fuel Channel Pressure Tube Inspections, 2011 04 06.
[R-6] Issue Resolution Form D160, NK38-REP-00770-0425566 Rev 000, Visual

Inspection Requirements in CSA-N285.5-M90, 2011 04 08.
[R-7] Issue Resolution Form D360, NK38-REP-00770-0460567 Rev 001, Sufficient

Access for Periodic Inspections, 2013 03 26.
[R-8] Issue Resolution Form D361, NK38-REP-00770-0460576 Rev 00, Inspection

of Piping Welds where Radiation Fields are High, 2013 03 26.

of Supports, 2013 03 26.

of Mechanical Couplings, 2013 03 26.
[R-11] Issue Resolution Form D364, NK38-REP-00770-0460575 Rev 00, Ten (10)
Year Periodic Inspection Time Periods, 2013 03 26.
[R-12] Issue Resolution Form D365, NK38-REP-00770-0460572 Rev 00, Timing of

Additional Inspections, 2013 03 26.

Requirements for the Supplementary Periodic Inspection of Fuel Channel
Feeder Pipes, 2016 03 26.
Page 91 of 98
0235 AD AGGREG 0001 01


of the Full Volume of Selected Pressure Tubes, 2013 03 26.
[R-15] Issue Resolution Form D368, NK38-REP-00770-0460570 Rev 00, Extent and
Minimum Sample Sizes of Periodic Inspections of Pressure Tubes, 2013 03
26.

Intervals of Periodic Inspections of Pressure Tubes, 2013 03 26.

Determination of Spacer Locations for PT/CT gap calculation, 2013 03 26.
[R-18] Issue Resolution Form D393, NK38-REP-00770-0460574 Rev 00 Fuel

Channel Inspection Process: Recording and Reporting Laminar Flaws, 2013
03 26.
[R-19] Issue Resolution Form D001, NK38-REP-00770-0417574 Rev 000, Localized

Discontinuity Stresses, 2011 06 16.

Mandatory Rules for Shell-and-Tube Heat Exchangers, 2011 06 01.
[R-21] Issue Resolution Form D021, NK38-REP-00770-0417587 Rev 000, Cleaning

Solution Composition Limits, 2011 05 03.

Nondestructive Testing of Reactor Components, 2011 04 29.
[R-23] Issue Resolution Form D023, NK38-REP-00770-0417589 Rev 000, Material

Properties of Reactor Components, 2011 04 21.

Section III - New Design Requirements, 2011 05 27.

Section III - Pump Design Rules, 2011 07 08.
[R-26] Issue Resolution Form D089, NK38-REP-00770-0421801 Rev 000 ASME

Section III - Thermal Gradients in Valve Design, 2011 08 15.
[R-27] Issue Resolution Form D283, NK38-REP-00770-0426313 Rev 000, Design

Requirements for Steel Safety Related Structures, 2011 05 11.
Page 92 of 98
0235 AD AGGREG 0001 01

[R-28] Issue Resolution Form D284, NK38-REP-00770-0426314 Rev 000, Load

Factors for Metallic Embedded Parts in Safety Related Building Structures,
2011 05 12.

Section III - Thermal Stress Ratchet, 2011 05 27.

Section III - Analysis of Piping Systems, 2011 05 27.
[R-31] Issue Resolution Form D040, NK38-REP-00770-0421330 Rev 001, Human

Factors Design, 2012 11 11.
[R-32] Issue Resolution Form D061, NK38-REP-00770-0421407 Rev 000, Special

Safety System Design, 2011 06 08.
[R-33] Issue Resolution Form D062, NK38-REP-00770-0421408 Rev 000, Post-

Accident Monitoring - Availability, 2013 06 20.

Provisions for Post-Accident Sampling, 2013 02 08.
[R-35] Issue Resolution Form D222, NK38-REP-00770-0425804 Rev 001, Public

Address System, 2013 06 26.

Factors - ECI & ANN System Display, 2012 11 11.
[R-37] Issue Resolution Form D270, NK38-REP-00770-0425844 Rev 001, Analysis

and Validation of Minimum Staff Complement Requirement, 2011 04 21.
[R-38] Issue Resolution Form D277, NK38-REP-00770-0426307 Rev 000, Primary

Heat Transport Coolant Supply for Multi Unit Shutdown, 2011 05 02.
[R-39] Issue Resolution Form D278, NK38-REP-00770-0426308 Rev 001, Turbine

Orientation, 2011 04 04.

Qualification - Post-Event Response and Actions, 2011 07 11.

Factors Implementation, 2012 11 11.
Page 93 of 98
0235 AD AGGREG 0001 01


Factors - ECI & ANN System Labels, 2012 11 11.

Factors - ECI Systems Dynamic Indication, 2012 11 11.

Factors - ECI System Ergonomics, 2012 11 11.

Factors - ECI & ANN System Controls, 2012 11 11.
[R-46] OPG Program, N-PROG-TR-0005 Rev 015, Training, 2012 10 29.
[R-47] OPG Program, N-PROG-AS-0002 Rev 014, Human Performance, 2013 07

12.
[R-48] OPG Program, N-PROG-OP-0001 Rev 005, Nuclear Operations, 2013 12

05.
[R-49] Issue Resolution Form D418, NK38-REP-00770-0471441 Rev 001, Feeders

are Not Classified as Having High Fatigue Factor Due to Feeder Cracking
OPEX at Other Plants, 2013 08 07.

Confirmation is Required That Primary and Secondary Stresses Including
Thermal Expansion Stresses Have Been Evaluated, 2013 05 28.
[R-51] Issue Resolution Form D411, NK38-REP-00770-0460553, Rev 0, Approval of

In-Service Examination Plans, 2013 03 26.
[R-52] Issue Resolution Form D483, NK38-REP-00770-0465064, Rev 0, CSA B51-

09 Hydrostatic Test Concession, 2013 05 18.
[R-53] Issue Resolution Form D488, NK38-REP-00770-0465060, Rev 0, CSA B51-

Hydrostatic Test Concession, 2013 05 18.
[R-54] Issue Resolution Form D489, NK38-REP-00770-0465059, Rev 0, CSA B51

Defective Pipe Concession, 2013 05 18.
[R-55] Issue Resolution Form D485, NK38-REP-00770-0465063, Rev 0, CSA

N285.0-12 Welding Misalignment Concession, 2013 05 18.
Page 94 of 98
0235 AD AGGREG 0001 01


N285.0-12 - Impact Testing Concession, 2013 05 18.

N285.0-12 Radiography of Welds Concession, 2013 05 18.
[R-58] Issue Resolution Form D490, NK38-REP-00770-0465058, Rev 000, Hansen

Quick Connective Couplings Concession, 2013 05 18.
[R-59] Issue Resolution Form D041, NK38-REP-00770-0421331, Rev 002, Special

Fire Suppression System Requirements, 2013 06 25.
[R-60] Issue Resolution Form D044, NK38-REP-00770-0421334, Rev 002, Fire

Alarm Systems, 2013 11 07.
[R-61] Issue Resolution Form D052, NK38-REP-00770-0421404, Rev 02,

Identification Signs for Fire Service Valves, 2013 06 26.
[R-62] Report, NK38-REP-03611-10041 Rev 000, Update of the OPG Darlington

Site Probabilistic Seismic Hazard Assessment for the Darlington Risk
Assessment, 2011 08 05.
[R-63] CNSC Regulatory Standard, S-294, Probabilistic Safety Assessment (PSA) of

Nuclear Power Plants, April 2005.
[R-64] Issue Resolution Form D233, NK38-REP-00770-0425813, Rev 01, Manual

Fire Alarm Pull Stations, 2013 07 12.
[R-65] Issue Resolution Form D298, NK38-REP-00770-0426328, Rev 01, National

Fire Code Storage Room Design Requirements, 2013 06 20.
[R-66] Issue Resolution Form D437, NK38-REP-00770-0462020, Rev 00, 2 hr

Emergency Lighting Requirement, 2013 07 02.
[R-67] Issue Resolution Form D438, NK38-REP-00770-0462021, Rev 00, Access to

Fire Fighting, 2013 05 31.

Combustible Material in Electrical Equipment, 2013 07 02.
[R-69] OPG Report, NK38-REP-03611-10051 Rev 001, Darlington NGS A Seismic

Probabilistic Risk Assessment, 2013 04 26.
Page 95 of 98
0235 AD AGGREG 0001 01


Separation Acceptable Deviations and Alternate Compliance, 2013 06 20.
[R-71] Issue Resolution Form D451, NK38-REP-00770-0462036, Rev 00, Building

Classification and Sprinkler Requirements, 2013 07 02.
[R-72] Reserved for future use.

Department Notification, 2013 07 02.
[R-74] Issue Resolution Form D454, NK38-REP-00770-0462040, Rev 00, Fire Alarm
Annunciator, 2013 07 02.

Emergency Notification System, 2013 07 02.

Requirements of Janitors Closets, 2013 07 02.
[R-77] Issue Resolution Form D457, NK38-REP-00770-0462044, Rev 00, Smoke

Recirculation, 2013 07 02.
[R-79] Issue Resolution Form D462, NK38-REP-00770-0462051, Rev 000, Volatiles

in Basements, 2013 07 02.
[R-80] Issue Resolution Form D463, NK38-REP-00770-0462052, Rev 000, Exiting

Requirements, 2013 06 20.
[R-81] Qualification Description, N-TQD-508-00001 Rev 013, Nuclear Fire Protection

Section Training and Qualification Description, 2012 10 31.
[R-82] Issue Resolution Form D340, NK38-REP-00770-0463395 Rev 000, Valve

Pressure Testing, 2013 04 05.
[R-83] Issue Resolution Form D341, NK38-REP-00770-0463396 Rev 000, Additional

Requirements for Pressure Relief Devices, 2013 04 05.

Anchorage System Requirements in Concrete Containment Structures, 2011
04 28.
Page 96 of 98
0235 AD AGGREG 0001 01


Anchorage System Requirements for Safety-Related Structures, 2011 05 12
[R-86] Issue Resolution Form D414, NK38-REP-00770-0460552 Rev 001, Time

Histories, 2014 01 29
[R-87] Issue Resolution Form D415, NK38-REP-00770-0460551 Rev 001, Soil-

Structure Interactions, 2014 01 29.

Qualification - General, 2013 08 22.

Hazards in Site Evaluations for Nuclear Installations, 2014 02 11.
[R-90] Issue Resolution Form D417, NK38-REP-00770-0477257 Rev 000, ANI

and/or CNSC does not approve procedures as required by N285.4-09 UPD2,
2013 09 03.
[R-91] Issue Resolution Form D564, NK38-REP-00770-0486906 Rev 000, DNGS

Governance Documents and PIP Plans Reference Previous Edition of Code,
2014 02 11.
[R-92] Issue Resolution Form D614, NK38-REP-00770-0490007 Rev 000, DNGS

Governance Documents and the PB Program Manual Reference Previous
Edition of Code, 2014 02 11.
[R-93] Issue Resolution Form D615, NK38-REP-00770-0490947 Rev 000, OPG

Pressure Boundary Document, 2014 02 11.
[R-94] Issue Resolution Form D327, NK38-REP-00770-0490443 Rev 000, Post

Accident Monitoring Availability Documentation, 2013 10 17.
[R-95] Issue Resolution Form D329, NK38-REP-00770-0490445 Rev 000, Special

Safety System Design, 2013 10 17.

Factors Design, 2014 02 11.
[R-97] Issue Resolution Form D506, NK38-REP-00770-0489244 Rev 000, Control of

Fire Alarm System, 2014 01 30.
[R-98] Issue Resolution Form D514, NK38-REP-00770-0489252 Rev 000, Enclosed

Passageways, 2014 01 30.
Page 97 of 98
0235 AD AGGREG 0001 01

[R-99] Issue Resolution Form D519, NK38-REP-00770-0489257 Rev 000, Fire

Protection and Life Saving System Commissioning, 2014 01 30.
[R-100] Issue Resolution Form D527, NK38-REP-00770-0489265 Rev 000, Entrance

Walkway Smoke Detector, 2014 01 30.
[R-101] Issue Resolution Form D528, NK38-REP-00770-0489266 Rev 000, Voice

Communication Systems, 2014 01 30.
[R-102] Issue Resolution Form D530, NK38-REP-00770-0489268 Rev 000, Exit

Signage, 2014 01 30.
[R-103] Issue Resolution Form D045, NK38-REP-00770-0421335, R001, Fire

Suppression, 2013 06 26.
[R-104] Issue Resolution Form D226, NK38-REP-00770-0425808, R003, Control

Room Complex Fire Protection, 2013 06 26.
[R-105] Issue Resolution Form D461, NK38-REP-00770-0462050, R000, Means of

Egress, 2013 07 02.
[R-106] Issue Resolution Form D464, NK38-REP-00770-0462053, R000, Signage

[R-107] Issue Resolution Form D472, NK38-REP-00770-0462061, R001, Oil

Storage Tank and Piping Requirements, 2014 04 17.
[R-108] Issue Resolution Form D507, NK38-REP-00770-0489245, R000, Automatic

and Manual Water-Based Fire Suppression Systems, 2014 01 30.
[R-109] Issue Resolution Form D522, NK38-REP-00770-0489260, R000, Tank

Storage of Combustible Liquids, 2014 01 30.
[R-110] Issue Resolution Form D523, NK38-REP-00770-0489261, R000, Piping

System Requirements, 2014 01 30.
[R-111] Issue Resolution Form D524, NK38-REP-00770-0489262, R000, Fire and

Smoke Characteristics of Electrical Wires and Cables, 2014 01 30.
Page 98 of 98
ONTARIO FiifiiER Report
Document Number:
NK38-REP-03680-10196
N/A
GENERATION Sheet Number: Revision:
N/A R001
Title:
EVALUATION OF SPECIAL SAFETY SYSTEMS ISR ACCEPTABLE DEVIATION ISSUES

FOR AGGREGATE EFFECTS BETWEEN ISSUES
purposes only. No part of this document may be reproduced, published, converted, or stored in any data retrieval system , or
permission of Ontari o Power Generati on Inc.
Evaluation of Special Safety Systems

ISR Acceptable Deviation Issues for
Aggregate Effects Between Issues
NK38-REP-03680-10196-R001
Accepted by:
--~~~~----~~~~~~
() c. -7'; 2 ~ / ;9-Authorized by:
1
Hors P Date mtiaz Malek

Mana er, Nuclear Safety Director, Nuclear Safety
0235 AD AGGREG 0003 01

Title: Evaluation of Special Safety Systems ISR Acceptable Deviation Issues
for Aggregate Effects between Issues
2014 05 28
Prepared By: Peter Wiebe Date
2014 05 28
Reviewed By: Keith Garel Date
2014 05 28
Approved By: M.J. Jansen, P.Eng. Date
VP Engineering
This document is the property of CPUS Limited and OPG. This document may be distributed by OPG to a 3 rd party
Page 1 of 75
0235 AD AGGREG 0003 01

Record of Revisions
Rev Date Description Prepared Reviewed by Approved
No. by by
00 2013 11 06 Issued for Use P. Wiebe R. Ravishankar M. Jansen
01 2014 05 08 Addition of Acceptable P. Wiebe K.C. Garel M. Jansen
Deviations from Emerging
Issues Report
The following new

Acceptable Deviations were
added to the report in the
sections listed:
D329 section 3.6

D564 section 5.20
D607 section 5.21, 5.25
and 6.10
D608 sections 3.11, 4.6
and 5.22
D609 section 5.23
D613 section 5.24
Page 2 of 75
0235 AD AGGREG 0003 01

SUMMARY
This report presents the assessment of the potential aggregate effect of Special
Safety Systems (SSSs) related Acceptable Deviations (ADs), which were identified as
part of the Darlington NGS Integrated Safety Review [R-1] and in certain reviews
(CNSC comments, Fire Code Review) post-ISR.
The assessment objective was to determine if there was an aggregate effect on

public safety when considering:
i. All of the ADs together for each SSS.

ii. All applicable ADs which could affect more than one SSS:
a) Shutdown Systems SDS1 and SDS2
b) Emergency Coolant Injection System (ECIS)
c) Negative Pressure Containment System (NPCS)
Forty Acceptable Deviations were reviewed, many of which contained multiple gaps.
Some of the ADs were applicable to more than one SSS.
The assessment was performed using a strictly qualitative similarity analysis

technique to determine which of the issues could result in an aggregate effect when
considered together. Attributes were assigned to each AD based on a pre-defined
set. When it was concluded that these attributes were common to more than one AD,
these ADs were grouped together. The aggregate effect of these grouped issues
were then assessed. Aggregate assessments were performed for each group of ADs
associated with each of the three special safety systems and for each group of ADs
affecting two or more SSSs.
The results of this assessment concluded that when the Acceptable Deviations with
common attributes were assessed as a group, there were no aggregate effects and
hence no significant impact on public safety.
Page 3 of 75
0235 AD AGGREG 0003 01

Table of Contents
SUMMARY ...................................................................................................................... 3
1 Introduction.............................................................................................................. 5
2 Methodology ............................................................................................................ 5
3 Acceptable Deviations Associated with the Shutdown Systems............................... 6
4 Acceptable Deviations Associated with ECIS ........................................................ 17
5 Acceptable Deviations Associated with the Containment ....................................... 24
6 Assessment of Aggregate effects of ADs across the Special Safety Systems ....... 43
7 Conclusion............................................................................................................. 52
8 References ............................................................................................................ 52
Table 1 - Shutdown Systems Acceptable Deviations ..................................................... 57
Table 2 - ECI Acceptable Deviations ............................................................................. 62
Table 3 Containment Acceptable Deviations .............................................................. 66
Table 4 Acceptable Deviations Common Across Special Safety Systems .................. 72
Page 4 of 75
0235 AD AGGREG 0003 01

1 Introduction
Based on a review of Darlington NGS against modern codes and standards, the
Darlington NGS Integrated Safety Review [R-1] identified gaps. Gaps of similar
scope were consolidated into ISR Issues of similar scope. Based on a review of the
ISR Issues; some were assessed as having minimal impact on public safety and were
classified as Acceptable Deviations (ADs). All of these ADs were reviewed using a
combination of the symptom classification technique and barrier analysis to determine
which engineered or administrative safety-related barriers they could potentially
impact [R-2]. In addition to the original thirty-four ADs assessed in Rev 0 of this
report, this revision of the report (Rev1) addresses an additional six ADs identified in
Darlington NGS Integrated Safety Review Emerging Issues Report [R-42]. The
methodology (common to all ADs in this report) and selection of barriers for the
additional 6 ADs are documented in Reference 41.
This assessment reviews the ADs that have been identified as being associated with
the Special Safety Systems (SSS). The assessment objective was to determine if
there was an aggregate effect on public safety for ADs within a SSS and for all ADs
associated with two or more of the SSSs namely:
(i) Shutdown Systems (SDS) SDS1 and SDS2 together
(ii) Emergency Coolant Injection System (ECIS)
(iii) Negative Pressure Containment System (NPCS)
2 Methodology
This assessment was performed using a similarity analysis technique. A number of
attributes were selected to use as a basis for determining if issues associated with
each AD were similar, i.e. related to each other in some way. The following attributes
were used when reviewing each AD:
Affected Component,
Safety requirement affected, e.g. reliability requirements,
Technical area affected, e.g. Safety Analysis,
Mitigating barriers credited in AD disposition, e.g. system chemistry,
Technical bases used in AD disposition, e.g. risk assessment,
If ADs shared any of these attributes, an aggregate effect assessment was performed
to assess the combined impact of the issues on risk to the public.
The review consisted of the following steps:

1. Review each Acceptable Deviation to collect pertinent information for each
issue, e.g. technical justification, safety significance.
Page 5 of 75
0235 AD AGGREG 0003 01

2. Determine if the AD was applicable to the special safety system being

reviewed, If not it was excluded from further assessment.
3. Identify if the issue was dispositioned in the acceptable deviation form as
having no impact on the safety system. If so it was excluded from further
assessment.
4. Review each remaining AD to identify the applicable attributes above (they
are documented in Tables 1 to 3).
5. Identify the ADs that share assessment attributes, i.e. those that are similar
and could have a compounding effect.
6. For those remaining ADs, determine if there is an aggregate effect when
considered together. This was done for each SSS individually, followed by
an assessment across all applicable SSSs. The methodology used to
perform the review across systems required some additional steps, which are
described in section 6.
7. If there is an aggregate effect, this report would then recommend that such
ADs be evaluated further to assess and identify any practical remedial action.
Sections 3, 4 and 5 provide a summary of the aggregate assessment done for each
group of SDS, ECIS and Containment related ADs. This is followed by Section 6,
which provides an assessment of groups of ADs that affect more than one SSS.
A more detailed description of the methodology can be found in CPUS Report 0235-
AD-AGGREG-0005 Rev 00 [R-41].
3 Acceptable Deviations Associated with the Shutdown

Systems
This section provides a summary of the assessment of the ADs associated with the
Shutdown systems. The following provides a brief description of each AD and the
basis for its selected attributes.
Reference 2 identified thirteen Acceptable Deviations pertaining to shutdown systems

(either or both of SDS1 and SDS2). In addition, five ADs arising from Design Guide
Exemptions and Reference 42 were also added to this review. Table 1 identifies the
information utilized to perform the similarity analysis for the shutdown systems. In
some cases, ADs consist of multiple gaps. The applicable gaps are listed in the
Table below the AD number in bold. The following sections provide a brief
description of each AD and the basis for its selected attributes.
Page 6 of 75
0235 AD AGGREG 0003 01

3.1 D021 - Cleaning Solution Composition Limits

NK38-REP-00770-0417587, Cleaning Solution Composition Limits [R-3], provides the
background information for Acceptable Deviation D021. It also provides the
justification for concluding this code compliance gap is an acceptable deviation. The
issue was assessed as posing a safety significance category of 4.
New CSA standard specified limits for the maximum halogen and sulphur content of
fluids used to clean a number of zirconium reactor components, are lower (i.e. more
restrictive) than those used when these components were produced for DNGS and
were revised to align with high quality commercially available cleaning fluids now
readily available.
This AD has two SDS components included in its scope: reactivity mechanism guide
tubes (for the SDS1 shut-off rods) and the Liquid Injection Shutdown System (LISS)
nozzles. The remaining components covered in the AD are not in the SDSs. The
shut off rod guide tubes and LISS nozzles are different components in fully
independent and diverse systems, i.e. SDS1 and SDS2 respectively. Therefore the
guide tubes were excluded from further assessment.
Table 1 identifies the assessment attributes associated with this AD. The higher
cleaning solution sulphur and halogen concentration limits in place at the time of
construction are not expected to have any significant impact on the material
properties of zircaloy reactor components. To mitigate any potential impact,
moderator water chemistry is specifically controlled for sulphates and halogens. Also,
there is a rigorous Aging Management Plan in place for reactor components.
This Acceptable Deviation does share an assessment attribute with D022, which is
discussed next.
3.2 D022 - Non-Destructive Testing of Reactor Components

NK38-REP-00770-0417588, Non-Destructive Testing of Reactor Components [R-4],
provides the background information for Acceptable Deviation D022. It also provides
the justification for concluding this code compliance gap is an acceptable deviation.
The issue was assessed as posing a safety significance category of 4.
This issue identifies that some of the specifications utilized for NDT of reactor
components during construction of DNGS, were different than the current
requirements of CSA standards. In some cases, records confirming non-destructive
testing and examination requirements that were utilized during the manufacture and
Page 7 of 75
0235 AD AGGREG 0003 01

assembly of zirconium alloy reactor components, could not be located and may differ
from those that would be applied under the current CSA standards.
Table 1 identifies the assessment attributes associated with this AD. Similar to AD
D021, the scope of this issue includes the LISS nozzles and therefore SDS2
functions. Again, the Aging Management Plan is in place to provide mitigation.
Therefore this acceptable deviation does share assessment attributes with another
AD (i.e. D021) and the presence of any compounded affect will be discussed later.
3.3 D029 - Compliance with CNSC R-8

NK38-REP-00770-0419196, Compliance with CNSC R-8 [R-5], provides the
justification for concluding that the code compliance gaps included in the scope are
an acceptable deviation.
This acceptable deviation consists of three separate issues:

(i) Reliability of D2O Storage Tank Level Instrumentation
(ii) Full Seismic Qualification of SDS1
(iii) Test Interval for full functional testing of SDS1/SDS2
The combined safety significance category of the three issues is 3.
3.3.1 Reliability of D2O Storage Tank Level Instrumentation

CNSC Regulatory Document R-8 requires that when manual actuation of a SDS is
credited, the reliability of the instrumentation must be commensurate with the
requirements for availability of the shutdown system. If the action is dependent on
only one signal, that signal shall be a part of the Shutdown System. This issue was
dispositioned on the basis that the credited action required for the applicable design
basis accident, is not to actuate a SDS trip, but rather to initiate a controlled unit
shutdown utilizing process system controls. Therefore, this issue does not impact on
the SDSs and is excluded from further assessment.
3.3.2 Full Seismic Qualification of SDS1

CNSC Regulatory Document R-8 requires that each shutdown system be designed
be such that it is possible to manually actuate each shutdown system from a
seismically qualified area following a design basis seismic event (DBE). SDS1 has
been qualified to ensure the shut-off rods can drop in the core following a DBE.
However, the entire system and all its functions are not seismically qualified, e.g.
withdrawal of the shut-off rods after insertion.
This issue is excluded from further assessment, as there is no requirement to

seismically qualify SDS1 to withdraw the shut-off rods from the reactor. SDS1 is
Page 8 of 75
0235 AD AGGREG 0003 01

seismically qualified to trip the reactor when needed following a design basis
earthquake.
3.3.3 Test Interval for Full Functional Testing of Shutdown Systems

CNSC Regulatory Document R-8 requires a testing interval of less than 2 years for
the Shutdown Systems (SDS). OPG has received a concession from the CNSC to
test the full system every three years to align with the current three year maintenance
outages at OPG.
Table 1 identifies the assessment attributes associated with this AD. The attribute
affected is SDS reliability. SDS actual reliability could potentially be impacted by the
longer test interval. CNSC acceptance of this test interval was based on an OPG
assessment that demonstrated that predicted future unavailability of SDS1 and SDS2
would not be adversely impacted and also that rigorous in-service testing and
maintenance programs assure continued reliability.
As shown in Table 1, this acceptable deviation does not share any of its assessment
attributes with another AD. Therefore it does not to be included in an aggregate
assessment.
3.4 D032 - Trip Parameter Acceptance Criteria - CNSC G-144

NK38-REP-00770-0419199, Trip Parameter Acceptance Criteria CNSC- G144 [R-
6], provides the background information for Acceptable Deviation D032. It also
provides the justification for concluding this code compliance gap is an acceptable
deviation. The issue was assessed as posing a safety significance category of 3.
CNSC G-144 requires trip parameter acceptance criteria in the licensee's safety
analysis to demonstrate that direct or consequential reactor fuel failures or pressure
tube failures due to any fuel failures are precluded. The trip parameter acceptance
criteria include the following:
1. The primary trip parameter predefined limit on each shutdown system
should be selected so as to prevent the onset of intermittent fuel sheath
dryout; and
2. The backup trip parameters predefined limit on each shutdown system
should be selected so as to prevent:
a) Fuel sheath temperature from exceeding 600C, and
b) The duration of post-dryout operation from exceeding 60 seconds.
DNGS safety analysis does not specify trip parameter acceptance criteria from CNSC
G-144, e.g. for a limiting loss of flow event, the trip parameter acceptance criteria
from CNSC G-144 is not met.
Page 9 of 75
0235 AD AGGREG 0003 01

Table 1 identifies the assessment attributes associated with this AD. The attribute
associated with this AD is nuclear safety analysis. The primary justification for the
acceptability of this gap is that the safety analysis criteria documented in the
Darlington NGS safety report is met, which precludes both fuel sheath and fuel
channel failure. Also, by utilizing an alternate industry accepted safety analysis
methodology, i.e., the best estimate uncertainty analysis (BEAU), it has been shown
that the G-144 criteria are met. Justification using risk assessment is not required,
since the issue dose not result in core damage and therefore does not impact on the
results of risk assessment.
As shown in Table 1, this acceptable deviation does not share any of its assessment
attributes with another AD. Therefore it does not to be included in an aggregate
assessment.
3.5 D060 and D305 - Shutdown System Diversity

NK38-REP-00770-0421406, Shutdown System Diversity [R-7], provides the
justification for concluding that this code compliance gap is an acceptable deviation.
NK38-REP-00770-0456340, Shutdown System Diversity [R-37], provides the

The issue was assessed as posing a safety significance category of 4. This AD was
raised to document two additional design guide exemptions that were not included in
the scope of D060. Given these two ADs address the same issue they were grouped
together in Table 1 and assessed together.
CSA standards require that within the constraints of equal quality and reliability,
similar components in the two shutdown systems should be supplied by different
manufacturers. Furthermore, where a choice is possible, such components should
employ different principles of operation. D060 identifies that a common manufacturer
is used for the Shutdown Systems trip computer termination modules, control
equipment panels, and flux detectors for both SDS1 and SDS2.
D305 identifies that a common manufacturer is used for (i) the SDS1 and 2 flux
detector amplifiers and (ii) the SDS1 and 2 ion chamber amplifiers.
Table 1 identifies the assessment attributes associated with these two ADs. The
attribute associated with this AD is the requirement for SDS1 and SDS2 to be
Page 10 of 75
0235 AD AGGREG 0003 01

independent and diverse. The primary justification for the acceptability of this gap is
that the vendor for these components had approved procedures in place to ensure
independence of manufacturing processes applied to SDS1 and SDS2.
As shown in Table 1, these two acceptable deviations do share assessment attributes

with AD D310. The common attribute is Independence and Diversity. Therefore
these ADs will be included in the aggregate assessment.
Also, although not associated with another distinct AD, there is a potential aggregate
effect within D305. Both the flux detector and ion chamber amplifiers in SDS1 and
SDS2 are addressed within the scope of this AD. The SDS flux detectors are used in
the SDS NOP trips and the ion chambers in the SDS log rate trips. These two trips
are independently credited in safety analysis. Table 1 identifies that the barrier used
for each component type is the use of strict vendor quality requirements. The same
OPG requirements were adhered to by both independent vendors (Scintrex and
Garrett). Therefore with the use of strict vendor quality requirements and two
independent vendors, an aggregate effect does not exist.
3.6 D061 - Special Safety System Design

NK38-REP-00770-0421407, Special Safety System Design [R-8], provides the
Reference 42 identified AD D329, which is documented in NK38-REP-00770-

0490445, Special Safety System Design [R-43]. It is a duplicate of D061, which
arose from the review of a different code with the same requirement. Therefore,
since it is already addressed by D061, it is not discussed further in this section.
CSA N290.6-M82, "Requirements for Monitoring and Display of CANDU Nuclear

Power Plant Status in the Event of an Accident" requires that: "For those design basis
event(s) comprising a process failure coincident with the assumed unavailability of a
Special Safety System, there shall be at least one redundant information chain
outside of the assumed unavailable Special Safety System". Evidence demonstrating
that DNGS meets this requirement could not be found.
The set of Safety Report design basis accidents does not include an accident in
which a process failure occurs coincident with the failure of a shutdown system.
Therefore this issue does not apply to the shutdown systems and it is excluded from
further assessment.
Page 11 of 75
0235 AD AGGREG 0003 01

3.7 D245 - Shutdown System Requirements for Start-up Instrumentation (SUI)

NK38-REP-00770-0425823, Shutdown System Requirements for Start-up
Instrumentation [R-9], provides the background information for Acceptable Deviation
D245. It also provides the justification for concluding that this code compliance gap is
an acceptable deviation. The issue was assessed as posing a safety significance
category of 4.
CSA-N290.4 states that because the SUI may be related to shutdown systems, it may
also have requirements imposed on it by CSA N290.1. The Code review identified
that SUI is in general compliance with the reactor regulating system requirements.
However, the Code review found that if SUI is considered to be a part of shutdown
system functionality, it may not meet all requirements of CSA N290.1, (such as
separation, environmental and seismic requirements).
Table 1 identifies the assessment attributes associated with this AD. The attributes
potentially affected are in the areas of environmental and seismic qualification and
separation between shutdown system independent channels. This issue is different
than that associated with D060 which deals with independence and diversity between
SDS1 and SDS2 and not separation between SDS channels. No other applicable
ADs are associated with environmental and seismic requirements.
The primary justification for the acceptability of this gap is time at risk, i.e. that the SUI
interfaces with the shutdown systems for a limited time during reactor start-up. Also
credited, are its design redundancy, high reliability and its fail-safe nature.
Administrative controls are continuously adhered to during its use.
As shown in Table 1, this acceptable deviation does share assessment attributes with
ADs 306 and 310. The common attributes are Separation requirements and Design
Redundancy. Therefore the aggregate assessment will address these.
3.8 Human Factors Acceptable Deviations

References 10 through 16 document the Acceptable Deviations pertaining to human
factors issues, primarily related to the ECI system. Although the titles of these ADs
reflect they pertain to the ECI system, the assessment in Reference 2 concluded they
were of a more general nature and therefore could pertain to all four special safety
systems. These ADs were reviewed in detail, however, are not discussed in depth as
part of the similarity analysis. These six ADs were screened out on the basis that
they have no impact on public safety. For further discussion see section 4.3.
Page 12 of 75
0235 AD AGGREG 0003 01

Also related to Human Factors, Reference 42 identified AD D608, which is

documented in NK38-REP-00770-0488753, Human Factors Design [R-44]. This AD
is discussed in section 3.11.
3.9 D306 Instrumentation and Control Separation Requirements

NK38-REP-00770-0457418, Instrumentation and Control Separation Requirements
[R-17], provides the background information for Acceptable Deviation D306. It also
provides the justification for concluding that the contained code compliance gaps
pose an acceptable deviation. The issues were assessed as posing a safety
significance category of 4. This AD consists of eight separate gaps, four of which
apply to the shutdown systems (gaps 01602, 01603, 01604 and 01609). Four gaps
apply to the ECI system (gaps 01602, 01611, 01612, 01618), which will be discussed
in section 4. Two gaps apply to the containment system (gaps 01611, 01612) and
will be discussed in section 5. One gap is not applicable to the AD and is not
discussed further in this analysis (gap 01610).
Table 1 identifies the assessment attributes associated with this AD for the shutdown
systems. All four gaps pertain to instrument tubing for redundant SDS trip channels,
which are not separated to the degree required in applicable regulations and OPG
governance. Four reactor trips in SDS1 and SDS2 are affected by the issue.
The primary justification for the acceptability for all of these gaps is physical
protection has been provided for the affected instrument tube runs. This assures they
are not physically damaged during normal operation, or as a result of a design basis
accident, e.g. jet impingement due to a pipe break.
As shown in Table 1, this acceptable deviation does share some of its assessment
attributes with other ADs (D245 and D310). The common attributes are Separation
requirements and Design Mechanical Protection and, therefore, AD D245 will be
addressed in the aggregate assessment.
3.10 D310 - SDS1 and SDS2 Steam Generator Feed Line Pressure Trip
NK38-REP-00770-0457422, SDS1 and SDS2 Steam Generator Feed Line Pressure
Trip [R-18], provides the background information for Acceptable Deviation D310. It
also provides the justification for concluding that the contained code compliance gap
poses an acceptable deviation. The issue was assessed as posing a safety
significance category of 4.
Nuclear Safety Design Guide NK38-DG-03650.3 [R-38] requires that systems be

protected from the effects of postulated pipe ruptures if they are credited to perform a
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function in the safety analysis. This requirement must be met for each shutdown
system independently. The diversity for both shutdown systems cannot be claimed in
all cases during a feed-water pipe whip event.
Table 1 identifies the assessment attributes associated with this AD. The issue is
associated with instrument tubing in both SDS1 and 2 potentially affected by pipe
whip following a feedwater failure. The requirement for separation between SDS1
and 2 is potentially challenged.
The primary justification for the acceptability of this gap is physical protection being
provided for the affected instrument tube runs. This assures they are not physically
damaged during normal operation or as a result of a design basis accident, e.g. jet
impingement due to a pipe break. Also design redundancy within the automatically
actuated channels of the SDS1 and 2 trips is also cited.
As shown in Table 1, this acceptable deviation does share some of its assessment
attributes with other ADs (D060, D245, D305 and D306). The common attributes are
Independence and Diversity Requirements, Design Mechanical Protection and
Design - Redundancy. Therefore since this acceptable deviation does share
assessment attributes with other ADs, the presence of any compounded affect will be
discussed in section 3.12.
3.11 D608 Human Factors Design

NK38-REP-00770-0488753, Human Factors Design [R-44], provides the background
information for Acceptable Deviation D608. It also provides the justification for
concluding that the contained code compliance gap poses an acceptable deviation.
CSA Standard, N290.0-11, "General Requirements for Safety Systems of Nuclear

Power Plants" [R-45], requires that the human-machine interfaces for the safety
systems be addressed during the design process to provide operators with necessary
and appropriate information in a usable format that is compatible with the necessary
decision-making and action times.
Reference 44 documents that Darlington had adequate human factors practices in

place during the original design of the station. This together with the current robust
human factors processes in the Engineering Control Program, results in this AD
having a negligible impact on public safety. AD D608 was screened out on this basis.
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3.12 Assessment of Shutdown Systems Acceptable Deviations Sharing the Same

Attributes
As reviewed above, the shutdown systems Acceptable Deviations that share

assessment attributes and therefore are similar are:
1. D021 and D022 associated with the SDS2 LISS nozzles

2. D060, D305 and D310 associated with Independence and Diversity
3. D245 and D310 associated with Design - Redundancy
4. D245 and D306 associated with Separation Requirements
5. D306 and D310 associated with Design Mechanical Protection
The potential aggregate effect of these similar issues is reviewed to determine if

together they could have an adverse effect on public safety.
Section 6 discusses the assessment of aggregate effect of groups of ADs across two
or more SSSs.
3.12.1 D021 and D022 SDS2 LISS Nozzles

These two ADs deal with the SDS2 LISS nozzles material handling and NDE
requirements during procurement and construction. The issues are on the same
component, i.e. LISS nozzles and the technical justification used to assess the AD is
also shared, i.e. the presence of an Aging Management Plan used to assure
continued fitness for service.
Both issues independently have some limited potential to lead to material

degradation. However as described above, the assessments performed for each
concluded that the likelihood of these issues affecting LISS nozzle material strength
was very low and therefore each posed a safety significance of 4, i.e. the lowest on
the scale.
The effectiveness of the primary barriers in place, i.e. the aging management plan
and system chemistry control are not challenged given the two issues together.
Having a robust Reactor Components & Structures Life Cycle Management Plan
addressing relevant aging mechanisms, assures fitness for service of these
components for life extension of the Darlington units.
3.12.2 D060, D305 and D310 - Independence and Diversity

These three ADs share the Independence and Diversity characteristic. D310 pertains
to the potential impact of a feedwater failure on both SDS1 and SDS2 due to pipe
whip. D060 and D305 pertain to the same issue, i.e. use of a shared manufacturer to
supply SDS equipment. Given the difference in how these ADs could have an impact
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on the Independence and Diversity requirement, i.e. material fabrication and the
impact of a design basis accident, there is no compounded effect due to D310 when
assessed together with D060 and D305.
D060 and D305 are more directly related in that they both pertain to use of a shared
manufacturer. The SDS components covered in the scope of the two ADs are
different. D060 addresses the Shutdown Systems trip computer termination modules,
control equipment panels, and flux detectors for both SDSI and SDS2. D305
addresses the SDS1 and 2 flux detector amplifiers and ion chamber amplifiers. The
impact of the two ADs together is a resultant increase in the scope of SDS
components subjected to the rigorous QA program used by the specified
manufacturers. However, it is judged that the OPG Quality Assurance and
independent inspection requirements, ensured that the independence requirements
were met, even with the small increase in scope of components addressed in these
two ADs.
3.12.3 D245 and D310 Design Redundancy

These two ADs share the Design -Redundancy characteristic used in the similarity
analysis. D245 pertains to reactor start-up instrumentation (SIU). Part of the
justification used in this AD is the redundancy in SIU channels provided by design.
D310 considers the redundancy in SDS1 and 2 channels, in justifying that the
impacts of pipe whip following a feed water failure are acceptable. Since the credited
redundancy is on different systems, i.e. SDS and SIU, there is no compounded
impact of these two ADs. Also, a feedwater failure is not credible when start-up
instrumentation is installed and used during approach to critical operation.
3.12.4 D245 and D306 Separation Requirements

These two ADs are similar as they both pertain to the Separation Requirement
imposed on channels of shutdown systems and start-up instrumentation (SIU) (being
related to the SDS). D245 pertains to reactor SIU and the degree to which SIU
channels meet separation requirements, i.e. the physical separation between SIU
channels. D306 deals with the proximity of instrument tubing runs on independent
channels and the resultant ability to meet separation requirements in SDS1 and
SDS2 trips following design basis accidents. First, the SDS and SIU are related but
different systems. Also, the SIU does not contain process trips contained in SDS1
and 2, e.g. moderator level. AD D306 only pertains to SDS process trips which
directly use instrument tubing in their safety function. Given these differences in the
issues, there is no compounded effect of these two Acceptable Deviations.
3.12.5 D306 and D310 associated with Design Mechanical Protection

These two ADs pertain to the potential for instrument tubing associated with SDS1
and 2 trips not being separated as required and the potential for damage due to their
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proximity to each other. In both ADs, mechanical protection is provided to ensure

there is a barrier to prevent damage to redundant SDS channels.
The trips potentially affected are:

Pressurizer level
Moderator high level
Moderator low level
Steam Generator Feedwater low pressure
In each individual case the AD states that the mechanical protection provided for the
subject instrument tubes both inside and outside containment, ensures the probability
of unsafe failure tubing is very low following a design basis accident. Therefore, the
probability of multiple failures of additional channels is an extremely low probability
event. Therefore there is no compounded impact when considering these two similar
Acceptable Deviations.
3.13 Conclusion
The similarity analysis performed for the sixteen shutdown systems Acceptable
Deviations, identified five groups of ADs that shared assessment characteristics and
therefore could result in some compounding effect when assessed together. The
aggregate effect of these five groups was independently assessed and in each case
determined to have no impact on public safety.
4 Acceptable Deviations Associated with ECIS

Reference 2 identified nine Acceptable Deviations pertaining to the Emergency
Coolant Injection (ECI) system. In addition, four ADs arising from Design Guide
Exemptions and Reference 42 were also added to this review. Table 2 identifies the
information utilized to perform the similarity analysis for the ECI system. The
following provides a brief description of each AD and the basis for its selected
attributes.

The issue was assessed as posing a safety significance category of 3. Reference 2
also associated this AD with the shutdown systems, but as described above was
found to be not applicable.
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Power Plant Status in the Event of an Accident" requires that: "For those design basis
event(s) comprising a process failure coincident with the assumed unavailability of a
Special Safety System, there shall be at least one redundant information chain
Unlike for shutdown systems this issue is applicable to ECIS since a process system
failure and loss of ECIS is a design basis accident addressed in the Safety Report.
associated with post-accident monitoring requirements. Post-accident monitoring is a
critical function required for event diagnosis and for identifying the need for credited
operator actions following a design basis accident.
The justification for the acceptability of this gap is that the unavailability of a special
safety system does not imply that the monitoring equipment in that SSS is also
unavailable. Also, considering the redundancy provided in the design, the existing
post-accident monitoring capability is sufficient.
Table 2 shows this acceptable deviation does share assessment attributes with AD
D307. The common attribute is Design Redundancy. Therefore it will be included
in the aggregate assessment for ECIS.
4.2 D071 - Coverings and Coatings within the Containment System

NK38-REP-00770-0421665, Coverings and Coatings within the Containment System
provides the justification for concluding that this code compliance gap is an
acceptable deviation. The issue was assessed as posing a safety significance
category of 4.
CNSC regulatory Document RD-337 requires that the coverings and coatings for
components and structures within the containment system shall be carefully selected
and their methods of application specified, to ensure fulfillment of their safety
functions and to minimize post-accident interference with other safety functions or
accident mitigation systems. In addition, the choice of materials inside containment
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should take into account the impact of post-accident containment conditions that may
affect containment performance and integrity and fission product release. There is no
evidence that applicable Darlington design documentation or construction
specifications considered the impact of post-accident containment conditions on the
performance on ECIS recovery operation.
Table 2 identifies the assessment attributes associated with this AD. The issue has
the potential to impact on the effectiveness of ECIS recovery and therefore long term
fuel cooling. Use of inappropriate materials inside containment can result in
inadequate NPSH available at the ECIS recovery pump suction as a result of
excessive pressure drop across ECIS strainers caused by plugging with liberated
material. The justification for the acceptability of this gap consists of suitable design
and construction specifications, a periodic inspection program to assure the specified
materials and coatings are used and thermal hydraulic analysis used to demonstrate
acceptable design margin. Lastly, a design modification was made to provide greater
strainer area to account for potential a higher pressure drop post-accident.
Table 2 shows this acceptable deviation does not share any of its assessment
attributes with another AD. Therefore it does not to be included in the aggregate
assessment.

factors issues, primarily related to the ECI system. Others are more general in
nature, e.g. annunciation colours and ergonomic issues. These gaps were reviewed
in detail, however, are not discussed in detail as part of the similarity analysis.
The issues specific to ECIS identified in the AD are of low risk significance and of little
relevance to the ECI system, being normally poised and not operating. In order to
prevent the type of human errors relevant to this issue, OPG employs rigorous error
reduction techniques. Notable examples are use of the self-check principle and pre-
job/post-job briefs. Therefore, the ADs have no impact on the ECI system and were
excluded from further assessment.

is discussed in section 4.6 below.
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This AD consists of eight separate gaps, four of which were addressed above for the
shutdown systems (gaps 01602, 01603, 01604 and 01609). Four gaps apply to the
ECI system (gaps 01602, 01611, 01612, 01618). Two gaps apply to the containment
system (gaps 01611, 01612) and will be discussed in section 5. One gap is not
applicable to the AD and is not discussed further in this analysis (gap 01610).
Table 2 identifies the assessment attributes associated with this AD for the ECI
system. Three gaps (01618, 01602 and 01612) pertain to instrument tubing for
redundant ECI channels, which are not separated to the degree required in applicable
regulations and OPG governance. The justification for the acceptability of these gaps
is physical protection has been provided for the affected instrument tube runs. This
assures they are not physically damaged during normal operation, or as a result of a
design basis accident, e.g. jet impingement due to a pipe break.
Gap 01611 pertains to use of common pressure transmitters (PTs) for the generation
of ECI initiation signals and for a HT pump trip. A HT pump trip is initiated to ensure
pump seal and containment integrity following a LOCA. The justification for the
acceptability of this gap is:
(i) The degree of redundant channels and pressure transmitters provided,
i.e. there are four pressure transmitters provided for each of the
functions.
(ii) These redundant channels will also act automatically if required.
(iii) Physical separation is also provided, as the PTs are located in different
rooms.
(iv) In addition, heat transport system conditions predicted in the safety
analysis are not expected to lead to pump seal failure and loss of
containment integrity. This has been validated by HT pump tests.
As shown in Table 2, this Acceptable Deviation does share some of its assessment
attributes with AD D061. The common attribute is Design Redundancy.
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4.5 D307 Electrical Separation Requirements

NK38-REP-00770-0457419, Electrical Separation Requirements [R-20], provides the
justification for concluding that the contained code compliance gaps pose an
acceptable deviation. The issues were assessed as posing a safety significance
category of 4. This AD consists of eleven separate gaps, four of which apply to the
ECI system (gaps 01598, 01601, 01607, 01617). Four gaps apply to the containment
system (gaps 01598, 01605, 01607, 01608) and will be discussed in section 5. Five
gaps were determined to be not applicable to the special safety systems and were
excluded from further assessment (gaps 01596, 01597, 01599, 01600 and 01606).
Table 2 identifies the assessment attributes associated with this AD for the ECI
system. Each gap is briefly discussed.
Gap 01598:
This gap pertains to the mixing of channels in multi-conductor cables between the
programmable controllers (PC) and CDF, resulting in the inability to meet separation
requirements. The primary justification for the acceptability of this gap is that a failure
in the cable affecting a division control, will also affect the wires which interrogate the
output contact status of another division controller, but will not inhibit or prevent
operation of the other division. In the case of triplicated systems, i.e. the special
safety systems, the other two channels would detect a failure of the third and operate
as if was a genuine channel initiation, i.e. it is fail safe. Therefore, Design Fail Safe
Practices is the barrier used in the assessment.
Gap 01601:
This gap arises as a common fibre-optic loop was used for Group 1 and Group 2
channels K, L and M, which is in non compliance with applicable OPG governance
and regulations and results in the inability to meet separation requirements. The
existing configuration allows testing of the ECIS transmitters and the simulation of the
two out three signals to open the injection valves utilizing a field monitor. During
normal operation this system is unavailable. Testing of the transmitters and the two
out of three signals can only be carried out when the field monitor is connected. Loss
of a fibre-optic test loop does not affect the integrity of the system. During testing
Group 2 controls are not affected by faults on the fibre-optic network. Therefore
Design Testing Features and Administrative Practices are the main barriers used in
the assessment.
Gap 01607:
This gap arises as odd and even fibre-optic Group 1 buffered cables run in odd and
even Group 2 cable trays between the EPS Control Room and the Powerhouse,
which is in non-compliance with OPG governance and results in the inability to meet
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separation requirements. The primary justification for running the fibre-optic cables in
Group 2 cable trays are because fibre-optic cables do not carry current resulting in no
impact on other cables. Therefore, Design Diverse Materials is the barrier used in
the assessment.
Gap 01617:
This gap pertains to supplying both odd and even power to the ECI branch
interconnect valves and results in the inability to meet separation requirements.
Circuits are properly fused to ensure the intent of the separation requirement is met.
Therefore, Design Electrical Practices is the barrier used in the assessment.
As shown in Table 2, acceptable deviation D307 shares some of its assessment

attributes with other ADs (D061 and D306). The common attributes are Separation
Requirements and Design Redundancy. Lastly, given the diverse nature of the four
separate gaps in this AD on Electrical Separation Requirements and that barriers
credited in each gap are different, the aggregate assessment does not address the
potential compounding affect of these four gaps in D307.

This Acceptable Deviation was discussed in section 3.11 for the shutdown systems.
The issue is generic in nature and applies to all the special safety systems.. As per
section 3.11, AD608 was screened out.
4.7 Assessment of ECI System Acceptable Deviations Sharing the Same Attributes
As reviewed above, the ECI system Acceptable Deviations that share assessment
attributes and therefore are similar are:

together they could result in any adverse effect on public safety.
4.7.1 D061 and D306 - Design Redundancy

analysis. D061 pertains to the Post-Accident Monitoring system (PAMS). Part of the
justification used in this AD is the redundancy in PAMS parameters and the ECI
system provided by design. D306 pertains to use of common pressure transmitters
(PTs) for the generation of ECI initiations signals and for a HT pump trip. Equipment
which could be common between these two ADs is the HTS low pressure parameter,
as it is credited in both issues and the therefore the redundancy barrier could be
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challenged. However, there are additional HTS pressure indications available that
could be used for operator post-accident monitoring which have not been credited in
these ADs, i.e. those associated with both shutdown systems SDS1, SDS2 and the
HTS process measurements. In addition, there is also redundancy provided within
the ECI system. Therefore, when considering these two ADs together there is no
threat to the credited Design - Redundancy barrier and therefore there is no impact
on public safety.
4.7.2 D306 and D307 - Separation Requirements

These two ADs are similar as they all pertain to the Separation Requirement imposed
on channels of the ECI system. D306 pertains to Instrumentation and Control
Separation requirements, dealing with the proximity of instrument tubing runs on
independent channels and the resultant ability to meet separation requirements.
D307 pertains to Electrical Separation Requirements dealing with cable runs to
various pieces of equipment.
Not completely satisfying separation requirements, has the potential to impact on the
ability to meet ECI reliability requirements for the following reasons:
The impacted specific ECI functions are different. The affected functions are:
Channel L and M, ECI recovery functions
The moderator high level conditioning signal for an in-core LOCA
The reactor building high pressure conditioning signal
The ECIs branch interconnect injection valves.
All of these functions are different and therefore the presence of them together
would not introduce an additional potential crosslink which could impact on
overall system reliability.
The effectiveness of the barriers credited in the Acceptable Deviation

assessment.
The safety significance of these two ADs was assessed as having the lowest
level.
Given the above, there is no compounded effect of these two Acceptable Deviations.
The aggregate effect of any applicable ECI system ADs when reviewed with other
SSSs is discussed in section 6.
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4.8 Conclusion
The similarity analysis performed for the ECIS Acceptable Deviations, identified two
groups of ADs that shared assessment characteristics and therefore could result in
some compounding effect when assessed together. The aggregate effect of these
groups was independently assessed and in each case determined to have no impact
on public safety.
5 Acceptable Deviations Associated with the Containment

This section provides a summary of the assessment of the ADs associated with the
Containment System.
Reference 2 identified eighteen Acceptable Deviations pertaining to the containment

system. In addition, twelve ADs arising from Design Guide Exemptions, Reference
42 and other code reviews were also added to this assessment. Table 3 identifies
the information utilized to perform the similarity analysis for the containment system.
The following provides and brief description of each AD and the basis for its selected
attributes.
5.1 D010 - Changes to Examination and Testing Requirements for Concrete

Containment Structures
NK38-REP-00770-0417578, Changes to Examination and Testing Requirements for
Concrete Containment Structures [R-21], provides the background information for
Acceptable Deviation D010. It also provides the justification for concluding that this
code compliance gap is an acceptable deviation. The issue was assessed as posing
a safety significance category of 4.
The issue is that some of the requirements for testing concrete that were established
by CSA N287.5-M81-CAN3 during Darlington construction, have not been shown to
satisfy CAN/CSA- N287.5-93, due to the lack of available compliance documentation.
Also, some new requirements related to concrete testing introduced by CSA-N287.5-
93 have not yet been incorporated in OPG governance.
associated the Darlington containment structures, including the vacuum structure.
The justification for the acceptability of this gap is that during construction, the
requirements in place for tests and quality control procedures ensured that the
concrete used in the as-built structures met the original design requirements. Also,
ongoing fitness for service of containment structures is confirmed via the Periodic
Inspection Program and In-Service testing.
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This Acceptable Deviation shares assessment attributes with other ADs and therefore
will be included in the aggregate assessment in section 5.25.
5.2 D013 Long Term Control of Hydrogen in Containment

NK38-REP-00770-0417581, Long Term Control of Hydrogen in Containment [R-22],
provides the background information for AD D013. This issue consists of five gaps,
four of which are open issues tracking installation of Passive Auto-Catalytic
Recombiners (PARs). The remaining gap #01481 is related to the requirements for
coatings and coverings within the containment system, per CNSC RD-337. This gap
has been transferred to AD D071. Since D013 no longer contains any acceptable
deviations it is not applicable and excluded from further assessment.
5.3 D014 - Anchorage System Requirements in Concrete Containment

Requirements
NK38-REP-00770-0417582, Anchorage System Requirements in Concrete
Containment Requirements [R-23], provides the background information for
The current edition of CSA N287.2-08 contains new prescriptive requirements for
material specifications and testing of anchors embedded in the concrete containment
structures. These requirements are aimed at preventing tensile failure of the
concrete around anchors.
associated with the Darlington containment structures, including the vacuum
structure. The issue has no effect on the pressure retaining capability of the
containment structures. The justification for the acceptability of this gap is that during
construction, OPG had a comprehensive anchor program and anchors were subject
to the qualification and testing requirements of CSA N287. In addition, anchor
manufacturers met the testing requirements that were in place during construction.
Lastly, ongoing fitness for service of containment structures is confirmed via the
Periodic Inspection Program and In-service Testing.
will be included in the aggregate assessment.
5.4 D015 - Requirements for Penetrations of the Containment Structure
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NK38-REP-00770-0417583, Requirements for Penetrations of the Containment

Structure [R-24], provides the background information for Acceptable Deviation D015.
It also provides the justification for concluding that this code compliance gap is an
category of 4.
CNSC Regulatory Document CNSC R-7 requires that piping systems which penetrate
the containment structure be designed to meet the requirement, that in order for a
manual isolation valve to be considered closed, it shall be either locked closed or
continuously monitored to show that the valve is in the closed position. Only certain
normally closed manual isolation valves are locked closed or continuously monitored.
A number of manual valves in the dousing water and storage system are frequently
operated and therefore it is not practical for them to be locked closed.
associated the Darlington containment boundary. The issue has limited potential to
affect pressure retaining capability of the containment structures. The justification for
the acceptability of this gap is that the subject valves continue to be tested for leaks
via safety related system tests and during Pressure Relief Valve (PRV) lift tests,
thereby continuing to provide periodic checks to ensure that the valves are configured
in the correct position.
5.5 D017 - Redundancy of Mechanical Splices in Concrete Containment Structures

NK38-REP-00770-0417584, Redundancy of Mechanical Splices in Concrete
Containment Structures [R-25], provides the background information for Acceptable
Deviation D017. It also provides the justification for concluding that this code
compliance gap is an acceptable deviation. The issue was assessed as posing a
safety significance category of 4.
CSA Standard N287.3-93 requires that redundancy shall be designed into the
requirement for mechanical splices (for reinforcing bars), in order to permit the
maximum number of production splices to be selected for testing during construction.
There is no evidence available to confirm the number of redundant splices that were
prepared and tested during DNGS construction.
Table 3 identifies the assessment attributes associated with this AD. Similar to
previous containment related ADs, the issue is associated with the Darlington
containment structures, including the vacuum structure. The issue has limited
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potential to affect pressure retaining capability of the containment structures. The

justification for the acceptability of this gap is that during construction, OPG had a
robust program in place and mechanical spices were subject to the requirements of
applicable standards at that time. Also, ongoing fitness for service of containment
structures is confirmed via the In-Service Testing and examination.
5.6 D018 - Maximum Concrete Tensile Stresses for Liners of Concrete Containment
Structures
NK38-REP-00770-0417585, Maximum Concrete Tensile Stresses for Liners of
Concrete Containment Structures [R-26], provides the background information for
D018 includes the following two issues:

(i) The tensile stress limit for the service load category in accordance with
CSA-N287.3-93 is approximately 20% lower than that specified in the
original code of construction.
(ii) The original code of construction allowed an exception whereby the post
tensioned concrete Vacuum Structure, considered to be a rigid liner,
could be relied upon as a membrane against leakage while CSA-
N287.3-93, does not allow a rigid type liner to be relied upon as a
membrane against leakage.
Table 3 identifies the assessment attributes associated with this AD. Similarly to
previous containment related ADs, the issue is associated the Darlington containment
structures, including the vacuum structure. The justification for the acceptability of
these issues is based on a robust and design and stress analysis. The tensile stress
limits in CSA-N287.3-93 are intended to prevent containment leakage due to cracking
of the concrete. Only the lower part of the Vacuum Structure wall is subject to tensile
stress. The maximum tensile stresses occur at the wall bottom and drop off rapidly to
negligible values at a height of 3-6 meters. To prevent any leakage due to cracking,
the Vacuum Structure wall has a steel liner up to a height of 6.5 meters.
Also, ongoing fitness for service of containment structures is confirmed via the In-
Service Testing and examination. This Acceptable Deviation shares assessment
attributes with other ADs and therefore will be included in the aggregate assessment.
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The issue was assessed as posing a safety significance category of 3. Reference 1
also associated this AD with the shutdown and ECI systems, which were addressed
above.


Power Plant Status in the Event of an Accident", requires that: "For those design
basis event(s) comprising a process failure coincident with the assumed unavailability
of a Special Safety System, there shall be at least one redundant information chain
As is the case for the ECI system, this issue is applicable to the Containment system
since a process system failure and loss of Containment is a design basis accident
addressed in the Safety Report. Table 3 identifies the assessment attributes
associated with this AD. The issue is associated with post-accident monitoring
requirements. Post-accident monitoring is a critical function required for event
diagnosis and for identifying the need for credited operator actions following a design
basis accident.
The justification for the acceptability of this gap is that the unavailability of a special
safety system does not imply that the monitoring equipment in that SSS is also
unavailable. Also, considering the redundancy and separation provided in the design,
the existing post-accident monitoring capability is sufficient.
Table 3 shows this acceptable deviation shares the Design Redundancy attribute with
AD D306. Therefore it will be included in the aggregate assessment.
5.8 D062 - Post-Accident Monitoring Availability (PAM) System

NK38-REP-00770-0421408, Post-Accident Monitoring Availability [R-27], provides the
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This issue covers availability requirements, including calculations and documentation

for the PAMS. Requirements on availability of the PAMS are not included in OPG
documentation as required by CSA N290.6-M82.
PAMS provides reliable and verifiable indications of important variables to be used by

operating staff after a design basis accident. These indications are used to verify
credited mitigating actions have taken place, e.g. ECI injection after a LOCA.
PAMs is not part of a Special Safety System, however some of the indications used
could be instrumentation used in a SSS. Regardless, this AD pertains to the lack of
information available to demonstrate that PAMs meets its unavailability requirements.
The containment system and its instrumentation and indications meet their reliability
requirements. Therefore, this AD does not affect the containment system or any of its
credited safety functions. On this basis, this issue is screened out.
5.9 D071 - Coverings and Coatings within Containment System

NK38-REP-00770-0421665, Coverings and Coatings within Containment System [R-
19], provides the background information for Acceptable Deviation D071. It also
category of 4. Reference 2 also associated this AD with the ECI system, which was
addressed above. The impact of this AD on ECI is the potential to increase the
pressure drop across ECIS strainers inside containment, which could affect ECI
recovery operation. Impacts on containment functions are addressed in this section.
CNSC regulatory Document RD-337 requires that the coverings and coatings for
components and structures within the containment system shall be carefully selected
and their methods of application specified, to ensure fulfillment of their safety
functions and to minimize post- accident interference with other safety functions or
accident mitigation systems. In addition, the choice of materials inside containment
should take into account the impact of post-accident containment conditions that may
affect containment performance and integrity and fission product release. There is no
evidence that applicable Darlington design documentation or construction
specifications considered the impact of post-accident containment conditions on
containment functions.
Table 3 identifies the assessment attributes associated with this AD. Containment
functions potentially affected by this issue are:
(i) Preserving the containment envelope Non-metallic coatings and liners
assist in this function.
(ii) Reducing airborne radiation levels in containment in the longer term.
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The justification for the acceptability of this AD consists of the existence of suitable
design specifications and a periodic inspection program to assure the integrity of the
coatings and coverings inside containment.
will be included in the aggregate assessment in section 5.25.
5.10 D159 - Inspection Access Requirements in CSA N285.5-M90

NK38-REP-00770-0425565, Inspection Access Requirements in CSA N285.5-M90
category of 4.
This issue concerns the inability to comply with the CSA N285.5-M90 requirement to
provide sufficient clearance in all places to permit inspection of Containment metallic
and plastic components. The Darlington Periodic Inspection Plan acknowledges non-
compliance in locations where physical limitations exist due to the existing plant
layout or where local dose rates are high enough to be too hazardous to inspection
personnel. The CNSC has agreed to the rationale for a variance to the Standard and
has accepted the alternate measures for inspection described in the PIP.
Table 3 identifies the assessment attributes associated with this AD. The justification
for the acceptability of this gap is that in some cases alternate inspection locations
from the same family can be selected. Regulatory approval has been obtained for
this alternate approach along with the requirement to document when inaccessible
locations are encountered.

factors issues, primarily related to the ECI system. Although the titles of these ADs
reflect they pertain to the ECI system, the assessment in Reference 2 concluded they
were of a more general nature and therefore could pertain to all four special safety
systems. These gaps were reviewed in detail, however, are not discussed in depth
as part of the similarity analysis. These six ADs were excluded on the basis that they
have no impact on public safety. Further discussion was provided in section 4.3.
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is discussed in section 5.22.
5.12 D164 - Start of PIP Inspection Interval

NK38-REP-00770-0425570, Start of PIP Inspection Interval [R-29], provides the
The Darlington Periodic Inspection Plan establishes that the first inspection of
containment components commence one year after the reactor first achieves
criticality. This is inconsistent with the requirement in the CSA N285.5 which requires
inspection commence when a reactor achieves first criticality.
The requirement for commencement date in the current Darlington Periodic

Inspection Plan is more stringent than the requirement in the applicable OPG
governance, N-PROC-MA-0064, Administrative Requirements for Periodic Inspection
of Nuclear Power Plants Containment Components [R-39] and the recent 2008
Edition of the CSA N285.5 Standard. Therefore, this AD has no impact on the
containment system. It is deemed not applicable and excluded from further
assessment.
5.13 D302 Extension of the Containment Envelope

NK38-REP-00770-0456338, Extension of the Containment Envelope [R-30], provides
the background information for Acceptable Deviation D302. It also provides the
Nuclear Safety Design Guide DG-38-03650.7 [R-40], states that a barrier is

acceptable as a normally closed barrier if the barrier is assured closed by one of the
following means:
a) Administrative control of a locked closed barrier, or
b) It is open less than 1 hour/annum and monitored
Design Guide Exemptions to permit the Liquid Recovery System and the Recovery
System valves to be open longer than 1 hour/annum were prepared.
associated with containment isolation requirements. The justification for the
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acceptability of this gap is that dedicated operators are stationed at the valves
whenever they are opened for required operations. Therefore, the credited barriers
used are Operator Action and Administrative Controls.
Table 3 shows this Acceptable Deviation shares the Containment Isolation attribute
with ADs D308 and D309. Therefore it will be included in the aggregate assessment.

This AD consists of eight separate gaps, four of which were addressed in section 3
for the shutdown systems (gaps 01602, 01603, 01604 and 01609) and t four gaps
(01602, 01611, 01612 and 01618) pertaining to ECIS which were addressed in
section 4. Two gaps apply to the containment system (gaps 01611, 01612). One
gap is not applicable to the AD and is not discussed further in this analysis (gap
01610).
Table 3 identifies the assessment attributes associated with this AD for the
Containment system. Both the applicable gaps for containment are also relevant to
ECIS and were discussed in section 4.4. The assessment attributes are the same as
those described for ECI, i.e. Separation Requirements, Design - Mechanical
Protection, Design Redundancy, Physical Separation and Independence
Requirements. This Acceptable Deviation shares assessment attributes with other
ADs and therefore will be included in the aggregate assessment.
5.15 D307 Electrical Separation Requirements

NK38-REP-00770-0457419, Electrical Separation Requirements [R-20], provides the
justification for concluding that the contained code compliance gaps pose an
acceptable deviation. The issues were assessed as posing a safety significance
category of 4. This AD consists of eleven separate gaps, four of which apply to the
ECI system (gaps 01598, 01601, 01607, 01617) and were discussed in section 4.
Four gaps apply to the containment system (gaps 01598, 01605, 01607, 01608).
Five gaps were determined to not applicable to the special safety systems and were
excluded from further assessment (gaps 01596, 01597, 01599, 01600 and 01606).
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Containment system. Each gap is briefly discussed below.
Gap 01598:
This gap was also applicable to the ECI system. It pertains to the mixing of channels
in multi-conductor cables between the programmable controllers (PC) and CDF,
resulting in the inability to meet separation requirements. The primary justification for
the acceptability of this gap is that the failure in the cable affecting a division control,
will also affect the wires interrogating the output contact status of another division
controller, but will not inhibit or prevent operation of the other division. In the case of
triplicated systems, i.e. the special safety systems, the other two channels would
detect a failure of the third and operate as if was a genuine channel initiation, i.e. it is
fail safe. Therefore, Design Fail Safe Practices is the barrier used in the
assessment.
Gap 01605:
This gap pertains to Separation requirements for the containment isolation function.
A common fibre-optic loop is used for Group 2 channels N and P in the Containment
Isolation System, which is in violation of applicable OPG governance and regulations.
Group 1 odd and even equipment requires Group 2 channel N and P permissives in
order to make it operational. The common fibre-optic loop does not affect the
integrity of the button-up signals generated in the Group 2 programmable controllers.
Operation of the Group 2 controls is not affected by faults on the fibre-optic network
nor can manual button-up of both channels be affected by a cross-link. Therefore,
Design Electrical Practices is the barrier used in the assessment.
Gap 01607:
This gap arises as odd and even fibre-optic Group 1 buffered cables run in odd and
even Group 2 cable trays between the EPS Control Room and the Powerhouse,
which is in violation of OPG governance and results in the inability to meet separation
requirements. The primary justification for running the fibre-optic cables in Group 2
cable trays are because fibre-optic cables do not carry current, resulting in no impact
on other cables. Therefore Design Diverse Materials is the barrier used in the
assessment.
Gap 01608:
This gap arises since Group 2 cables supplying power to containment isolation valves
are partially routed along the seismically qualified Group 1 cable pan. This is in
violation of applicable OPG governance and regulations on separation requirements.
The primary justification for the acceptability of this gap is that the routing of the
Group 2 cables has been assessed as not being affected by common mode events,
e.g. a seismic event. In addition, the routing of the Group 2 cables was assessed as
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not affected by other common mode events, e.g. fire. Design Seismic Qualification
and Assessment are the barriers used in the assessment.
As shown in Table 13, acceptable deviation D307 shares some of its assessment
attributes with AD D306. The common attribute is Separation Requirements and
therefore this AD will be included in the aggregate assessment.
5.16 D308 Electrical Shield Grounding

NK38-REP-00770-0457420, Electrical Shield Grounding [R-32], provides the
The gap arises as the grounding requirements for the high activity monitors for
containment button up were not met. It is required that all shields should be
grounded at one point only, except for cables in the switchyard area in which case the
shields should be grounded at both ends.
associated with containment isolation requirements. The justification for the
acceptability of this gap is that testing of the monitors was performed in the alternate
configurations and no problems were observed. Therefore, the credited barrier used
is Operations Monitoring.
Table 3 shows this Acceptable Deviation shares the Containment Isolation attribute
with ADs D302 and D309. Therefore it will be included in the aggregate assessment.
5.17 D309 Extension of Containment Envelope

NK38-REP-00770-0457421, Extension of the Containment Envelope [R-33], provides
the background information for Acceptable Deviation D309. It also provides the
The issue was assessed as posing a safety significance category of 4. It consists of
two gaps covering: (i) compression seal requirements, (ii) the length of tubing used
for containment isolation purposes.
Containment system. Each gap is briefly discussed below.
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Gap 01594:
This gap arises as a single compression fitting is used for containment isolation
purposes, which is in violation of Nuclear Safety Design Guide DG-38-03650.7 [R-40]
and CNSC regulations. To justify the acceptability of this gap, the subject penetration
seals are tested for leakage during the Reactor Building pressure tests. Testing will
ensure compression seals maintain containment integrity. Therefore, In-Service
Testing is the barrier used in the assessment.
Gap 01595:
This gap arises since the containment isolation valves provided in the tubing runs of
the D2O in H2O Detection system are not accessible for closing after an accident
(LOCA) due to high radiation fields. Alternate credited containment isolation valves
are utilized in the system, but are located a considerable distance from the
containment penetration, which violates the applicable Nuclear Safety Design Guide.
The primary justification for the acceptability of this gap is that the tubing is protected
from dynamic effects for events requiring containment, by providing mechanical
barriers and running the tubing in steel channels. Therefore, Design Mechanical
Protection is the barrier used in the assessment.
Table 3 identifies the assessment attributes associated with AD D309. The issue is
associated with containment isolation requirements. This Acceptable Deviation
shares assessment attributes with other ADs and therefore will be included in the
aggregate assessment.
5.18 D357 - Frequency of Leakage Rate Tests on Negative Pressure Containment

NK38-REP-00770-0460565, D357 - Frequency of Leakage Rate Tests on Negative
Pressure Containment [R-34], provides the background information for Acceptable
compliance gap is an acceptable deviation. The issue was assessed as posing a
safety significance category of 4.
Regulatory Document CNSC R-7 requires Negative Pressure Containment leakage

tests at full design pressure be performed at least every six years. Vacuum Building
inspections and tests are currently performed every twelve years at Darlington NGS.
The balance of the containment boundary is tested every six years.
Table 3 identifies the assessment attributes associated with this AD. Similar to ADs
discussed above, the issue is associated with the integrity of the containment
boundary. The justification for the acceptability of this AD consists of continued
acceptable results from past leakage rate tests and periodic inspections which
demonstrate no significant degradation of the containment structures.
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will be included in an aggregate assessment described in section 5.25.
5.19 D358 - Lack of Certified Mill Test Report Records

NK38-REP-00770-0460543, D358 - Lack of Certified Mill Test Report Records [R-35],
provides the background information for Acceptable Deviation D358. It also provides
the justification for concluding that this code compliance gap is an acceptable
deviation. The issue was assessed as posing a safety significance category of 4.
CSA N287.1-93 requires that the material manufacturer provide quality records,
including certified mill test reports (CMTR) of the materials supplied, for inclusion in
the construction reports. CMTRs for the materials used in the original construction of
the Darlington NGS containment structures could not be located.
During construction, Darlington NGS either met the requirements of CSA N287.1-93
or had other processes in place to ensure compliance of the material with the
purchase order and the technical specification. Therefore, this AD has no impact on
the containment system. It is deemed not applicable and excluded from further
assessment.
5.20 D564 Darlingtons Governance Documents and PIP Plans Reference

Previous Edition of Code
NK38-REP-00770-0486906, Darlingtons Governance Documents and PIP Plans
Reference Previous Edition of Code [R-46], provides the background information for
Acceptable Deviation D564. It also provides the justification for concluding that the
contained code compliance gap is an acceptable deviation. The issue was assessed
as posing a safety significance category of 4.
This AD pertains to governance related to the PIP program not referencing the latest
version of CSA Standard N285.5. The current station operating licence still
references the previous version of the standard. This previous version is referenced
in PIP program governance as required. Therefore this AD has no impact on public
safety and is screened out.
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5.21 D607 Severe Accidents and Beyond Design Basis Accident (BDBA)
Design/SAMG
NK38-REP-00770-0488763, Severe Accidents and Beyond Design Basis Accident
(BDBA) Design/SAMG [R-48], provides the background information for Acceptable
compliance gap is an acceptable deviation. The issue is assessed as posing a safety
significance category of 2, however this is a result of the more significant gaps
addressed in the AD requiring resolution, i.e. the lack of sufficient design provisions
following a severe accident. AD D607 consists of thirteen gaps, but only gap 2286 in
AD D607 was assessed as an AD. It is applicable to the Containment System.
CSA Standard N290.3-11 Requirements for the Containment System of Nuclear

Power Plants [R-49], requires the selection of the containment concrete material for
new builds take into account the effects of severe accidents involving interaction of a
melted reactor core and concrete. Darlington was not designed for core-concrete
interaction (CCI), which can occur following severe accidents. However, as part of
refurbishment, design features are being installed to ensure containment integrity
following a severe accident. Once these design features are installed, this
requirement on concrete materials is not essential and therefore this issue classified
as an acceptable deviation.
Table 3 identifies the assessment attributes associated with AD D607, which are:
containment integrity, concrete structures, severe accidents, and design
modifications. This Acceptable Deviation shares assessment attributes with other
ADs and therefore will be included in the aggregate assessment in section 5.25.

This Acceptable Deviation was discussed in section 3.11 for the shutdown systems.
The issue is generic in nature and applies to all the special safety systems. As per
section 3.11, AD608 was screened out.
5.23 D609 Darlingtons Governance Documents and PIP Plans Reference

NK38-REP-00770-0489774, Darlingtons Governance Documents and PIP Plans
Reference Previous Edition of Code [R-47], provides the background information for
Acceptable Deviation D609. It also provides the justification for concluding that the
contained code compliance gap is an acceptable deviation. The issue was assessed
as posing a safety significance category of 4.
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This AD pertains to governance related to the PIP program not referencing the latest
version of CSA Standard N287.7. The current station operating licence still
references the previous version of the standard. This previous version is referenced
in PIP program governance as required. Therefore this AD has no impact on public
safety and is screened out.
5.24 D613 Containment Boundary Leakage

NK38-REP-00770-0489529, Containment Boundary Leakage [R-50], provides the
The issue is assessed as posing a safety significance category of 4. D613 consists of
five gaps against various clauses of CSA Standard N290.3-11, Requirements for the
Containment System of Nuclear Power Plants [R-49].
Gap 02304:
This gap arises as there are no defined separate leakage limits for liquids through
containment penetrations. However, the Safety Report includes analysis of the
discharge of liquids outside containment, and analysis of accidents combined with
either chronic or consequential steam generator tube leakage. Accidents combined
with leakage from other containment boundary locations are expected to be covered
by these stylized accidents with containment bypass in the Safety Report. Therefore
the safety significance of this gap is very low and is screened out.
Gap 02305:
This gap arises due to the lack of an explicit requirement for containment penetrations
being designed to be leak tight. Electrical penetrations, airlocks and transfer
chambers are all testable. The interspace between isolation valves for piping
penetrating containment, are also tested for leakage. In addition to these individual
tests, the overall containment structure is tested. Hence, if the overall leakage rate is
acceptable, it follows that each of the individual penetrations is also leak tight.
Therefore, the design of containment penetrations meets the intent of this leak
tightness requirement. Therefore the safety significance of this gap is very low and is
screened out.
Gap 02306:
This gap arises due to the lack of an explicit requirement for electrical and cable
penetrations being designed to be testable for leaktightness. This code requirement
only applies to new builds and therefore is screened out as being not applicable.
Gap 02307:
This gap arises as pipes that connect to the reactor coolant system and penetrate the
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containment structure are not always provided with two isolation barriers. In some
cases crimping of small lines is credited instead of having two series isolation
barriers. This code requirement only applies to new builds and therefore is screened
out as being not applicable.
Gap 02308:
Piping that connects to the reactor coolant system and penetrates the containment
structure, and has barriers that could be open for 1 hour per year or more, should
have two automatic barriers that also fail to the closed position. In some cases
manual isolation barriers are used at Darlington. However, this code requirement
only applies to new builds and therefore is screened out as being not applicable.
Since all these gaps are screened out, D613 is not included in the aggregate
assessment.
5.25 Assessment of Containment System Acceptable Deviations Sharing the Same

Attributes
As reviewed above, the Containment system Acceptable Deviations that share
assessment attributes and therefore are similar are:
3. D306 and D309 associated with Design - Mechanical Protection
4. D302, D308 and D309 associated with Containment Isolation
5. Ten ADs associated with Containment Integrity and In-Service Testing
6. Seven ADs associated with the Periodic Inspection Program
7. Seven ADs associated with the Containment Structure
This last group of seven ADs sharing the Containment Structure attribute, are all
included in the group of ten ADs associated with Containment Integrity and In-Service
Testing attribute. Given they are a sub-set of the ten ADs which will reviewed to
determine if an aggregate impact exists, this last group of seven ADs does not have
to be assessed separately.

together they could result in any adverse effect on public safety.
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5.25.1 D061 and D306 - Design - Redundancy

analysis. D061 pertains to the Post-Accident Monitoring system (PAMS). Part of the
justification used in this AD is the redundancy in PAMS parameters and the
containment system provided by design. D306 pertains to use of common pressure
transmitters (PTs) for the generation of ECI initiation signals and for a HT pump trip.
Tripping of the main HTS pumps after a LOCA ensures that the pump seals remain
intact assuring containment integrity.
The containment system does not use the HTS low pressure parameter (used to trip
the HTS pumps) in any of its safety functions. Therefore, these two issues which
credit the Design -Redundancy attribute are independent from each other and
therefore there is no compounding effect.
5.25.2 D306 and D307 - Separation Requirements

These two ADs are similar as they all pertain to the Separation Requirements
imposed on channels of the containment system. D306 pertains to Instrumentation
and Control Separation requirements and the proximity of instrument tubing runs on
independent channels and the resultant ability to meet separation requirements.
D307 pertains to Electrical Separation Requirements dealing with cable runs to

various pieces of equipment. Gap 01608 in D307 pertains to the separation
requirements between special safety systems, in this case ECIS and Containment.
Therefore this gap cannot introduce a compounding effect when reviewed with other
containment gaps and therefore it is excluded from this aggregate assessment.
Not completely satisfying separation requirements, has the potential to impact on the
ability to meet containment reliability requirements. In this case, the impacted
containment function is containment isolation posed by gaps 01605 and 01612.
There is no impact on containment isolation function for the following reasons:

The effectiveness of the barriers credited in the Acceptable Deviation
assessment, i.e. Design - Electrical Practices and Design Mechanical
Protection.
As described in section 5.14 for gap 01605 the common fibre-optic loop does
not affect the integrity of the button-up signals generated in the Group 2
programmable controllers.
The safety significance of these two ADs was assessed at the lowest level, i.e.
4.
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The other gaps associated with these two ADs with the separation requirements
attribute (gaps 01607 and 01612) are more general in nature. Again, given the
effectiveness of the barriers credited in the Acceptable Deviation assessment for
these gaps, there will be no impact on reliability. Also, the safety significance of
these two ADs was assessed at the lowest level.
Given the above, there is no compounded effect introduced with these two
5.25.3 D306 and D309 - Design - Mechanical Protection

These two ADs pertain to the potential for instrument tubing associated with the
containment system not being separated as required and the potential for damage
due to their proximity to each other. In both ADs, mechanical protection is provided
to ensure there is a barrier to prevent damage to tubing used in functions.
The containment functions potentially affected are:

Containment isolation (high RB pressure loops)
Isolation of H2O in D2O tubing
In each individual case the AD states that the mechanical protection provided for the
subject instrument tubes both inside and outside containment, ensures the probability
of unsafe failure of tubing is very low following a design basis accident. Therefore,
the probability of failure of both containment functions is an extremely low probability
event. Therefore there is no compounded impact when considering these two similar
5.25.4 D302, D308 and D309 - Containment Isolation

These ADs pertain to the Containment Isolation safety function. In AD D309, gap
01594 is excluded from this aggregate assessment, as deals with containment
integrity and not a specific containment isolation function (it is addressed in section
5.25.5).
The remaining ADs pertain to the following containment functions/equipment:

Containment boundary valves in the D2O/H2O system
Activity Monitors for the containment isolation signal
Containment boundary valves in the D2O Collection System
Based on the description of these issues in the previous sections on these ADs, they
are sufficiently diverse, deal with different aspects/equipment related to the
containment isolation function and rely on robust barriers (identified in Table 3) that
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are not challenged when considered together. Therefore there is no compounding

effect.
5.25.5 Ten ADs - Containment Integrity and In-Service Testing

The above assessment has identified that ten Acceptable Deviations are associated
with Containment Structural Integrity and the In-Service Testing barrier. The potential
aggregate effect of these similar issues is reviewed to determine if together they
could result in any adverse effect on public safety. The applicable ADs are D010,
D014, D015, D017, D018, D071, D159, D309, D357 and D607.
These ADs have the potential to impact on the containment structures or containment
boundary leakage requirements. Four pertain to concrete containment degradation
over time (D010, D014, D017 and D018). Four others relate to containment
boundary components and the potential for containment leakage (D015, D071, D159
and D309). AD D357 addresses the increased In-Service test interval of Vacuum
Structure leakage rate tests. AD607 deals with concrete material design
requirements for severe accidents. AD607 is not addressed in the aggregate
assessment since it is the only AD pertaining to requirements for severe accidents.
Given the diversity of the issues and the inherent technical difficulty in attempting to
assess the combined impact of these issues, an alternate approach using a technical
assessment has been employed. The assessment concludes that there is no impact
on public safety:
(i) The combined impact of the nine remaining ADs with containment
structural integrity and leakage rate attributes can be measured directly
during containment leakage rate tests. Regular leakage rate tests of the
reactor vaults and F/M duct are performed with reactors operating. In
addition, during station containment outages, leakage rate tests are
performed on the entire containment envelope up to its design pressure.
The maximum containment pressure reached during the worst design
basis accident is bounded by the design pressure.
(ii) As discussed in the description of D357, the increase in the test interval
for containment design pressure tests was justified based on measured
leakage rates being well below Safety Report assumptions.
(iii) In addition, containment inspections performed in accordance with the
containment aging management plan during station outages, have
shown containment structures to be in excellent condition.
(iv) The continued performance of leakage rate testing post-refurbishment
will provide continued assurance of this conclusion.
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5.25.6 Seven ADs - Periodic Inspection Program

Seven Acceptable Deviations in this review are associated with Periodic Inspection
Program (PIP) barrier. The applicable ADs are D010, D014, D017, D018, D071,
D159 and D357. All of these ADs are also associated with the structural integrity
attribute. The ADs which share this common attribute were reviewed in section
5.25.5 and no compounded effect was identified.
5.26 Conclusion
The similarity analysis performed for the 24 Containment system Acceptable
Deviations, identified six groups of ADs that were similar and could resulting in some
compounding effect when assessed together. The aggregate effect of these issues
was found to have no impact on public safety. The aggregate effect of any
Containment system ADs potentially affecting another SSS, are addressed in section
6.
6 Assessment of Aggregate effects of ADs across the Special

Safety Systems
The previous sections examined the aggregate effect of Acceptable Deviations for
each Special Safety System individually. In some cases, Acceptable Deviations can
also be applicable to multiple SSSs. This section reviews the aggregate effect of
applicable ADs potentially affecting more than one SSS. The same approach
described in section 2 was used for this assessment; however some additional steps
were required.
All of the attributes used in the similarity analysis (contained in Tables 1 to 3) were
listed to identify which were shared amongst the four SSS. Attributes associated with
more than one SSS could pose an aggregate risk when the impact on the SSSs is
assessed together. Table 4 provides the listing of all assessment attributes used,
along with the Acceptable Deviations Associated with the attribute for each SSS.
Acceptable Deviations that were previously assessed as not applicable were
excluded. As shown in Table 4, sixteen assessment attributes were shared amongst
two or more SSS, which could potentially require an aggregate assessment.
However, it is not required to assess the aggregate effect of any of these sixteen
attributes, if only a single AD is associated with that shared attribute. For example, in
Table 4, the attribute Design Diverse Materials is used in the similarity analysis for
ECIS and Containment. However, Table 4 also shows that this attribute was only
used in AD D307. The justification for Acceptable Deviation D307 was already
prepared as part of the ISR process and therefore any aggregate effect of systems in
its scope would have been assessed. Therefore, it is not necessary to perform an
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aggregate assessment for shared attributes of this type and therefore these have
been screened out.
On the other hand, in Table 4, the attribute Administrative Controls is used in the
similarity analysis for SDS1, SDS2, ECIS and Containment. Since these attributes
were used in assessing different ADs (D245, D302 and D307), an assessment of the
aggregate effect of these grouped ADs across the affected systems is required.
Table 4 shows that an aggregate assessment is required for the ten remaining
attributes that are shared amongst the SSSs. The following sections perform the
assessment for each of these attributes. First, one more AD is discussed.
AD D146 was identified in Reference 2 as not being associated with a particular SSS
and therefore is not shown in Tables 1 to 3 nor was it discussed above. It is
described in, NK38-REP-00770-0425544, Specifications for Developing Computer
Programs not given in Software QA [R-36], provides the background information for
This AD concerns gaps related to requirements for proper development, verification

and review of computer programs used for Safety Analysis, as well as one gap
related to requirements for software validation.
Safety Analysis Improvement (SAl) and RD-310 Implementation are two initiatives
underway to address these gaps. This is being done under the auspices of a COG
Working Group. An additional barrier in place is current OPG governance, which
provides the necessary specifications in this area.
This issue has been excluded from further assessment on the following basis:
There is the required confidence in the current safety analysis toolset.
The two initiatives described above are underway and will provide additional
validation.
The next sections describe the aggregate assessment for each of the attributes
identified as common across more than one SSS.
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6.1 Administrative Controls

This attribute is shared amongst all three SSS and is associated with three ADs:
D245, D302 and D307.
D245 addresses reactor start-up instrumentation (SIU) (although not a
SSS, the AD is associated with SDS1/2). Administrative controls, i.e.
procedural compliance, are adhered to during its use.
D302 addresses operator surveillance during opening of containment
boundary valves.
The applicable gap (1601) in D307 addresses testing and administrative
practices used during ECIS pressure transmitter and injection valve tests.
At any time SIU is used during reactor start-up, the HTS in that unit must be cold
(<90degC). During this time ECIS is not credited for that unit. Therefore D245 and
D307 (associated with ECIS) cannot have a compounding affect. The activities that
D302 and D307 pertain to are of short duration, infrequently performed and
procedural adherence practices are used. Therefore, it is judged that there is no
compounding affect when reviewing these three ADs across the SSSs.
6.2 Design Mechanical Protection

This attribute is shared amongst all four SSS and is associated with two ADs: D306
and D310.
D306 addresses separation requirements for instrument tubing for
redundant SDS trip channels. Mechanical protection was used in the
design to ensure the tubing was not subject to damage during normal
operation and post-accident conditions. D306 also includes similar tubing
used in ECIS and Containment instrumentation. The potential for an
aggregate effect has been addressed as part of the justification for the
associated gaps being classified as Acceptable Deviations. Therefore, this
does not need to be addressed in this assessment.
D310 is associated with instrument tubing in both SDS1 and 2 (used in the
Steam Generator Feed Line Pressure Trip (SGFLP)) can be potentially
affected by pipe whip following a feedwater failure. The requirement for
separation between SDS1 and 2 is potentially challenged. As per D306,
mechanical protection was used in the design to ensure the tubing was not
subject to damage during normal operation and post-accident.
The addition of D310 together with D306 is judged to have no aggregate effect across
the four SSS for the following reasons:
The subject SDS instrumentation tubing in the powerhouse is located remote
from the affected ECIS and Containment tubing (R-111 and R-112 to the
RAB).
Page 45 of 75
0235 AD AGGREG 0003 01

The primary heat sink used for feedwater failures (affecting D310) is the
Group 2 Emergency Water System, not ECIS.
A robust design is employed to ensure the likelihood of tubing damage is very
low.
Redundant channels are provided in the design of the SSS.
Therefore, it is judged that there is no compounding affect when reviewing these two
ADs across the SSSs.
6.3 Design - Redundancy

This attribute is shared amongst all four SSS and is associated with four ADs: D061,
D245, D306 and D310.
D061 addresses the requirements for post-accident monitoring system
(PAMS) following a process failure plus a coincident loss of a special safety
system. Redundancy of PAMS is credited in the AD.
D245 addresses reactor start-up instrumentation (SIU) (although not a
SSS, the AD is associated with SDS1/2). The fact that the SIU is
comprised of redundant instrument channels for reactor trips (required to
cater to a potential loss of regulation/control) is credited in the AD.
D306 (gap 1611) addresses the use of common pressure transmitters in
ECIS and Containment following loss of coolant accidents. The degree of
redundancy of ECIS and NPCS pressure transmitters is credited in the AD
D310 is associated with instrument tubing in both SDS1 and 2 being
potentially affected by pipe whip following a feedwater failure. Redundancy
in the design of SGFLP trip is credited in this AD.
It is judged that there is no compounded affect across the SSS with the following
bases:
As described above, each AD is applicable for different design basis
accidents.
The redundancy in all of these different safety functions meets all applicable
system design requirements.
The justification for the acceptability of the subject ADs all credit additional
factors in addition to redundancy in design, e.g. Administrative controls for
D245. Therefore, additional barriers are in place to ensure there is not a
loss of redundancy in any of these functions and hence there is no
compounding affect.
Page 46 of 75
0235 AD AGGREG 0003 01

6.4 Periodic Inspection Program/ Aging Management Program

These two attributes are grouped together given their very similar objectives. These
attributes are shared amongst all four SSS and are associated with the following ADs:
D010, D014, D017, D018, D021, D022, D071, D159 and D357.
D021 and D022 address issues associated with reactor components. The
reactor structures aging management plan (AMP) is credited in the
disposition of these gaps. An AMP is a form of periodic inspection
programs mandated by CSA standards.
D071 is associated with the potential for ECIS recovery screen plugging
due to debris, coatings and liners being liberated post-LOCA. Periodic
inspections of liners and coatings are performed as part of the PIP
program.
The remaining ADs are all gaps related to the containment structure. The
PIP program for the concrete structure and in-service inspection are
credited in the justification for these gaps. CSA standard N285.6 and .7
address concrete containment structures.
Although a periodic inspection program is one of the barriers used in the justification
of these ADs, they are three distinct programs all meeting mandated requirements.
Hence there is no aggregate effect across the SSSs.
6.5 Safety Related System Test Program

This attribute is shared amongst SDS1, SDS2 and Containment and is associated
with two ADs: D015 and D029.
D015 is associated with containment boundary valves and the requirement
that in order for a manual isolation valve to be considered closed, it shall be
either locked closed or continuously monitored to show that the valve is in
the closed position. The justification for the acceptability of this gap is that
manual valves in the dousing water and storage system continue to be
tested for leaks via safety related system tests and during Pressure Relief
Valve (PRV) lift tests.
D029 (gap 403) addresses the test frequency for full functional testing of
SDS1 and 2.
The tests credited are not related at all. Also, due to their distinct nature, the
reliability of either of these systems would not be affected when the two issues
viewed together. Hence there is no aggregate effect across the shutdown and
containment systems.
Page 47 of 75
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6.6 Vendor Quality Requirements

with three ADs: D014, D060 and D305.
D060 and D305 identify that a common manufacturer is used for the
Shutdown Systems trip computer termination modules, control equipment
panels, and flux detectors for both SDSI and SDS2. The primary
justification for the acceptability of this gap is that the vendor for these
components had approved procedures in place to ensure independence of
manufacturing processes applied to SDS1 and SDS2.
D014 pertains to new prescriptive requirements for material specifications

and testing of anchors embedded in the concrete containment structures.
One of the barriers in place for this AD is that anchor manufacturers met
the rigorous testing requirements that were in place during construction.
Two different vendors supplying very different types of components are covered in
these ADs. Hence there is no aggregate effect across the shutdown and containment
systems.
6.7 Independence Requirements

This attribute is shared amongst all four SSSs and is associated with four ADs: D060,
D305, D306 and D310, which were all discussed in previous sections.
D060 and D305 identify that a common manufacturer is used for the
Shutdown Systems trip computer termination modules, control equipment
panels, and flux detectors for both SDSI and SDS2.
D306 (gap 1611) addresses the use of common pressure transmitters in
ECIS and Containment following loss of coolant accidents.
D310 is associated with instrument tubing in both SDS1 and 2 (used in the
Steam Generator Feed Line Pressure Trip (SGFLP)) potentially affected by
pipe whip following a feedwater failure.
In assessing these four ADs together there is no aggregate effect across the four
SSS for the following reasons:
Acceptable deviations D306 and D310 are applicable to two distinct design
basis accidents, i.e. LOCA and a loss of feedwater event.
AD D060 and D305 were assessed as having low safety significance and
SDS1 and 2 performance has been shown to not be adversely affected.
Therefore, it is judged that there is no compounding affect when reviewing these four
ADs across the SSSs.
Page 48 of 75
0235 AD AGGREG 0003 01

6.8 Safety Analysis

with two ADs: D032 and D071. Although this attribute was not identified in the
justification for this gap in the ECIS similarity analysis, the potential aggregate effect
of the issue will also include ECIS.
D032 is associated with the Trip Parameter Acceptance Criteria in CNSC-
G144. In the justification for this gap, OPG has demonstrated that the
existing safety analysis criteria are met, which preclude both fuel sheath and
fuel channel failure. Also, by utilizing an alternate industry accepted safety
analysis methodology, i.e., the best estimate uncertainty analysis (BEAU), it
has been shown that the G-144 criteria are met.
due to debris, coatings and liners being liberated post-LOCA and the
selection of coatings to aid in the minimization of post-LOCA fission
product release.
Based on the following rationale, there is no aggregate effect across the SSSs:
Given the very conservative nature of the analysis used in the design of the
modified ECIS recovery screens, sensitivity of shutdown system
performance (regardless of which of the two trip effectiveness criteria used)
can have no impact on long term fuel cooling provided by ECIS recovery,
i.e. no further plugging of screens would be expected.
The beneficial effect that some coatings can have of reducing airborne
activity in containment is not credited in the safety analysis.
6.9 Separation Requirements

This attribute is shared amongst all four SSS and is associated with three ADs: D245,
D306 and D307.
D245 addresses reactor start-up instrumentation (SIU) (although not a SSS
the AD is associated with SDS1/2). Separation requirements imposed on
the shutdown systems are not fully met by the start-up instrumentation.
D306 addresses separation requirements for instrument tubing for
redundant SDS trip channels.
D307 addressed electrical separation requirements for special safety
systems.
Page 49 of 75
0235 AD AGGREG 0003 01

Fulfilling separation requirements ensures that the post-accident consequential

impacts, e.g. pipe whip, or common mode events, do not adversely affect special
safety system performance as credited in the Safety Report.
As discussed in the methodology for this assessment, the aggregate effect across
SSSs for individual ADs is not required, since it has already been addressed in the
ISR process outside of this assessment. Also, the assessment of the aggregate
effect for the start-up instrumentation (D245) and ECIS was already addressed in
section 6.1 and therefore is not described again here.
SIU is located remote from any of the equipment affected by the containment related
gaps in ADs 306 and 307, e.g. cables run in the powerhouse. Also, all of the gaps
related to containment in these two ADs are of low safety significance and not related
to SIU and therefore there is no aggregate effect across SSSs introduced with
acceptable deviation D245 and therefore it is not assessed further.
This leaves assessing the aggregate effect of ADs 306 and 307 across the four SSS.
The gaps in these two ADs related to separation requirements are:

SDS1: 01609
SDS2: 01602, 01603, 01604 and 01609
ECIS: 01598, 01601, 01602, 01607, 01611, 01612 and 01618
NPCS: 01598, 01605, 01607, 01608, 01611 and 01612
First, the safety significance of the gaps for both of these acceptable deviations has
been assessed as low (category 4). As described in earlier sections the following
gaps in AD D307 have been described as having no impact on the SSS or a fail safe
response would be expected:
Gaps 01598, 01601, 01605, 01607 and 01608
Therefore, the remaining gaps to address in the aggregate assessment are those in
D306 and D307 gap 1617.
Gap 1617 pertains to supplying both odd and even power to the unit ECI branch
interconnect valves. The power supply circuits are properly fused to ensure the intent
of the separation requirement is met. Therefore, there isnt an aggregate effect when
assessing this gap against the instrument tubing gaps in D306.
Page 50 of 75
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6.10 Design Modification

This attribute is shared amongst the ECI and Containment systems and is associated
with two ADs: D071 and D607.
due to debris, coatings and liners being liberated post-LOCA and the
selection of coatings to aid in the minimization of post-LOCA fission
product release. To partially address this gap a design modification was
made to the ECIS screens to prevent plugging and impairment of ECIS.
D607 (gap 403) addresses the selection of concrete material for the
containment structure in consideration of severe accidents. CSA Standard
N290.3-11 Requirements for the Containment System of Nuclear Power
Plants [R-49], requires the selection of the containment concrete material
take into account the effects of severe accidents involving interaction of a
melted reactor core and concrete. Core concrete interaction (CCI) during a
severe accident has the potential to challenge containment integrity, due to
the generation of large quantities of aerosols and non-condensable gases.
To address this gap, design modifications are being made to install a
containment filtered venting system to increase the pressure relief
capability of containment during postulated severe accidents. This
modification will mitigate the impacts of CCI, without the need to re-
evaluate the acceptability of the concrete used in the Darlington design.
The two modifications being made for these two ADs are different in nature and are,
or will be effective in mitigating the accident conditions they are designed for. Also,
the Engineering Change Control program is effective in ensuring design modifications
are made per required specifications. Therefore there is no aggregate effect across
the ECI and containment systems.
6.11 Conclusion
This section reviewed the potential for an aggregate effect of Acceptable Deviations
across the special safety systems. To perform this review for the forty ADs,
assessment attributes were reviewed to determine which ADs/gaps could impact on
more than one SSS. An aggregate assessment was required for ten attributes that
were shared amongst the SSSs. In each case it was demonstrate that no aggregate
effect was introduced.
Page 51 of 75
0235 AD AGGREG 0003 01

7 Conclusion
The assessment in this report reviewed the Acceptable Deviations identified as being
associated with the Special Safety Systems (SSSs). The objective was to determine
if there was an aggregate effect on public safety when considering:
(i) All of the ADs together for each SSS.

(ii) All applicable ADs which could affect more than one SSS.
This report assesses this impact for the:
(i) Shutdown Systems SDS1 and SDS2

(ii) Emergency Coolant Injection System
(iii) Negative Pressure Containment System
Forty Acceptable Deviations were reviewed, many of which contained multiple gaps.
Some of the ADs were applicable to more than one SSS.
The assessment was performed using a strictly qualitative similarity analysis

technique to determine which of the issues could result in a compounded effect when
considered together. Attributes were assigned to each AD based on a pre-defined
set. When it was concluded that these attributes were common to more than one
AD, these ADs were grouped together. The aggregate effect of these grouped issues
was then assessed.
Aggregate assessments were performed for all three special safety systems and
across SSSs. This assessment concludes that when the Acceptable Deviations are
assessed as a group, there was no aggregate effect and hence no significant impact
on public safety.
8 References
[R-1] Report, NK38-REP-03680-10104 Rev 000, Darlington NGS ISR Final ISR
Report, Oct 21, 2011.
[R-2] CPUS Report, Darlington Global Assessment Acceptable Deviation

Analysis, 0235-GAR-AD-REVIEW-R00, June 25, 2013.
[R-3] Issue Resolution Form D021, NK38-REP-00770-0417587, Cleaning

Solution Composition Limits, May 03, 2011.
Page 52 of 75
0235 AD AGGREG 0003 01

[R-4] Issue Resolution Form D022, NK38-REP-00770-0417588, Non-Destructive

Testing of Reactor Components, April 29, 2011.
[R-5] Issue Resolution Form D029, NK38-REP-00770-0419196, Compliance with

CNSC R-8, May 15, 2011.
[R-6] Issue Resolution Form D032, NK38-REP-00770-0419199, Trip Parameter

Acceptance Criteria CNSC- G144, May 17, 2011.
[R-7] Issue Resolution Form D060, NK38-REP-00770-0421406, Shutdown

System Diversity, May 16, 2011.
[R-8] Issue Resolution Form D061, NK38-REP-00770-0421407, Special Safety

System Design, June 8, 2011.
[R-9] Issue Resolution Form D245, NK38-REP-00770-0425823, Shutdown

System Requirements for Start-up Instrumentation, May 18, 2011.

Factors ECI & ANN System Display, November 11, 2012.

Factors - Implementation, November 11, 2012.

Factors ECI & ANN System Labels, November 11, 2012.

Factors ECI System Dynamic Indication, November 11, 2012.

Factors ECI System Ergonomics, November 11, 2012.

Factors ECI System Maintenance, November 11, 2012.

Factors ECI & ANN System Controls, November 11, 2012.
[R-17] Issue Resolution Form D306, NK38-REP-00770-0457418, Instrumentation

and Control Separation Requirements, February 8, 2013.
Page 53 of 75
0235 AD AGGREG 0003 01

[R-18] Issue Resolution Form D310, NK38-REP-00770-0457422, SDS1 and SDS2

Steam Generator Feed Line Pressure Trip, February 8, 2013.

Coverings and Coatings within Containment System, February 8, 2013.
[R-20] Issue Resolution Form D307, NK38-REP-00770-0457419, Electrical

Separation Requirements, February 8, 2013.
[R-21] Issue Resolution Form D010, NK38-REP-00770-0417578, Changes to

Examination and Testing Requirements for Concrete Containment
Structures, April 06, 2011.
[R-22] Issue Resolution Form D013, NK38-REP-00770-0417581, Issue D013 Long

Term Control of Hydrogen in Containment, April 29, 2013.
[R-23] Issue Resolution Form D014, NK38-REP-00770-0417582, Anchorage

System Requirements in Concrete Containment Requirements, April 28,
2011.
[R-24] Issue Resolution Form D015, NK38-REP-00770-0417583, Requirements

for Penetrations of the Containment Structure, May 02, 2011.
[R-25] Issue Resolution Form D017, NK38-REP-00770-0417584, Redundancy of

Mechanical Splices in Concrete Containment Structures, April 19, 2011.
[R-26] Issue Resolution Form D018, NK38-REP-00770-0417585, Maximum

Concrete Tensile Stresses for Liners of Concrete Containment Structures,
Sept 29, 2011.
[R-27] Issue Resolution Form D062, NK38-REP-00770-0421408, Post-Accident

Monitoring - Availability, June 20, 2011.
[R-28] Issue Resolution Form D159, NK38-REP-00770-0425565, Inspection

Access Requirements in CSA N285.5-M90, April 8, 2011.
[R-29] Issue Resolution Form D164, NK38-REP-00770-0425570, Start of PIP

Inspection Interval, April 14, 2011.

Extension of the Containment Envelope Requirements, Aug 15, 2013.
Page 54 of 75
0235 AD AGGREG 0003 01

[R-32] Issue Resolution Form D308, NK38-REP-00770-0457420, Electrical Shield

Grounding, February 8, 2013.
[R-33] Issue Resolution Form D309, NK38-REP-00770-0457421, Extension of the

Containment Envelope, February 8, 2013.
[R-34] Issue Resolution Form D357, NK38-REP-00770-0460565, Issue D357 -

Frequency of Leakage Rate Tests on Negative Pressure Containment,
March 26, 2013.
[R-35] Issue Resolution Form D358, NK38-REP-00770-0460543, Issue D358 -

Lack of Certified Mill Test Report Records, March 26, 2013.
[R-36] Issue Resolution Form D146, NK38-REP-00770-0425544, Specifications

for Developing Computer Programs not given in Software QA, April 22,
2011.
[R-37] Report, NK38-REP-00770-0456340, Nuclear Refurbishment Issue

Resolution Form - Darlington - Issue # D305 - Shutdown System Diversity,
Feb 08, 2013.
[R-38] Design Guide, NK38-DG-03650.3 Rev 007, Nuclear Safety Design Guide:
Limiting Consequential Damage Of Postulated Pipe Ruptures, Sept 23,
2012.
[R-39] OPG Procedure, N-PROC-MA-0064 Rev 004, Administrative Requirements

For The Periodic Inspection Of Nuclear Power Plant Containment
Components, Jan 12, 2012.
[R-40] Design Guide, DG-38-03650.7 Rev 003, Nuclear Safety Design Guide Dg-
38-03650-7 Rev 4, December 1991.
[R-41] CPUS Report 0235-AD-AGGREG-0005 R01, Acceptable Deviations

Aggregate Assessment, March 2014.

Safety Review Emerging Issues Report, February 18, 2014.
[R-43] Issue Resolution Form D329, NK38-REP-00770-0490445, Special Safety

System Design, October 17 2013.
Page 55 of 75
0235 AD AGGREG 0003 01

[R-44] Issue Resolution Form D608, NK38-REP-00770-0488753, Human Factors

Design, February 11, 2014.
[R-45] CSA Standard, N290.0-11, General Requirements for Safety Systems of

Nuclear Power Plants.
[R-46] Issue Resolution Form D564, NK38-REP-00770-0486906

R000,Darlingtons Governance Documents and PIP Plans Reference
Previous Edition of Code, February 11, 2014.
[R-47] Issue Resolution Form D609, Darlingtons Governance Documents and PIP
Plans Reference Previous Edition of Code, February 11, 2014.
[R-48] Issue Resolution Form D607, NK38-REP-00770-0488763, Severe

Accidents and Beyond Design Basis Accident (BDBA) Design/SAMG,
February 11, 2014.
[R-49] CSA Standard N290.3-11, Requirements for the Containment Systems

of Nuclear Power Plants.
[R-50] Issue Resolution Form D613, NK38-REP-00770-0489529, Containment

Boundary Leakage, February 11, 2014.
Page 56 of 75
0235 AD AGGREG 0003 01

Table 1 - Shutdown Systems Acceptable Deviations
Acceptable Issue Title Safety Component Potential Attributes - Gap Bases for Associated
Deviation Significance Affected Impact on Shutdown System Applicable Acceptable AD
(AD)/Gap Component Function / (Y/ N) Deviation /
Technical Area Barriers in Place
Potentially
Affected
D021 Cleaning Solution 4

Composition Limits
Gap 00317 Cleaning Solution Guide Tubes Material property SDS1 Effectiveness Y System Chemistry None
Composition Limits - degradation Aging Management
Guide Tubes Plan
Gap 00314 Cleaning Solution LISS Nozzle Material property SDS2 Effectiveness Y System Chemistry D022
Composition Limits - Tubing degradation Aging Management
LISS Nozzles Plan
D022 Non-destructive 4 LISS Nozzle Material property SDS2 Effectiveness Y Aging Management D021
Testing of Reactor Tubing degradation Plan
Components
D029 Compliance with 3
CNSC R-8
Gap 00401 Reliability of D2O N/A N/A N/A N N/A None
Storage Tank Level
Instrumentation
Gap 00402 Full Seismic N/A N/A N/A N N/A None

Qualification of
SDS1
This document is the property of CPUS Limited and OPG. This document may be distributed by OPG to a 3 rd party (including but not limited to the CNSC) for the purposes of
validating the work including a review of the estimate, costs, scheduling and technical components. Express written agreement from CPUS Limited is required for any other distribution
or transfer.
Page 57 of 75
0235 AD AGGREG 0003 01

Potentially
Affected
Gap 00403 Test Interval for full No specific N/A SDS Reliability Y Safety System Test None
functional testing of component Program
SDS1/SDS2 Maintenance Program
D032 Trip Parameter 3 No specific N/A Safety Analysis Y Safety Analysis None
Acceptance Criteria - component Methodology
CNSC G-144
D060/D305 Shutdown System 4 D060: Trip Vendor Quality Independence and Y Vendor Quality D310
Diversity Computer Issues Diversity Requirement Requirements / Design
Termination Diversity
Modules,
Control
Equipment
Panels,
Flux Detectors
D305: Flux
Detector and
Ion Chamber
Amplifiers
D061 Special Safety 3 No specific N/A N/A N N/A None

System Design component
or transfer.
Page 58 of 75
0235 AD AGGREG 0003 01

Potentially
Affected
D245 Shutdown System 4 Start-up EQ, Seismic EQ Requirements, Y Design Redundancy D306/D310
Requirements for Instrumentation Capability Seismic Requirements Administrative Controls
Start-up Separation
Instrumentation Requirements
D261 Human Factors - ECI 3 MCR None None N N/A None

& Annunciation Annunciations
System Display and Displays
D286 ECI & Annunciation 3 No specific None None N N/A None
System - Human component
Factors Operating affected -
Experience Human factors
issues (Impact
of Human
Factors related
ADs are being
addressed
separately)
D289 Human Factors - ECI 4 MCR labeling None None N N/A None
& Annunciation
System Labels
D290 Human Factors - ECI 4 Not related to N/A N/A N N/A None
& System Dynamic Shutdown
Indication Systems
or transfer.
Page 59 of 75
0235 AD AGGREG 0003 01

Potentially
Affected
System Maintenance Shutdown
Systems
& Annunciation Shutdown
System Controls Systems
D306 Instrumentation and 4
Control Separation
Requirements
Gap 01609 SDS1 and 2 Instrument N/A Separation Y Design - Mechanical D245/D310
Pressurizer Level Tubing Requirements Protection
Trip
Gap 01603 SDS2 Pressurizer Instrument N/A Separation Y Design - Mechanical D245/D310
Level Trip Tubing Requirements Protection
Gap 01604 SDS2 Moderator Low Instrument N/A Separation Y Design - Mechanical D245/D310
Level Trip Tubing Requirements Protection
Gap 01602 SDS2 Moderator Instrument N/A Separation Y Design - Mechanical D245/D310
High Level Trip & Tubing Requirements Protection
ECIS
D310 SDS1 and SDS2 4 Instrument N/A Independence and Y Design - Mechanical D060/D305/
Steam Generator Tubing Diversity Requirement Protection D245/ D306
Feed Line Pressure Design - Redundancy
Trip
or transfer.
Page 60 of 75
0235 AD AGGREG 0003 01

Potentially
Affected
D329 Special Safety 3 (duplicate of N/A N/A N N/A None

System Design D061)
D608 Human Factors 4 No specific N/A N/A N N/A None

Design component
or transfer.
Page 61 of 75
0235 AD AGGREG 0003 01

Table 2 - ECI Acceptable Deviations
Acceptable Issue Title Safety Component Potential Impact Attributes -ECI System Gap Bases for Associated
Deviation Significance Affected on Component Function / Technical Applicable Acceptable AD
(AD)/Gap Area Potentially (Y/ N) Deviation /
Affected Barriers in
Place
D061 Special Safety 3 No specific N/A Post-Accident Y Risk D306
System Design component Monitoring Assessment
Design
Redundancy
D071 Coverings and 4 ECI Recovery Increased pressure ECIS Recovery Y Design None
Coatings within Strainers drop leading to Effectiveness Specifications
Containment inadequate ECIS Long Term Fuel Cooling Periodic
System recovery pump Inspection
NPSH Design
Assessment
Design
Modification
D261 Human Factors - 3 MCR Annunciations None N/A N/A N/A N/A
ECI & Annunciation and Displays
System Display
D286 ECI & Annunciation 3 No specific None N/A N/A N/A N/A
System - Human component affected
Factors - Human factors
Implementation issues (Impact of
Human Factors
related ADs are
being addressed
separately)
D289 Human Factors - 4 MCR labeling None N/A N/A N/A N/A
ECI & Annunciation
System Labels
or transfer.
Page 62 of 75
0235 AD AGGREG 0003 01

Place
D290 Human Factors - 4 N/A N/A N/A N/A N/A
ECI & System
Dynamic
Indication
ECI System
Ergonomics
ECI System
Maintenance
ECI &
Annunciation
System Controls
D306 Instrumentation 4
and Control
Separation
Requirements
Gap 01618 ECI Channel L Instrument Tubing N/A Separation Y Design - D307
and M Separation Requirements Mechanical
Protection
Gap 01602 SDS2 Moderator Instrument Tubing N/A Separation Y Design - D307
High Level Trip & Requirements Mechanical
ECIS Protection
Gap 01612 ECI/NPCS Instrument Tubing N/A Separation Y Design - D307
Pressure Requirements Mechanical
Transmitter Protection
Reference Legs
or transfer.
Page 63 of 75
0235 AD AGGREG 0003 01

Place
Gap 01611 ECI/NPCS Use of Pressure N/A Independence Y Physical D061/D307
Common Transmitters Requirements Separation
Pressure Design
Transmitters Redundancy
D307 Electrical 4
Separation
Requirements
Gap 01617 ECIS - Odd and ECIS Branch N/A Separation Y Design - D306
Even Supplies Interconnect Valves Requirements Electrical
Practices
Gap 01601 ECI - Common Group 1 and 2 N/A Separation Y Design - Testing D306
Fibre Optic Loop channels K, L, M Requirements Features
Administrative
Practices
Gap 01598 OH180 Programmable N/A Separation Y Design - Fail D306
Programmable Controllers Requirements Safe Practice
Controllers
Gap 01607 Interlock and Group 1 and 2 N/A Separation Y Design - D306
Control Logic with Cables Requirements Diverse
Fibre Optic Loops Materials
D329 Special Safety 3 (duplicate of D061) N/A N/A N N/A None
System Design
D608 Human Factors 4 No specific N/A N/A N N/A None
Design component
or transfer.
Page 64 of 75
0235 AD AGGREG 0003 01

or transfer.
Page 65 of 75
0235 AD AGGREG 0003 01

Table 3 Containment Acceptable Deviations
Acceptable Issue Title Safety Component Potential Impact on Attributes- Gap Bases for Acceptable Associated
Deviation Significance Affected Component Containment System Applicable Deviation/Barrier AD
(AD)/Gap Function / Technical (Y/ N) Credited
Area Potentially
Affected
D010 Changes to Examination 4 Containment Material Properties Containment Integrity Y Periodic Inspection D014/D015/
and Testing Structures not meeting Program D017/D018/
Requirements for Specifications In-Service Testing D071/D159/
Concrete Structures D309/D357
D013 Long Term Control of 4 N/A N/A N/A N/A N/A N/A
Hydrogen in
Containment
D014 Anchorage System 4 Containment Material Properties Containment Integrity Y Program D010/D015/
Requirements in Structures not meeting In-Service Testing D017/D018/
Concrete Containment Specifications Vendor Quality and D071/D159/
Requirements Testing Program D309/D357
D015 Requirements for 4 Containment N/A Containment Integrity Y Safety Related Test D010/D014/
Penetrations of the Boundary Program D017/D018/
Containment Structure D071/D159/
D309/D357
D017 Redundancy of 4 Containment Quality Assurance Containment Integrity Y Periodic Inspection D010/D014/
Mechanical Splices in Structures associated with Program D015/D018/
Concrete Containment Reinforcing bars In-Service Testing D071/D159/
Structures D309/D357
or transfer.
Page 66 of 75
0235 AD AGGREG 0003 01

Area Potentially
Affected
D018 Maximum Concrete 3 Containment Material Properties Containment Integrity Y Periodic Inspection D010/D014/
Tensile Stresses for Structures not meeting Program D015/D017/
Liners of Concrete Specifications In-Service Testing D071/D159/
Containment Structures D309/D357
D061 Special Safety System 3 No specific N/A Post-Accident Y Risk Assessment D306/D307
Design component Monitoring Design Redundancy
D062 Post-Accident 4 N/A N/A N/A N N/A N/A

Monitoring Availability
D071 Coatings and Coverings 4 Containment Containment Containment Integrity Y Design Specifications D010/D014/
Within Containment Structures Leakage Reduction of Airborne Periodic Inspection D015/D017/
System Fission Products Program (Coatings and D018/D159/
Safety Analysis liners) D309/D357
D159 Inspection Access 4 Containment Pressure Boundary Containment Integrity Y Periodic Inspection D010/D014/
Requirements in CSA Components Integrity Program (alternate D015/D017/
N285.5-M90 methods) D018/D071/
D309/D357
D164 Start of PIP Inspection 4 N/A N/A N/A N N/A N/A
Interval
D261 Human Factors - ECI & 3 N/A N/A N/A N N/A N/A
Annunciation System
Display
D286 ECI & Annunciation 3 N/A N/A N/A N N/A N/A
System - Human
Factors Operating
Experience
or transfer.
Page 67 of 75
0235 AD AGGREG 0003 01

Area Potentially
Affected
Annunciation System
Labels
System Dynamic
Indication
D292 Human Factors - ECI 3 N/A N/A N/A N N/A N/A
System Maintenance
Annunciation System
Controls
D302 Extension of the 4 Containment N/A Containment Isolation Y Operator Action D308/D309
Containment Envelope Components Administrative Controls
D306 Instrumentation and 4
Control Separation
Requirements
Gap 01612 ECI/NPCS Pressure Instrument N/A Separation Y Design - Mechanical D307/D309
Transmitter Reference Tubing Requirements Protection
Legs
Gap 01611 ECI/NPCS Use of Pressure N/A Independence Y Physical Separation D061/D307
Common Pressure Transmitters Requirements Design Redundancy
Transmitters
D307 Electrical Separation 4
Requirements
Gap 01598 OH180 Programmable Programmable N/A Separation Y Design - Fail Safe D306
Controllers Controllers Requirements Practice
or transfer.
Page 68 of 75
0235 AD AGGREG 0003 01

Area Potentially
Affected
Gap 01605 Containment Button-up Fibre Optic N/A Separation Y Design - Electrical D306
System Loop Requirements Practices
Gap 01607 Interlock and Control Group 1 and 2 N/A Separation Y Design - Diverse D306
Logic with Fibre Optic Cables Requirements materials
Loops
Gap 01608 Containment Boundary Containment N/A Separation Y Design - Seismic D306
Modifications at 3381- Isolation Valve Requirements Qualification and
PV26 Assessment
D308 Electrical Shield 4 Activity N/A Containment Isolation Y Operations Monitoring D302/D309
Grounding Monitors
D309 Extension of the 4
Containment Envelope
Gap 01594 DGE: Tubing Containment N/A Containment Integrity Y In-Service Testing D010/D014/
Penetrations Components D015/D017/
D018/D071/
D159/D306/
D357
Gap 01595 DGE: H2O in D2O Containment N/A Containment Isolation Y Design - Mechanical D302/D308
Components Protection
D329 Special Safety System 3 (duplicate of N/A N/A N N/A None
Design D061)
D357 Frequency of Leakage 4 Containment Containment Containment Integrity Y Periodic Inspection D010/D014/
Rate Tests on Negative Structures Leakage Program D015/D017/
Pressure Containment In-Service Testing D018/D071/
D159/D309
D358 Lack of Certified Mill 4 N/A N/A N/A N N/A N/A
Test Report Records
or transfer.
Page 69 of 75
0235 AD AGGREG 0003 01

Area Potentially
Affected
D564 Darlingtons Governance 4 N/A N/A N/A N N/A N/A
Documents and PIP
Plans Reference
D607 Severe Accidents and 2 Containment Core Concrete Severe Accidents Y Design Modification
Beyond Design Basis Structures Interaction Containment Integrity
Accident (BDBA)
Design/SAMG
D608 Human Factors Design 4 No specific N/A N/A N N/A None
component
D609 Darlingtons Governance 4 N/A N/A N/A N N/A N/A
Documents and PIP
Plans Reference
D613 Containment Boundary 4
Leakage
Gap Limits for Liquid N/A N/A N/A N/A N/A N/A
02304 Releases
Gap Design Requirements N/A N/A N/A N/A N/A N/A
02305 for Embedded Parts to
be Leaktight
Gap Requirement for N/A N/A N/A N/A N/A N/A
02306 Electrical EPs to be
Tested for Leaktightness
Gap Requirement for Two N/A N/A N/A N/A N/A N/A
02307 Isolation Barriers for
HTS Penetrations
or transfer.
Page 70 of 75
0235 AD AGGREG 0003 01

Area Potentially
Affected
Gap Requirement of Barriers N/A N/A N/A N/A N/A N/A
02308 for HTS Penetrations
or transfer.
Page 71 of 75
0235 AD AGGREG 0003 01

Table 4 Acceptable Deviations Common Across Special Safety Systems

Attribute Common Across Applicable Acceptable Deviations Aggregate
SSS? SDS1 SDS2 ECI Containment Assessment
Required?
Administrative Controls
D245 D245 D307
Y D302 Y
Design - Mechanical Protection
D306/D310 D306/D310 D306
Y D306 Y
Design Redundancy
D245 D245 D061/D306
Y D061/D306 Y
Periodic Inspection Program/AMP
D021/D022 D021/D022 D071
Y Multiple Y
Safety System Test Program
D029 D029 -
Y D015 Y
Vendor Quality
D060/D305 D060/D305 -
Y D014 Y
Independence and Diversity
Requirement D060/D305/ D310 D060/D305 D306
Y D306 Y
Safety Analysis
D032 D032 -
Y D071 Y
Separation Requirements
D245/D306 D245/D306 D306/D307
Y D306/D307 Y
Design Modification
- - D071
Y D607 Y
Design - Diverse Materials
D307
Y - - D307 N
or transfer.
Page 72 of 75
0235 AD AGGREG 0003 01


Required?
Design Electrical Practices
D307
Y - - D307 N
Design Fail Safe Practices
D307
Y - - D307 N
Design Specifications
Y - - D071 D071 N
Physical Separation
Y - - D306 D306 N
Post-Accident Monitoring
Y - D061 D061 N
Containment Integrity
N - - - - N
Containment Isolation
N - - - - N
ECIS Recovery Effectiveness
N - - - - N
EQ Requirements
N - - - - N
Long Term Fuel Cooling
N - - - - N
Reduction of Airborne Fission Products
N - - - - N
Risk Assessment
N - - - - N
SDS Reliability
N - - - - N
or transfer.
Page 73 of 75
0235 AD AGGREG 0003 01


Required?
SDS1 Effectiveness
N - - - - N
SDS2 Effectiveness
N - - - - N
Seismic Requirements
N - - - - N
Aging Management Plan
N - - - - N
Design Diversity
N - - - - N
Design - Seismic Qualification
N - - - - N
Design - Testing Features
N - - - - N
Design Assessment and Modification
N - - - - N
In-Service Testing
N - - - - N
Maintenance Program
N - - - - N
Operations Monitoring
N - - - - N
Operator Action
N - - - - N
Periodic Inspection Program (alternate
methods) N - - - - N
or transfer.
Page 74 of 75
0235 AD AGGREG 0003 01


Required?
Periodic Inspection Program (Coatings

and Liners) N - - - - N
Safety Analysis Methodology - -

N - - N
Severe Accidents
N N
System Chemistry - -
N - - N
or transfer.
Page 75 of 75
ONTARIO FiiiiER Report
Document Number:
NK38-REP-03680-10199
N/A
N/A R001
Title:
EVALUATION OF DARLINGTON NGS FIRE PROTECTION ISR ACCEPTABLE DEVIATION

ISSUES FOR AGGREGATE EFFECTS OF COMBINATIONS OF THE GAPS
Evaluation of Darlington NGS Fire

Protection ISR Acceptable Deviation
Issues for Aggregate Effects of
Combinations of the Gaps
NK38-REP-03680-10199-R001
Accepted by: /~Authorized by:

e mtiaz Malek
Manager, Director, Nuclear Safety
0235 AD AGGREG 0004 01
Evaluation of Darlington NGS Fire Protection ISR Acceptable Deviation

Issues for Aggregate Effects of Combinations of the Gaps
Prepared by: May 26, 2014

J.M. Cuttler, P.Eng. Date
Technical Specialist
Reviewed by: May 27, 2014

K.C. Garel Date
Consultant CPUS Ltd
Accepted by: May 28, 2014

VP Engineering
scheduling and technical components. Expressed written agreement from CPUS Limited or OPG is required for any other
Page 1 of 77
0235 AD AGGREG 0004 01

Record of Revisions
Rev. Date Description Prepared by Reviewed by Accepted by
00 2013 11 08 33 ISR ADs assessed J.M. Cuttler K.C. Garel M.J. Jansen
for aggregate effects R.J. Ravishankar
of gaps
01 2014 05 26 52 additional ADs J.M. Cuttler K.C. Garel M.J. Jansen
were added and
assessed, increasing
the total to 85 ADs.
The additional ADs
are:
D044, D045, D048,
D080, D115, D116,
D181, D215, D225,
D226, D227, D251,
D428, D429, D439,
D445, D446, D452,
D461, D464, D466,
D469, D472, D473,
D475, D476, D477,
D479, D482, D506,
D507, D509, D510,
D511, D512, D513,
D514, D515, D516,
D517, D519, D520,
D522, D523, D524,
D525, D526, D527,
D528, D529, D530,
D607
This changed all
sections of the report
except Section 3.1.
Appendix 2 was
added.
Page 2 of 77
0235 AD AGGREG 0004 01

SUMMARY
The Integrated Safety Review (ISR) for Darlington NGS (DNGS) includes a code
compliance review, which identified gaps against requirements specified in clauses of
current codes and standards. Similar gaps were combined into ISR Issues consisting
of one or more gaps. The fire protection (FP) code compliance review was performed
by external third party, FP-qualified, individuals. They produced Issue Resolution
Forms (IRFs) that resolved the gaps as Closed, Acceptable Deviations (ADs) or
Requiring Resolution. This report refers to ISR Issues as Acceptable Deviations
(ADs) when they have a low or very low overall safety significance that has been
dispositioned in their IRFs as No further action required [R-96].
In the study documented in Revision 0 of this report, 33 ADs were examined. The
initial review identified gaps that could be excluded from the assessment of aggregate
effects. This resulted in the elimination of 19 ADs, and the aggregate effects of the
14 remaining ADs were determined.
Subsequent to the issue of Revision 0 of this report, it was identified that 51 additional
fire protection ADs had not been included in this assessment. Revision 1 of this
report included the evaluation of these 51 ADs, bringing the total to 84 ADs. OPG
carried out an additional analysis for gaps that required resolution, and this resulted in
one more AD.
Using the same process as in Revision 0 report, the report now excludes many gaps
from the 85 ADs, which resulted in the elimination of 48 ADs. The aggregate effects
of the remaining 37 ADs on public safety, which includes nuclear safety, were
determined in this report.
Attributes were assigned to each AD using a pre-defined set of attributes as a guide.

When it was observed that attributes were common to more than one AD, these ADs
were grouped together. The aggregate impact of each combination of ADs was then
assessed.
The results of this assessment concluded that when the ADs with common attributes
were assessed as a group, there were no aggregate impacts and hence no significant
impact on public safety, which includes nuclear safety.
The above conclusion is further supported by the conclusions of an additional review,

which is documented in Review of Fire Code Acceptable Deviations and
Refurbishment Modifications for Impact on DNGS Fire PRA [R-39], that none of the
ADs were found to have any potential impact on the DNGS Fire PRA either singularly
or collectively.
Page 3 of 77
0235 AD AGGREG 0004 01

Table of Contents
SUMMARY ...................................................................................................................... 3
1 Introduction.............................................................................................................. 5
1.1 Scope .............................................................................................................. 5
1.2 Purpose ........................................................................................................... 5
2 Methodology ............................................................................................................ 6
3 Assessment ............................................................................................................. 7
3.1 Identification of fire protection (FP) barriers ..................................................... 7
3.2 IRF Summary and exclusion of gaps from aggregate review ........................... 7
3.3 Assessment of ADs collectively for aggregate effects ...................................... 8
4 Conclusions and recommendations ....................................................................... 23
5 References ............................................................................................................ 24
Appendix 1: Summary of accepted gap resolutions in 85 ADs....................................... 31
Appendix 2: Acceptable Deviation Gaps that were examined in this evaluation report for
Aggregate Effect ........................................................................................................... 70
Page 4 of 77
0235 AD AGGREG 0004 01

1 Introduction
1.1 Scope
An Integrated Safety Review (ISR) was performed to support the life extension of the
Darlington Nuclear Generating Station (DNGS). To assess its level of safety against
modern nuclear power plants, the ISR included a code compliance review of DNGS
design documentation, programs and policies against the requirements of modern
Codes and Standards. ISR gaps were identified where compliance with modern
Codes and Standards could not be readily confirmed. Similar gaps were combined
into ISR Issues. The fire protection (FP) code compliance review was performed by
external third party FP-qualified individuals, who produced Issue Resolution Forms
(IRFs) that resolved the gaps as Closed, Acceptable Deviations or Requiring
Resolution. This report refers to ISR Issues as Acceptable Deviations (ADs) when
they have a low or very low overall safety significance that has been dispositioned in
their IRFs as No further action required [R-96]. However, different ADs can interact
and impact collectively on the same components, systems or programs that constitute
barriers against risks to public safety, which includes nuclear safety. Hence,
assessments were carried out on the aggregate effects of combinations of ADs to
identify the presence of any aggregation that could impact collectively on the barriers.
This report presents the assessment of the potential aggregate impact of FP-related
ADs that were identified as part of the Darlington NGS Integrated Safety Review and
in subsequent related reviews (e.g., CNSC comments on the ISR). In Revision 0 of
this report, 33 FP ISR Issues, which had been resolved in the Issues Resolution
Forms (IRFs) as ADs, to determine the aggregate effects of these ADs on public
safety, which includes nuclear safety, were examined.
Subsequent to the issue of Revision 0 of this report, it was identified that 51 additional
fire protection ADs had not been included in this assessment. OPG carried out an
additional analysis for gaps that required resolution, and this resulted in one more
AD. Revision 1 of this report, examines these additional 52 ADs to determine the
aggregate effects of 85 ADs on public safety, which includes nuclear safety.
1.2 Purpose
The purpose of this study is to assess whether there is any aggregate effect from the
85 Fire Protection ADs, which could adversely affect public safety, which includes
nuclear safety.
Page 5 of 77
0235 AD AGGREG 0004 01

2 Methodology
The methodology that was used for this aggregate review is as follows:
1. The safety significance and resolutions of the gaps in each AD, documented in
Section E of its IRF were examined, and summarized. The resultant summaries
appear in Appendix 1 of this report. A list of the gaps that were classified as ADs
appears in Appendix 2, in gap number order.
2. Appendix 1 also documents the rational for excluding from further consideration
those gaps that are designated as Requiring Further Resolution, identifying an
Action Request (A/R), or as moved to a different ISR Issue. In a number of
instances the resolution in the IRF documented that the intent of the code or
standard was met through alternate means. In most cases, the information
demonstrated adequate compliance for the purpose of assessing the aggregate
effects of combinations of gaps. The gaps for those cases were also excluded
from the evaluation.
3. The remaining AD gaps were tabulated in Section 3.3, and assigned attributes
based on the fire protection (FP) component, system or program affected and on
fire-protection barriers.
4. The ADs with common attributes were then grouped and assessed for aggregate
effects. Evaluations were then carried out for the significances of any aggregate
effects of the ADs.
Page 6 of 77
0235 AD AGGREG 0004 01

3 Assessment
3.1 Identification of fire protection (FP) barriers

Fire is a very important consideration in the design and operation of the station with
respect to both safety and economics [R-1], Appendix 11.7.1. It affects employee
safety (injuries or deaths) and public safety (fire-induced releases of radioactivity).
The economic issues are loss of production, damage to equipment and loss of public
confidence in the safety of the nuclear station. The FP measures, incorporated into
the station design, construction and operation, reduce the likelihood of fire and its
consequences to as low as reasonably achievable. The basic FP strategy,
particularly for nuclear safety, is the physical separation of safety-related systems.
3.2 IRF Summary and exclusion of gaps from aggregate review

Appendix 1 summarizes the information for the 85 ADs, which are:
D041 [R-2] D226 [R-49] D452 [R-56] D473 [R-62] D513 [R-74]
D044 [R-40] D227 [R-50] D453 [R-19] D474 [R-30] D514 [R-75]
D045 [R-41] D233 [R-10] D454 [R-20] D475 [R-63] D515 [R-76]
D048 [R-42] D251 [R-51] D455 [R-21] D476 [R-64] D516 [R-77]
D052 [R-3] D298 [R-11] D456 [R-22] D477 [R-65] D517 [R-78]
D076 [R-4] D428 [R-91] D457 [R-23] D478 [R-31] D519 [R-79]
D080 [R-43] D429 [R-52] D458 [R-24] D479 [R-66] D520 [R-80]
D110 [R-5] D437 [R-12] D461 [R-57] D480 [R-32] D522 [R-81]
D115 [R-44] D438 [R-13] D462 [R-25] D481 [R-33] D523 [R-82]
D116 [R-45] D440 [R-14] D463 [R-26] D482 [R-67] D524 [R-83]
D125 [R-6] D443 [R-15] D464 [R-58] D492 [R-34] D525 [R-84]
D171 [R-7] D447 [R-16] D465 [R-27] D506 [R-68] D526 [R-85]
D176 [R-8] D450 [R-17] D466 [R-59] D507 [R-69] D527 [R-86]
D181 [R-46] D451 [R-18] D469 [R-60] D509 [R-70] D528 [R-87]
D215 [R-47] D439 [R-53] D470 [R-28] D510 [R-71] D529 [R-88]
D222 [R-9] D445 [R-54] D471 [R-29] D511 [R-72] D530 [R-89]
D225 [R-48] D446 [R-55] D472 [R-61] D512 [R-73] D607 [R-90]
Appendix 2 is a list of the 234 gaps that were examined, in gap number order. Nearly
all of them are ADs.
The second step of the methodology is removal of gaps that are not appropriate for
further consideration of the aggregate effects of ADs in combination. The information
in each IRF was reviewed, and the Summary and Disposition columns in Appendix 1
give the reasons for excluding gaps.
Page 7 of 77
0235 AD AGGREG 0004 01

Some of the IRFs removed gaps that are being resolved separately in other ISR
Issues; 16 gaps are being resolved in D430 [R-92], two in D431 [R-93] and one in
D442 [R-94]. These 19 gaps are therefore outside the scope of this evaluation.
Removal of gaps from the 85 ADs resulted in the exclusion of the following 48 ADs:
D048, D076, D116, D125, D215, D226, D233, D298, D428, D429, D440, D445,
D446, D447, D451, D456, D461, D462, D463, D464, D466, D469, D470, D471,
D473, D474, D477, D478, D480, D481, D482, D492, D507, D509, D510, D511,
D512, D513, D515, D517, D519, D520, D522, D526, D527, D529, D530 and D607.
The remaining 37 ADs, a total of 80 gaps, are against one or more of the following
codes and standards: NFCC 2005 and 2010; CAN/CSA N293-2007 and -2012;
NBCC 2005 and 2010; NFPA-20 2007 and 2013; NFPA-24 2007 and 2013; CNSC
RD-337 and ASME N509-2002. The ADs are assessed collectively in Section 3.3.
3.3 Assessment of ADs collectively for aggregate effects

The 37 ADs evaluated for aggregate effects are listed in Table 1 below. Attributes
were assigned according to:
1) fire protection component, system or program affected, and the impact of the AD
2) defense-in-depth barrier affected, and the mitigation credited.
Then the ADs with common attributes were examined to identify significant collective
interactions that could affect safety.
3.3.1 Component or System
3.3.1.1 Building issues

Eight (8) ADs associated with building issues: D080, D110, D438, D450, D452, D458,
D514 and D516, were examined for interactions between gaps.
D080, about lack of fire separations between floors and areas within each building
and between buildings, credits DNGS as a special unusual structure that the code
recognizes. In this regard, it is similar to D450, about building height and mezzanine
effects, which includes also OPG procedural controls. They are related to D110, on
smoke infiltration into the operator travel route between the MCR and the SCA. The
combination of these three ADs does not present a significantly increased risk to
safety because the buildings are designed to good fire protection practice and OPGs
good procedural controls, including the mitigation measure for the potential hazard in
D110. These ADs have no commonality with the other five ADs in this combination.
D438 (against CSA N293-07) is about the lack of window openings and hatches that
provide access to fighting fires, which is the same concern that is identified in D458
(against NBCC 2005). D514 and D516 are about the lack of enclosed passageways
to access the fire pump rooms. The justifications for accepting D514 and D516 are
Page 8 of 77
0235 AD AGGREG 0004 01

not significantly affected by acceptance of D438/D458. These four ADs are different
from the other ADs in Section 3.3.1.1, so there is no aggregate effect.
D452 on the area of and distance between unprotected openings in the D2O and
TRF Annex buildings are different from the other seven ADs.
In conclusion, based on the above discussions, there are no significant aggregate
effects for any combinations of the eight building-related ADs.
3.3.1.2 Fire suppression systems

Fourteen (14) ADs are related to fire suppression systems: D041, D045, D052, D171,
D225, D227, D443, D472, D475, D476, D479, D514, D516 and D523.
D041 identifies a lack of posted instructions and markings on the valves and controls
of the CO2 fire suppression system in the EPS fuel building/room. It is related to
D052, on lack of function information on firewater valve labels. Fire suppression
activity is restricted primarily to the ERT; both of these ADs are addressed by ERT
training, knowledge and periodic drills. The combination of these two ADs does not
present a significantly increased risk to safety.
D045 is about limiting fire extinguisher use to the ERT. It also identifies the lack of a
pre-alarm for CO2 discharge in the EPG fuel building that is related to the fire alarm
system, assessed below. Minor standpipe non-compliances are also identified, which
are mitigated by the ERT response.
D171 points out the lack of a fire extinguisher at each charging station for battery-
powered trucks. During charging, the battery remains on the truck, which has an
extinguisher. Also, ERT bring additional fire fighting equipment (extinguishers, hoses
and booster pumps) to the fire location.
D225 addresses the lack of two separate ESW connections to the D2O management
building, the water treatment plant and the unit pumphouses. ERT action is credited
to control a potential fire in any of these low-hazard buildings.
D443 is about the lack of extinguishers at 276 locations, non-compliant fire hose
cabinets (FHCs) and hose connections. The plant has many extinguishers, FHCs,
hoses, booster pumps and fire-fighting procedures. The ERT and selected workers
have been trained to be capable of suppressing all potential fires effectively, which
includes having the proper equipment to do so. Also, ERT bring additional fire fighting
equipment (extinguishers, hoses and booster pumps) to the fire location. D472,
which is about extinguishers and FHCs at the indoor EPG oil storage tanks, is related
to D443 in crediting action by ERT and selected workers. Specific design features of
the EPG tank installation are also credited for acceptance of this issue. The
combination of the two ADs does not present a significantly increased risk to safety.
D475 is about lack of an alarm on each standpipe system valve, lack of valves to
disconnect other systems using the same supply as the sprinkler system, two
Page 9 of 77
0235 AD AGGREG 0004 01

hydrants near the VB that have buried non-indicating gate valves, the use of outside
screw and yoke (OS&Y) type gate valves instead of listed post-indicator valves for the
connection from the fire main to the building. D227 has gaps regarding fire hydrants
that are similar to gaps in D475. The combination of these two ADs does not
increase safety risks significantly because of OPG governance and the credited ERT
actions.
D476 is about the lack of information on the dimensions of every piping component
that was installed in the underground firewater piping. This issue is not related to any
of the other 13 ADs pertaining to fire suppression systems.
D479 is about the means of disconnecting electrical power to pumps. This issue is
not related to any of the other 13 ADs pertaining to fire suppression systems.
D514 and D516 are about the lack of enclosed passageways to access the fire pump
rooms that has been assessed in Section 3.3.1.1 on building issues. These ADs
credit the pumps being in areas with low combustible loading (low exposure to fire)
and the ability of the ERT to reach the pump or connect to a pump in an adjacent
reactor unit.
D523 is about valves being designed to comply with pressure and temperatures
requirements. This issue is not related to any of the other 13 ADs pertaining to fire
suppression systems.
Assessing these 14 ADs for aggregate effects, D476, D479 and D523 have nothing in
common with each other, or with the other 11 ADs. The ADs D041 and D052 have
nothing in common with the others except for their dependence on knowledgeable
ERT personnel who can identify and operate the valves and controls correctly. D225
is independent of the other 13 ADs, but credits ERT action in the very unlikely event
of a fire in one of the three low-hazard buildings and a simultaneous failure of its
ESW connection. D475 and D227 are independent of the other 12 ADs; their
acceptance is based on OPG governance and ERT knowledge and periodic drills.
D514 and D516 are also independent of the other 12 ADs except for reliance on the
ERT to either access a firewater pump surrounded by fire or connect to the pump
located in the adjacent reactor unit. Four ADs: D045, D171, D443 and D472, have
common gaps that have been resolved by OPG governance (procedures, training,
design documents, etc.) and by crediting ERT knowledge and rapid response to
suppress potential fires. When OPG governance and rapid ERT response are taken
into account, there are no significant aggregate effects for any combination of these
14 fire suppression ADs and hence there is no significant impact on public safety,
which includes nuclear safety.
3.3.1.3 Fire alarm system and communication system

These systems are affected by the following eight (8) ADs: D044, D045, D222, D453,
D454, D455, D506 and D528.
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D044 requires a 2-stage alarm system that provides an initial alert signal throughout
the building to be followed by an automatic 5-minute audible alarm, if the alert signal
is not acknowledged. This issue also requires a single-stage alarm in small buildings
(pumphouses and the water treatment plant) and requires the alarm system to be in
the MCR instead of the CER. D506 requires the display and control centre be
located in the MCR and in each SCA; the U0 operator is required to be able to control
the system without having to leave the MCR panel. In the established OPG process,
the U0 operator receives the initial alert in the MCR, goes to the CER and then
sounds a special alarm for the ERT to suppress the fire. The U0 operator orders an
evacuation, if this is required. The staff in small buildings phone 911 to reach the U0
operator.
D045 requires the CO2 system in the EPG fuel building to provide a pre-discharge
fire alarm.
D222 requires a public address (PA) system that provides integrated, supervised
one-way voice communication throughout the plant. The alarm signals and voice
announcements are to be audible and intelligible in all accessible locations. This is
achieved by a monitoring program of periodic inspection, testing and maintenance of
the PA system. The U0 operator has a very important role and responsibility in
complying with the requirements and integrating the information on the panels in the
MCR and the CER.
D453 requires the alarm system or the use of firewater to automatically send a signal
to the local fire department (in Clarington).
D454 requires that annunciators be located at building entrances to facilitate fire
fighting by the local fire department.
D455 requires that the automatic system have audible and visual alarm devices (to
warn employees) and incorporate more extensive electrical supervision. It has much
in common with D222, the PA system gaps.
D528 requires acceptable audibility of the PA system. It is closely related to D222,
the PA system.
D045 regarding a pre-discharge alarm is related to D044; however DNGS does not
have a 2-stage alarm system. D044 and D045 have no commonality with the other
fire alarms system ADs, namely D453, D454 and D455. These are different from
OPGs process of sending all the alarm signals to the U0 operator, who is required to
1) initiate alarms to the ERT, 2) notify the local fire department of the location of a fire
(request support if needed) or of any issues with the fire alarm equipment, 3) order an
evacuation if needed, or 4) request Maintenance to repair faulty equipment. D222 is
about the PA system that is related to D528, regarding audibility of the PA system.
The aggregate effect on safety of combinations of these ADs is very small because of
the U0 operators training, experience and capabilities and the known effectiveness of
OPG governance with the existing fire alarm system and PA system. Therefore, the
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fire alarm system and communication system ADs have a negligible aggregate effect
on safety.
3.3.1.4 Air-cleaning units

D251 on the requirement for fire protection of the air-cleaning units has commonality
with D044 requiring a 2-stage fire alarm system, D457 requiring prevention of smoke
circulation by fan shutdown and D439 requiring protection of the charcoal filters by
preventing their temperatures from rising to the 330C ignition point. The ERT is
credited to prevent charcoal filter ignition by spraying fire water on the housings after
the U0 operator receives an alarm. The combination of these ADs has been
considered in the assessment of fan shutdown, which is not provided because it
would have a negative impact on nuclear safety.
3.3.1.5 Elevators
D465 and D525 pertain to the elevators. The first is about accommodating a patient
stretcher, and the second is about the smoke detector in each the elevator machine
room, which does not have the elevator recall feature. There is nothing in common
between these two elevator gaps. Because D465 credits ERT skill and training to
remove stretcher patients, it has commonality with other ADs that credit the ERT.
3.3.1.6 Chemical laboratories

D115 and D176 are about posting warning signs in the Chemistry Lab, preparing a
fire-fighting plan and carrying out training drills to be able to respond promptly and
effectively to a fire that could occur there due to presence of flammable agents.
Analysis of a D115 gap that would require different fume hoods and damper changes
demonstrated the existing design to be adequately safe. An examination of these
similar ADs in combination does not indicate an increased likelihood of a safety
concern. There is commonality between these ADs and the other ADs that credit
excellent OPG governance and ERT response.
3.3.2 Defence-in-depth levels or fire protection barriers
3.3.2.1 Prevention
Fires are prevented by properly designing systems that will not leak, overheat nor
cause an electrical discharge. Flammable materials are either avoided or isolated
from ignition sources with posted warning signs. Inspection and maintenance work is
performed periodically to avoid equipment failures that could lead to the ignition of
flammable materials. The following eight (8) ADs are related to fire prevention:
D080, D115, D176, D439, D450, D472, D523 and D524. Building related ADs, D080
and D450, were assessed for aggregate effects in Section 3.3.1.1. The Chemistry
Lab ADs, D115 and D176, were discussed in Section 3.3.1.6 and are not related to
the building ADs. D439 is about preventing fire inside the charcoal filter housings.
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D472 on oil tank piping is somewhat related to D523 on proper valve design (new
code vs. the OPG design and construction manual), but the combination of these ADs
does not indicate any significant increase in concern. These two ADs are not related
to the building or the Chem Lab ADs or the charcoal filter AD. D524, smoke
characteristics of electrical wires and cables, has no commonality with any other ADs
in this section on fire prevention. Therefore, combinations of these ADs have a
negligible aggregate effect on safety.
3.3.2.2 Detection
Fires are detected by automatic smoke detectors and by nearby human occupants
who manually activate fire alarms or telephone the MCR. Five (5) ADs associated
with fire detection are: D044, D045, D453, D454 and D525. D044 on the lack of a 2-
stage fire alarm system is related to D045, which identified that the CO2 system for
the EPG fuel building does not have a pre-discharge alarm. The combination of
these ADs does not have a significant impact on safety. D453 and D454 are related,
but their combination has no increased effect; the U0 operator can manage both
readily. D525 on adding elevator recall when smoke detected in the elevator
machine rooms is unrelated to any other AD. The aggregate effects of any
combination of these gaps do not increase risk.
3.3.2.3 Suppression
In addition to the 14 ADs that were assessed in Section 3.3.1.2 on fire suppression
systems, the following four (4) ADs affect fire suppression: D222, D438, D453 and
D454. D222 includes notifying the ERT to respond to a fire alarm. D438 (CSA N293-
07) is the same as D458 (NBCC 2005), and pertain to the ERTs capability to enter
the buildings to suppress fire. D453 and D454 are related to the fire alarm system
not being designed to inform the local fire department of a fire and facilitate its
participation in fire suppression. The IRFs credit DNGS procedures and U0 Operator
training and action. The only commonality apparent for these 4 ADs with those
assessed in Section 3.3.1.2 is their dependence on ERT and the U0 operator action.
The aggregate effects of any combination of these gaps do not increase risk.
3.3.2.4 Minimization of consequences

The ADs associated with minimizing the consequences of fire for employees, the
public and the station are: D044, D222, D525 and D528 (evacuation), D110 (smoke
in the route to the SCA), D115 and D176 (Chemistry Lab evacuation), D437 (2-hour
emergency lighting), D455 (audible fire alarm), D465 (elevator capacity for stretcher)
and D439 (charcoal filter). None of these ADs has any significant aggregate effects
in combination with any of the others.
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3.3.3 U0 Operator, ERT and staff training and action

When the U0 operator, ERT and staff training and their actions are credited, the
assessments in Sections 3.3.1 and 3.3.2 demonstrate there is no aggregation or
negligible aggregation between the 37 ADs when they are grouped into combinations
that are based on the attributes that have been assigned. This assessment
concludes that there is no significant impact on public safety, which includes nuclear
safety.
The resolutions in the IRFs for many of the ADs reviewed in this assessment of
aggregate effects credit U0 Operator and/or ERT training, experience and actions.
While ERT and U0 Operator actions are common factors, this assessment notes that
the ERT members and U0 Operators are highly trained and experienced in
preventing and fighting fires. Reference [R-35] describes the OPG nuclear fire
protection training and qualification requirements for OPGN Fire Protection. ERT
members carry out drills to practice their emergency response skills, which include
fighting fires. Furthermore, the DNGS policies and programs in OPGs nuclear
Training program [R-36] ensure Operators are well trained to perform their duties and
remain qualified to do so. Finally, OPG has ensured that rigorous error reduction
techniques are used during normal operation and accident management, as
described in OPGs nuclear programs on Human Performance [R-37] and Nuclear
Operations [R-38]. Therefore, it is concluded that the aggregate impacts of these
thirty-seven (37) Fire Protection ADs are negligible and, hence, there is no impact on
public safety, which includes nuclear safety.
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Table 1: Assessment of combinations of 37 ADs for aggregate effects
Attribute
Acceptable Deviations Basis in IRF for
Component, Effect on Defence-in- Mitigation Accepting Gaps
System or Component, Depth Barrier Credited in as Acceptable
Program System or for DNGS Fire IRF Deviations
Affected Program Protection
D041 [R-2] Special Fire Fire suppression Improper Suppress fire in ERT training ERT training and
Suppression System CO2 system in operation or EPG fuel and actions periodic drills
Requirements EPS fuel maintenance management OPG error OPG error
Gap 00415, Item 7 & 8 management leading to fire building and reduction reduction
building and fuel fighting failure fuel storage
No O&M instructions storage room room
posted; no marking of
valves and controls
D044 [R-40] Fire Alarm Fire alarm system The initial Detection for Alert signal Established OPG
Systems alert signal of earlier action to appears in the process whereby
Gap: 00535 00536 00537 a 2-stage suppress fire CER & MCR U0 operator sees
require 2-stage alarm; no system is and evacuate. fire-indicating initial alert in MCR/
initial alert signal in DNGS missing. panels. CER. Operator
Delay in fire U0 operator sounds ERT alarm
fighting action receives input
& evacuation device signal; U0 operator orders
Gap 00538 requires small Pumphouse & he sounds evacuation, if
building to have single- WTP staff ERT alert required
stage fire alarms; none phone 911 within 1minute
Staff training and
Gap 00540 MCR to be Move alarm U0 operator is high temperature
central alarm control system from accustomed to alarms on motors
Gap 01880 requires auto CER to MCR CER location
audible alarm signal 5 min Delay in Staff training
after fire initiating device, evacuation & temperature
if alert not acknowledged alarms on
pump motors
D045 [R-41] Fire Fire suppression Small fires, Earlier action to ERT trained in ERT prompt
Suppression not stopped extinguish fires; effective use response and
Gaps 00547, 01270, by occupants, human factors; of extinguisher training to use fire
01286, 01287, 01846, grow larger; effectiveness of ERT arrives extinguishers and
01850 and 02112 identify lack of CO2 systems that promptly other suppression
extinguishers limited to alarm is not extinguish fires systems effectively
so important; Existing CO2
ERT only, CO2 system in and standpipe
EPG fuel bldg has no pre- standpipe
configuration systems are
discharge alarm, and acceptable
standpipes to be ADs is not concern
with credit for
ERT action
D052 [R-3] Identification Firewater service Delay to Suppress fire, DNGS label DNGS labels on
Signs for Fire Service valves locate and with firewater on each valve firewater valves
Valves operate hoses and ERT and ERT training
Gap 00838 No function valves for training
info on valve label firewater
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Attribute
D080 [R-43] Fire Building floors and Propagation Prevention, DNGS special NBCC Cl. 3.2.2.2
Separation areas of fire Design to good unusual recognizes DNGS
Gap 01272 requires fire between fire protection structure that as special unusual
separations between floors, areas practice is designed to structure designed
floors and areas within and buildings good fire to good fire
each building and protection protection practice
between buildings practice.
D110 [R-5] Travel Routes Building; Operators fail Minimize Multiple Operator training.
between Main Control Operators route to reach SCA consequences seismically Multiple seismic
Room and Secondary from MCR to SCA for post- smoke ingress qualified routes available,
Control Area shutdown into route from routes to SCA and not all routes
Gap 00512 design to limit plant control MCR to SCA would be impaired
smoke infiltration into the due to smoke
route from MCR to SCA infiltration
D115 [R-44] Fire Protectn Chemical Prevent fires; Prevention, Annual drill Regular ERT
for Laboratories Laboratory extinguish fire suppress lab ERT training, training exercises
Gap 00472 on fumehoods Replace fume promptly fire, minimize Pre-fire plan and pre-fire plan
hoods & dampers consequences Existing fume Existing fume
Gap 01958 requires fire
drill 3 months, designate Fire drills, signs hoods and hoods and
lab as dangerous goods dampers are dampers are safe
area, post signage. safe enough
D171 [R-7] Industrial Charging station Delay to Suppress fire Extinguisher Battery remains on
Trucks for battery-power suppress fire, and battery on trucks; also
Gap 00430 requires one trucks, no no truck and ERT extinguisher. ERT
portable fire extinguisher extinguisher extinguisher fast response response
at each battery charging
location
D176 [R-8] Fire Fire program for Delay to Prevention, Assembly and Pre-Fire-Plan has
Emergency Planning of Chemical Lab. No evacuate minimize accounting the info, and ERT
Laboratories three-month drills consequences drills for regular training
Gap 00469 requires fire and no dangerous radiation exercises
drill every 3 months, sign goods signs emergencies
for dangerous goods, etc
D181 [R-46] Fire Safety Employee fire Delay to Fire fighting Extensive fire Extensive fire
Training Requirements safety training suppress fire, safety training fighting training
Gap 00565 on employee evacuate only for ERT limited to ERT and
fire safety training on nine and to specific to specific people
topics and procedures work groups who are required
to have this
Gap 00566 requires staff training
hands-on training to use
portable extinguishers
D222 [R-9] Public PA System Delay to Suppress fire OPG OPG governance
Address System suppress fire, (alert ERT), governance, and U0 operator
Gap 00534 for integrated delay to minimize U0 operator implementation of
supervised, one-way evacuate consequences implement a monitoring
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Attribute
voice communication monitoring program and
Gap 01285 audible and program of maintenance of
intelligible in all accessible periodic alarm signals and
areas of plant inspection, voice messages
testing and
Gap 01845 audible visual maintenance
alarm signal devices
D225 [R-48] Fire Fire protection Two separate Fire fighting ERT manual ERT manual
Protection Water Supply (FP) water supply connections actions can actions can control
Gap 01848 requires the to D2O managmt are not control fires in fires in these low
FP water distribution, building, water provided to these low hazard buildings
ESW, be as per NFPA 24. treatment plant & these 3 hazard
unit pumphouses buildings buildings
D227 [R-50] Fire Hydrant Fire hydrants Hydrants not Fire fighting ERT is aware ERT training and
Requirement available for of location of knowledge; OPG
Gap 00556 Isolation valve fire fighting the valves and procedures on
to fire hydrant be a post- road boxes; position of locked
indicating valve; locked can operate if valves.
open in lieu of fire alarm needed. OPG Robust building
supervision. Two VB yard procedures walls assure
hydrants are isolated by require work access by ERT to
buried gate valves authorizations wall hydrants.
to close Many options are
Gap 00557 Wall hydrants valves.
shall not be a substitute available for ERT
for yard hydrants. All wall Walls are access to fire
hydrants except 2 are robust. Smoke water if a wall
yard. or heat will not hydrant is not
deter ERT. accessible, e.g.,
Gap 02013 Hydrants not Also adjacent standpipes and
less than 40 ft from bldg. hydrants are other hydrants
VB hydrants are 30 ft available if a
others are wall hydrants wall hydrant is
not accessible
D251 [R-51] Fire Air-cleaning Prevent Minimize Fan shutdown Fan shutdown
Protection Requirements system; no auto smoke consequences would have would have
for Air-Cleaning Units fan shutdown logic recirculation for employee negative negative impact
Gap 01333 requires fire safety impact on on nuclear safety.
detection in air-treatment nuclear safety Linked to D457
systems inclusive of 2- gap 01887, D044
stage alarms gap 00535 and
D439 gap 01764.
D437 [R-12] 2-Hour Emergency lights; Emergency Minimize Use of Class II Emergency light
Emergency Lighting Battery pack lasts light for timely consequences power; ERT duration is longer
Requirement less than 2 h, (but employee for employee and Operators than time required
Gap 01762 Emergency are adequate evacuation in safety by have for evacuation
lighting to have 2 h because required areas without effective flashlights Class II power is
emergency power supply evacuation time is Class II evacuation very reliable ERT
less than 2 h) power and Operator use
flashlights
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Attribute
D438 [R-13] Access for Buildings Modifications Suppress fire There are Full time, trained
Fire Fighting No documents for window multiple ERT and multiple
Gap 01763 provides demonstrate openings and access access locations
exemption for NBCC on compliance access locations and with ventilation to
window openings and hatches; no ERT has manage smoke
access hatches to documents on access to all
suppress fire exemptions building
interiors
D439 [R-53] Fire HVAC Prevent filter Minimize Temperature Temperature
Protection of Charcoal contaminated ignition that consequences alarm for ERT sensors in filter
Filters exhaust units; emits activity. for employee action to spray housing alarms to
Gap 01764 Requires filter prevent fire inside Heat from and public water on filter U0 operator; ERT
protection against spread charcoal filter radioactivity safety housing. sprays water on
of fire and uncontrolled housing could ignite Release is low filter housing to
release of contamination charcoal filter only 0.14% of prevent fire.
weekly DRL Radioactivity low
D443 [R-15] Location of Extinguisher and Suppression Suppress fire ERT bring Plant has many
Extinguishers and FHCs fire hose cabinets of fires is additional fire extinguishers,
Gap 01851 276 locations lack constrained extinguishers FHCs and
portable extingers when procedures.
Gap 01852 Standpipes do not responding to ERT and selected
comply a fire, hoses people have
Areas lack and booster training and
Gap 01853
portable unit pumps adequate
Gap 01895 Many issues on equipment to
hose connections suppress all fires.
Gap 01896 Many issues on
FHCs
D450 [R-17] Building Building Changes to Prevention Prevention Meets code
Height Determination and building, not Procedural considerations for
Fire Resistance practicable controls to Special and
11 Gaps: 01866-1869, limit Unusual
01901-01907 flammable Structures and
materials procedural
controls
D452 [R-56] Spatial Buildings Increased Propagation Good building Good construction,
Separation and Exposed likelihood of construction, low exposure,
Building Face fire low exposure, constant
Gap 01873 D2O/TRF/Annex propagation constant attendance, low
exceeds max. attendance, fire risk, fast ERT
Distance and area low risk of fire, response
of unprotected fast ERT
openings in faces response.
Similar to 01873 Reduction of
Gap 01874 openings and
Gap 01875 Similar to 01873 upgrading of
walls do not
benefit much
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Attribute
D453 [R-19] Fire Fire alarm system Direct alarm Suppress fire, U0 Operator U0 Operator
Department Notification and water flow connection to with Clarington phone call to training and
Gap 01883 devices to send Clarington FD fire service CFD prompt action to
signal to local fire to improve support contact CFD
department response time
D454 [R-20] Fire Alarm Fire alarm system Relocate Suppress fire, U0 Operator U0 Operator
Annunciator annunciators in annunciators using phone to CFD; training and
Gap 01884 NPP buildings to building Clarington FD staff escorted prompt action and
entrances to fire location ERT escort CFD
for radiation to fire location
protection req
D455 [R-21] Emergency Fire alarm system, Change fire Minimize U0 Operator U0 Operator
Notification System audible and visual alarm system; consequences actions to test procedures,
Gap 01885 for electrical alarm devices more employee and initiate training and
supervision of devices & electrical safety repairs, post prompt action to
signals to fire department supervision, signs, and supervise fault
improve limit access. detection and
Gap 01888 alarm signals signal devices Operator send repairs to fire
to be audible for employee emergency alarm system.
Gap 01889 requires visual warnings tones and PA Operator sends
signals where audible system voice emergency tones
signals are not effective announcemts and PA voice
announcements,
post warning signs
and limit access
D457 [R-23] Smoke Air-cleaning Smoke Minimize Fan shutdown Fan shutdown
recirculation system recirculation consequences would have would have
Gap 01887 requires air- not prevented for employee negative negative impact
handling system to Fan shutdown safety impact on on nuclear safety.
prevent smoke circulation not provided nuclear safety Linked to D251
upon a signal from duct in some gap 01333 and
smoke detector systems D044 gap 00535
D458 [R-24] Fire Fighter Buildings Change Suppress fire ERT pre-plans ERT can access
Access to Above and buildings to allow access all areas to fight
Below Grade improve into existing fires. Upgrading
Gaps 01890, 01891 and access buildings access of little
01892 value
D465 [R-27] Elevator Elevators Enlarge (or Minimize ERT can TRF-D2O
Requirements remove) TRF consequences remove elevators were not
and D2O employee stretchers installed to meet
Gap 01926 Elevators to TRF and D2O elevators safety without codes. Credit ERT
accommodate patient elevators small for elevators to evacuate all
stretcher stretchers Add signage
stretchers
D472 [R-61] Oil Storage Indoor oil tanks Prevention, Analysis confirms
Tank and Piping suppress fire, adequate safety
Requirements limit spreading Sumps and leak
No significant
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Attribute
Gaps 01947 and 01949 EPG tank reduction in detection provided

EPG tanks have could rupture tank safety
Normal and emergency no emergency ERT responds to
venting for fuel storage vents stop leaks and
tanks Sumps with fight fires
Gap 01950 Hose stations Increase local level alarms in Design of piping is
EPG fuel mgmt fire fighting tank and fuel adequate for risks
near storage tank rooms; bldg has tank
portable fire extinguishers capability pump rooms. Tank and vent
rooms ERT will know
Reveal and design meets
Gap 01953 Piping above EPG, SG storage prevent piping and stop leaks concerns without
ground where enters bldg oil tank piping damage before a fire checking vents
and shutoff valves starts; ERT
Tank rupture can fight fire
Gap 01957 OMs do not Operating or overflow
require tank vent checking Tank and vent
procedure change Piping is design copes
underground with concerns
D475 [R-63] Valves Firewater system Firefighting Suppress fire Procedure on OPG governance;
Controlling Water water not control of procedure and
Supplies available position- employee training
Gap 01897 Standpipe assured
Not all valves components
system valves to have have supervised
electrically supervised switches Sprinkler
switches; send alarms system more Sprinklers protect
likely requires only a few rooms.
Gap 01898 Valves to Prevent sprinkler Compensatory
disconnect other systems maintenance.
disconnection to Compensatory measures used for
using same water supply service standpipe infrequent service
as a sprinkler system means used
or other systems for isolating to standpipes
standpipes
Gap 02004 Yard hydrants ERT aware of ERT credited to
HY-22 and HY-23 have Not easy to check location of the operate hydrants.
buried non-indicating gate open/closed valve hydrants and OPG has position
valves; no AHJ approval status can operate. control for valves
WA needed to
close them.
Gap 02008 Listed post- OS&Y gate valves
indicator valve (PIV) for ERT is aware
in all connections of locations of ERT training and
every connection from fire from fire service action to control
main to building to control all gate valves
mains; no PIVs. Has complete water supply to all
sources of water supply Fire dept uses PIV buildings.
access to all
areas
Gap 02009 As 02008, No Same as 02008
documents show AHJ has
waived PIV requirement
D476 [R-64] Underground Firewater system Firewater Suppress fire OPG design OPG had design
Pipe underground unreliability specifications and construction
Gaps 02023 to 02032 piping were in place standards and
Dimensions specified for Because piping is during design, specifications for
every piping component; not visible, cannot construction of NPP water piping.
confirm dimension water piping Gives confidence
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Attribute
underground installations of components systems of proper piping.
D479 [R-66] Fire Pump Firewater supply Firewater Suppress fire For OPG OPG safety
Disconnecting Means pump unreliability worker safety requires complete
Gap 01975 No more than Disconnects are good isolation separation, Off
one power disconnecting between manual of voltage between Odd and
means and overcurrent transfer switches needed. Even power
device in power supply to and pump Controller supplies. All
pump controller controller. disconnect disconnect means
switch is not are near the pump
adequate. and easy to locate
D506 [R-68] Control of the Fire alarm system Display and Detection, fire U0 operator U0 operator can
Fire Alarm System The display and control centre fighting, can move move from MCR to
Gap 02134 requires the control units can- to be located evacuation, from MCR to CER and back
display and control centre not be controlled in MCR and communication CER and back effortlessly. SCA
be located in the MCR without operator in each SCA effortlessly. fire alarm control
and in each SCA going from station (not in CER) Also, in SCA, panels are short
from station to distance away, but
fire alarm do provide audible
control panels alarm and trouble
signals.
D514 [R-75] Enclosed Building access to Firewater Suppress fire Backup pump Have backup
Passageways Firewater pump unreliability is in adjacent pump; low pump
Gap 02142 Fire pump rooms reactor unit. In exposure to fire;
rooms not directly Need access to area with low Pressure and flow
accessible from outside pumps during fire, combustible are adequate at
be accessible via an but no enclosed loading; low pump elevation
enclosed passageway passageways to exposure to without this pump.
from stairway or exit way pumps located fire. ERT can ERT can reach
inside the facility reach pumps pump during fire
D516 [R-77] Packaged Firewater supply Firewater Suppress fire Same as Same as D514.
and Prefabricated Fire pump assembly unreliability D514
Pump Assembly
Requirements
Gap 02146 linked to D514 Same gap as in
gaps; each pump room no D514
enclosed passageway.
D523 [R-82] Piping Piping systems for Firewater Prevention, OPG design- OPG design-
System Requirements liquids: for water failure suppress fire construction construction
Gap 02163 Valves to be and for flammable Flammable manual that manual that water
designed for temperatures and combustible liquid leakage water valves valves be to
and pressures of system; liquids be to ASME ASME Class 600
conform to ULC/ORD- Class 600 or or 1500.
C842, etc 1500. Fuel systems
Valve on fuel valves are
systems are designed for
designed for combustible
these liquids. liquids.
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Attribute
D524 [R-83] Fire and Electrical wires Worker safety Prevention, fire Evacuation to Evacuation to
Smoke Characteristics of and cables Smoke during spread, worker SCA; MCR SCA; MCR has
Electrical Wires & Cables Worker safety in combustion of safety has manual manual smoke
Gap 02165 Limits on wire MCR due to insulation smoke venting venting
and cables in a plenum smoke release
Gap 02166 Limits on during combustion
wiring in a plenum. of insulation
Vertical flame test
requirement
D525 [R-84] Elevator Elevators Add elevator Evacuation Personnel are Personnel are
Requirements Worker safety recall when trained and trained and PA
Gap 02170 Requires smoke is in PA system system reminds
detection of smoke in elevator reminds them them not to use
elevator machine rooms machine not to use elevator
to recall elevators. room elevator
D528 [R-87] Voice Voice PA system Evacuation The present The present PA
Communication Systems Communication doesnt meet Fire fighting PA system is system acceptable
Gaps 02172 to 02180 System this code acceptable, for life extension,
require 2-way system Worker safety requirement but it will not but it will not last
between central alarm for a 2-way last 30 years. 30 yr.
and control centre and voice system Replacement Replacement
each floor area system will system will meet
comply Clause 3. 2.4.22
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4 Conclusions and recommendations

Acceptable deviations against fire protection clauses in NFCC 2005 and 2010,
CAN/CSA N293-2007 and -2012, NBCC 2005 and 2010, NFPA-20 2007 and 2013,
NFPA-24 2007 and 2013; ASME N509-2002 and CNSC RD-337 were assessed to
determine any aggregate effects. The ADs were evaluated for different common
factors and aggregate effects of negligible impact were found for certain combinations
of ADs.
The review noted that the IRF resolutions for many of the ADs credited actions by the
U0 Operator and/or the Emergency Response Team (ERT). When the actions of the
U0 Operators and the ERT were considered, all of the aggregate effects identified
were assessed to be of negligible significance.
The conclusion of this assessment is that some combinations of ADs have aggregate
effects, but they are all of negligible significance. Hence, the effects have no impact
on public safety, which includes nuclear safety.
The above conclusion is further supported by an additional review performed to
investigate the impact (if any) of the Acceptable Deviations on the Darlington Fire
Probabilistic Risk Assessment (PRA), to ensure that the impact of the fire protection-
related Acceptable Deviations, both individually and as a whole, on Darlington station
operation is acceptable. The review, which is documented in Review of Fire Code
Acceptable Deviations and Refurbishment Modifications for Impact on DNGS Fire
PRA [R-39], concluded that none of the Acceptable Deviations were found to have
any potential impact on the DNGS Fire PRA either singularly or collectively.
Page 23 of 77
0235 AD AGGREG 0004 01

5 References
[R-1] OPG report, NK38-SR-03500-10002, Rev 4, DN 1-4 Safety Report, Part 3,

Accident Analysis, 2012 09 28.
[R-2] Issue Resolution Form D041, NK38-REP-00770-0421331, R002, Special Fire

Suppression System Requirements, 2013 06 25.
[R-3] Issue Resolution Form D052, NK38-REP-00770-0421404, R002,

Identification Signs for Fire Service Valves, 2013 06 26.
[R-4] Issue Resolution Form D076, NK38-REP-00770-0421668, R001, Fire Safety

Assessment, 2013 06 25.
[R-5] Issue Resolution Form D110, NK38-REP-00770-0421815, R002, Travel

Routes Between Main Control Room and Secondary Control Room, 2013 06
26.

Underground Fire Piping Acceptance Tests, 2013 07 12.
[R-7] Issue Resolution Form D171, NK38-REP-00770-0425577, R001, Industrial

Trucks, 2013 06 26.

Emergency Planning of Laboratories, 2013 06 26.
[R-9] Issue Resolution Form D222, NK38-REP-00770-0425804, R001, Public

Address System, 2013 06 26.
[R-10] Issue Resolution Form D233, NK38-REP-00770-0425813, R001, Manual Fire

Alarm Pull Stations, 2013 07 12.
[R-11] Issue Resolution Form D298, NK38-REP-00770-0426328, R001, National

Fire Code Storage Room Design Requirements, 2013 06 20.
[R-12] Issue Resolution Form D437, NK38-REP-00770-0462020, R000, 2 hr

Emergency Lighting Requirement, 2013 07 02.
[R-13] Issue Resolution Form D438, NK38-REP-00770-0462021, R000, Access to

Fire Fighting, 2013 07 02.
Page 24 of 77
0235 AD AGGREG 0004 01


Combustible Material in Electrical Equipment, 2013 07 02.
[R-15] Issue Resolution Form D443, NK38-REP-00770-0462026, R000, Location of

Extinguishers and FHCs, 2013 06 20.

Separation Acceptable Deviations and Alternate Compliance, 2013 06 20.
[R-17] Issue Resolution Form D450, NK38-REP-00770-0462034, R000, Building

Height Determination and Fire Resistance, 2013 06 25.
[R-18] Issue Resolution Form D451, NK38-REP-00770-0462036, R000, Building

Classification and Sprinkler Requirements, 2013 07 20.
[R-19] Issue Resolution Form D453, NK38-REP-00770-04 62038, R000, Fire

Department Notification, 2013 07 02.
[R-20] Issue Resolution Form D454, NK38-REP-00770-0462040, R000, Fire Alarm

Annunciator, 2013 07 02.
[R-21] Issue Resolution Form D455, NK38-REP-00770-0462041, R000, Emergency

Notification System, 2013 07 02.

Requirements of Janitors Closets, 2013 07 02.
[R-23] Issue Resolution Form D457, NK38-REP-00770-0462044, R000, Smoke

Recirculation, 2013 07 02.
[R-24] Issue Resolution Form D458, NK38-REP-00770-0462045, R000, Fire Fighter

Access to Above and Below Grade, 2013 06 25.
[R-25] Issue Resolution Form D462, NK38-REP-00770-0462051, R000, Volatiles in

Basements, 2013 07 02.
[R-26] Issue Resolution Form D463, NK38-REP-00770-0462052, R000, Exiting

[R-27] Issue Resolution Form D465, NK38-REP-00770-0462054, R000, Elevator

Page 25 of 77
0235 AD AGGREG 0004 01

[R-28] Issue Resolution Form D470, NK38-REP-00770-0462059, R000, Hazardous

Materials Requirements, 2013 06 25.
[R-29] Issue Resolution Form D471, NK38-REP-00770-0462060, R000, Fuel

Storage/Transfer Room Ventilation Requirements, 2013 07 02.
[R-30] Issue Resolution Form D474, NK38-REP-00770-0462063, R000, Mains

Supplying Hydrants, 2013 07 02.
[R-31] Issue Resolution Form D478, NK38-REP-00770-0462067, R000, Compliance

with NFPA 70 for Booster Pumps, 2013 07 02.
[R-32] Issue Resolution Form D480, NK38-REP-00770-0462069, R000, Fire Pump

Over-current Protection, 2013 07 12.
[R-33] Issue Resolution Form D481, NK38-REP-00770-0462070, R000, Manual

Transfer Switch, 2013 07 02.
[R-34] Issue Resolution Form D492, NK38-REP-00770-0462086, R000, Stair

[R-35] Qualification Description, N-TQD-508-00001, R 013, Nuclear Fire Protection

Section Training and Qualification Description, 2012 10 31.
[R-36] OPG Program, N-PROG-TR-0005, R 015, Training, 2012 10 29.
[R-37] OPG Program, N-PROG-AS-0002, R014, Human Performance, 2013 07 12.
[R-38] OPG Program, N-PROG-OP-0001, R005, Nuclear Operations, 2013 12 05.
[R-39] OPG Report, NK38-REP-03680-10187, R000 LOF, Review of Fire Code

Acceptable Deviations and Refurbishment Modifications for Impact on DNGS
Fire PRA, 2013 07 02.
[R-40] Issue Resolution Form D044, NK38-REP-00770-0421334, R002, Fire Alarm

Systems, 2013 11 07.

Suppression, 2013 06 26.

Protection Requirements for Storage Tanks, 2013 06 25.
Page 26 of 77
0235 AD AGGREG 0004 01


Separation, 2013 11 07.

Protection Requirements for Laboratories, 2013 06 25.

Protection Requirements for Building Materials, 2013 06 26.
[R-46] Issue Resolution Form D181, NK38-REP-00770-0425764, R001, Fire Safety

Training Requirements, 2013 06 25.

Department Connections to Fire Mains, 2013 06 25.

Protection Water Supply, 2013 06 26.
[R-49] Issue Resolution Form D226, NK38-REP-00770-0425808, R003, Control

Room Complex Fire Protection, 2013 06 26.

Hydrant Requirement, 2013 07 12.

Protection Requirements for Air-Cleaning Units, 2013 07 12.

Separations Corrective Actions, 2013 07 02.

Protection of Charcoal Filters, 2013 07 02.

Combustible Insulation, 2013 07 02.

Combustible Material in Ducts, 2013 06 25.
[R-56] Issue Resolution Form D452, NK38-REP-00770-0462037, R000, Spatial

Separation and Exposed Building Face, 2013 07 02.
Page 27 of 77
0235 AD AGGREG 0004 01

[R-57] Issue Resolution Form D461, NK38-REP-00770-0462050, R000, Means of

Egress, 2013 07 02.
[R-58] Issue Resolution Form D464, NK38-REP-00770-0462053, R000, Signage


Hoistway and Machine Room Requirements, 2013 07 02.
[R-60] Issue Resolution Form D469, NK38-REP-00770-0462058, R000, Inspection,

Testing and Maintenance Requirements, 2013 06 25.
[R-61] Issue Resolution Form D472, NK38-REP-00770-0462061, R000, Oil Storage

Tank and Piping Requirements, 2013 06 25.

Documentation, 2013 06 25.
[R-63] Issue Resolution Form D475, NK38-REP-00770-0462064, R000, Valves

Controlling Water Supplies, 2013 06 05.

Underground Pipe, 2013 06 05.
[R-65] Issue Resolution Form D477, NK38-REP-00770-0462066, R000, Size of

Bypass, 2013 07 12.

Disconnect Means, 2013 06 03.
[R-67] Issue Resolution Form D482, NK38-REP-00770-0462071, R000, Monitoring

of Fire Pump Alternate Power Source, 2013 07 02.
[R-68] Issue Resolution Form D506, NK38-REP-00770-0489244, R000, Control of

Fire Alarm System, 2014 01 30.
[R-69] Issue Resolution Form D507, NK38-REP-00770-0489245, R000, Automatic

and Manual Water-Based Fire Suppression Systems, 2014 01 30.
[R-70] Issue Resolution Form D509, NK38-REP-00770-0489247, R000, Thread

Specifications on Drawings, 2014 01 30.
Page 28 of 77
0235 AD AGGREG 0004 01

[R-71] Issue Resolution Form D510, NK38-REP-00770-0489248, R000, Valves

Controlling Water Supplies, 2014 01 30.

Connections Between Sectional Valves, 2014 01 31.
[R-73] Issue Resolution Form D512, NK38-REP-00770-0489250, R000, Information

Indicated on Plans, 2014 01 31.

Nameplates. 2014 01 30.
[R-75] Issue Resolution Form D514, NK38-REP-00770-0489252, R000, Enclosed

Passageways, 2014 01 30.
[R-76] Issue Resolution Form D515, NK38-REP-00770-0489253, R000, Hose Valve

Thread Requirement, 2014 01 30
[R-77] Issue Resolution Form D516, NK38-REP-00770-0489254, R000, Packaged

and Prefabricated Fire Pump Assembly Requirements, 2014 01 30.
[R-78] Issue Resolution Form D517, NK38-REP-00770-0489255, R000, Electrical

Protections and Requirements for Fire Pump Systems, 2014 01 30.

Protection and Life Safety Systems Commissioning, 2014 01 30.
[R-80] Issue Resolution Form D520, NK38-REP-00770-0489258, R000, Operation

and Maintenance of Industrial Trucks, 2014 01 30.
[R-81] Issue Resolution Form D522, NK38-REP-00770-0489260, R000, Tank

Storage of Combustible Liquids, 2014 01 30.
[R-82] Issue Resolution Form D523, NK38-REP-00770-0489261, R000, Piping

System Requirements, 2014 01 30.
[R-83] Issue Resolution Form D524, NK38-REP-00770-0489262, R000, Fire and

Smoke Characteristics of Electrical Wires and Cables, 2014 01 30.

Page 29 of 77
0235 AD AGGREG 0004 01

[R-85] Issue Resolution Form D526, NK38-REP-00770-0489264, R000, Electronic

Supervision of Water Supply Valves, 2014 01 30.
[R-86] Issue Resolution Form D527, NK38-REP-00770-0489265, R000, Entrance

Walkway Smoke Detector, 2014 01 30.
[R-87] Issue Resolution Form D528, NK38-REP-00770-0489266, R000, Voice

Communication Systems, 2014 01 30.
[R-88] Issue Resolution Form D529, NK38-REP-00770-0489267, R000, Electrical

Conductors for Fire Protection Systems, 2014 01 30.
[R-89] Issue Resolution Form D530, NK38-REP-00770-0489268, R000, Exit

Signage, 2014 01 30.
[R-90] Issue Resolution Form D607, NK38-REP-00770-0488763, R000, Severe

Accident and Beyond Design Basis Accident (BDBA) Design/SAMG, 2014 02
11.
[R-91] Issue Resolution Form D428, NK38-REP-00770-0462011, R001, Detection of

Significant Fire Hazards, 2013 11 07.
[R-92] Issue Resolution Form D430, NK38-REP-00770-0462013, R001, CNSC

Acceptance of FHA and FSSA, 2013 11 07.
[R-93] Issue Resolution Form D431, NK38-REP-00770-0462014, R000, CNSC

Acceptance of FHA, 2013 07 02.

Endurance of Fire Alarm Cable, 2013 07 02.
[R-95] OPG Report, NK38-REP-03680-10204, R000, Additional Analysis of DNGS

ISR Fire Protection Related Issues, 2014 03 03.
[R-96] OPG Instruction, N-INS-00770-10004, R001, Nuclear Refurbishment Gap

Resolution Process Darlington,
Page 30 of 77
0235 AD AGGREG 0004 01

Appendix 1: Summary of accepted gap resolutions in 85 ADs

Issue Title and IRF record Summary of gap assessments in the Issue Resolution Form (IRF) Disposition
D041 Special Fire Two (2) gaps from the National Fire Code of Canada (NFCC) 2005 regarding CO2 fire
[R-2] Suppression System suppression system. Addressed by moving part of gap 00415 to Issue D045 and
Requirements crediting the remaining part of the gap to ERT training and action. Gap 00475 is
NK38-REP-00770- compliant and closed.
0421331 R002 Gap 00415 against NFCC Clauses 2.1.3.5 which states:
1) Where a special fire suppression system is required conform to one of standards in
(3) and (4).
2) If a water-based system is not compatible with the fire suppression requirements for certain
types of dangerous goods, a special system conforming to a standard in Sentence (3) is
permitted.
3) Standards for a special fire-suppression system that is not water-based.
4) Standards for water-based special fire-suppression systems.
5) Wetting agents for water-based systems shall conform to NFPA 18.
6) A hazard for which a system has been designed is not permitted to be increased unless the
level of protection is increased.
7) Posting of operating and maintenance instructions.
8) Marking of valves and controls for a special fire suppression system.
CO2 suppression was originally installed as per NFPA 12 in several buildings. NFPA 12
requires suitable safeguards to ensure prompt evacuation and to prevent entry into hazardous
atmospheres. Gap 00415 identifies that safeguards (in Sentences 3 and 4) have not been
fully installed at DNGS to properly warn personnel of fire-related dangers.
Additionally, no documentation was found to indicate compliance with Sentences 7 and 8 for
posting operating and maintenance instructions in proximity to the equipment and controls,
and marking the valves and controls to indicate their function.
The portion of this gap associated with 3) and 4) were identified in the gap analysis of N293-
07 as gaps 00547, 01286 and 01287, to be resolved under Issue D045.
As per a specialist review, the CO2 systems were removed from all areas of DNGS except
the fuel pump room and the fuel storage rooms of the EPG Fuel Management Building.
Procedural controls have been implemented to achieve the intent of the required safeguards
consisting of: gas supply isolation, maintaining communication with personnel outside the
areas protected by the CO2 systems, and wearing SCBA when entering such areas. The Gap 00415 (7)
safeguard requirements and intent have not changed since 1980, so the procedural measures & (8), credit
remain valid for the extended life. ERT training
The portion of this gap associated with Sentences (7) and (8) are addressed by and actions
Emergency Response Team (ERT) training and actions; no further action needed.
Gap 00475 against NFCC Clause 6.6.1.1 It requires that the special system be tested, Exclude
inspected and maintained in conformance with the appropriate requirements. The gap
identifies that the safeguards required by NFPA 12 in order to properly warn personnel of fire-
related dangers have not been fully installed in DNGS. The actions taken have resolved this
gap. After a third party review, IRF reclassified this gap as compliant and closed.
D044 Fire Alarm Systems Seventeen (17) gaps, 15 against CAN/CSA N293-07 and two against NBCC 2005. Gaps
[R-40] NK-REP-00770- 00533, 00539 and 00542 are compliant; 00545 is not applicable; 00543, 01268, 1843 and
0421334 1844 were moved to other issues. 00538, 00540, 00541 and 02070 will be made compliant.
Gap 00533 against N293-07 Clause 7.2.1.1 requires that fire alarm systems using very early Exclude
warning fire detection technology be provided. Very early warning systems as per NFPA 76
were not provided. The existing systems are not compliant with Clauses 3.3.1.3, 4.2.4, 4.2.10
and 5.8.3 of CAN/ULC-S524-06 relating to circuit wiring, data communication links and duct-
type smoke detectors. Additional analysis in [R-95] Appendix A-2 recommends retaining
Page 31 of 77
0235 AD AGGREG 0004 01

existing duct detectors with sampling tubes in their current configuration. Cost for additional
sampling- tube duct detectors do not justify benefits gained when alternative standards (i.e.,
NFPA 72) indicate protection goals met with the existing devices. Alternative compliance
Gaps 00535, 00536 and 00537 against N293-07 Clause 7.2.1.6.1, .2 and .3 which require a Credit Unit 0
two-stage fire alarm system. The DNGS system is not a two-stage alarm; it is missing the operator
initial alert signal.
Gap 00538 against N293-07 Clause 7.2.1.6.4 It states that a building less than 5000 ft2 may AD
use a single-stage alarm system, but none of the DNGS are smaller than 5000 ft2. A further Credit staff
study of building size vs. alarm was carried out [R-95] Appendix A-1. The NBCC would training
require manual pull stations and smoke detection in the water treatment plant (WTP) and the
pumphouses. The lack of pull stations is justified by the training of staff to report the fire by
dialing 911; the PA system speakers notify and instruct staff there in the event of fire or other
emergencies. The fire hazards in the pumphouses are the large pump motors that have high
temperature alarms in the MCR. Because occupancy is low in the WTP, it has automatic fire
detection within a pump room, the control room and the CER. The design meets code intent
Gap 00539 against N293-07 Clause 7.2.1.7 It requires the alarm and voice communication Exclude
systems be equipped with back-up batteries for not less than 24 hours supervisory functions.
The six main Pyrotronics indicating panels in the CER do not have back-up batteries. Direct
compliance, supplied by Class II power, which is backed up by batteries.
Gap 00540 against N293-07 Clause 7.2.1.9 It requires the MCR be the Central Alarm and AD
Control Facility and the display and control centre be in the MCR. In DNGS, it is in the CER. Credit U0
Additional analysis in [R-95] Appendix B-1 proposes leaving the fire control panels in the CER operator skill
instead of moving the annunciator panels to the MCR; the potential convenience gained does and familiarity
not justify the cost. A common signal is displayed in the MCR with details (visual and audible
alarm and trouble signals) on the panels in the adjacent CER. It requires the U0 operator to
leave his station in the MCR to view the full details of a fire alarm signal. The travel distance
and time is insignificant, and the operator is already accustomed to the present design.
Gap 00541 against N293-07 Clause 7.2.1.10.3 It requires capability to transfer control of the A/R Exclude
alarm system from the MCR to the SCA. The SCA multizone local indicating panels are
incapable of full control of the station alarm system. A/R 28155463-16
Gap 00542 against N293-07 Clause 7.2.1.12.2 It requires all separate fire extinguishing-
Exclude
agent-releasing panels or modules integrated into the fire alarm panel have a power supply
with an emergency power source. Most local releasing panels do not have this source. Direct
compliance, supplied by Class II or III power with battery backup.
Gap 00543 against N293-07 Clause 7.2.1.13.1 It requires that wiring in service spaces
containing other combustible materials and that are used for alarm and emergency equipment Exclude
shall be capable of performing for at least 1 h after a fire. No evidence that 1 h-rated wiring
has been used. Moved to D442. See also additional analysis in [R-95] Appendix A-11.
Gap 00545 against N293-07 Clause 7.2.3.3 It requires that where visual signals are provided
both visual and audible signals operate immediately and simultaneously upon activation. Exclude
MCR operators shall be capable of selectively stopping signals. No facility to selectively stop
signals. No DM evidence that visual signals meet NFPA 72 for synch and minimum candela.
Not applicable to DNGS (no visual alarm devices).
Gap 01268 against N293-07 Clause 5.7.3.1 It requires a fire alarm system be installed in
buildings in accordance with N293-07 and NBCC. Gaps were identified with the design and Exclude
suppression capabilities. Moved to D428 (see below).
Gap 01880 against NBCC 2005 Credit Unit 0
Clause 3.2.4.4.(1) It requires that a single-stage alarm system, upon the operation of any operator
manual station, waterflow detecting device, or fire detector, cause an alarm signal to sound
on all audible signal devices in the system.
Clause 3.2.4.4.(2) It requires that a 2-stage alarm system
a) cause an alert signal to sound upon the operation of any manual station, waterflow
device or fire detector
b) automatically cause an alarm signal to sound, if the alert signal is not acknowledged
Page 32 of 77
0235 AD AGGREG 0004 01

within 5 min
c) have manual stations, each of which is equipped so that the use of a key or other similar
device causes an alarm signal to sound that continues upon removal of the key or device
from the station.
Audible signal devices do not sound automatically 5 min after operation of an alarm device
Gap 01882 against NBCC 2005 Clause 3.2.4.6 It requires that
1) a fire alarm system be designed so that when an alarm signal is actuated, it cannot be Exclude
silenced automatically before a period of time has elapsed that is not less than
a) 5 min for a building not required to be equipped with an annunciator, and
b) 20 min for any other building
2) Fire alarm system does not incorporate manual silencing switches other than those
installed inside the fire alarm control unit.
The systems were designed to ULC-S524 and commissioned and verified to ULC-S537 and
are maintained to ULC S536, but the DM does not indicate the alarm silencing requirements
are met. The intent is to prevent alarms being prematurely silenced. Not applicable to
DNGS. Audible signal devices are not provided; there is no automatic signal upon operation
of an alarm initiating device. The U0 operator receives all alarm initiating signals and is
required to sound the ERT tone within one minute of being informed of a fire.
Gap 01843 against N293-07 Clause 7.2.2.2 It requires very early warning detection Exclude
technology unless the FHA and FSSA permit otherwise. Moved to D430.
Gap 01844 against N293-07 Clause 7.2.2.4 It requires that alternative fire detection methods Exclude
be considered where fire detectors cannot operate as per their design specs or where the
detection method is not practical. Moved to D430.
Gap 02070 against N293-07 Clause 7.2.1.10.2 It requires that each display and control
centre in an SCA provide full display and control for all portions of the system that are located A/R Exclude
within the area under the control of the SCA. Multi-zone local indicating panels are in each
SCA. The fire alarm system network panels are set up in a peer-to-peer system, which
permits control from each panel without the need for transfer. However, these panels do not
provide full display and control functions for the Pyrotronics system. A/R 28155463-16
D045 Fire Suppression Fifteen (15) gaps, against CAN/CSA N293-07. Gap 00553 is compliant; 00552 not applicable
[R-41] NK38-REP-00770- and 00546, 00548, 00554 and 01269 were moved to D430. The remaining gaps have been
0421335 R001 addressed. Fire extinguishers, standpipes and the CO2 system are ADs.
Gap 00546 against Clause 7.3.1.1.1 It requires damage from the fire suppression agent be
considered during fire suppression system selection. No documents confirm this requirement Exclude
met. Moved to D430.
In the following 7 gaps, there are eight deviations from NFPA and FM-7 101 standards. The
FHA documented multiple findings regarding portable fire extinguishers and fire hose stations.
Gap 00547 against Clause 7.3.1.1.2 It requires the fire suppression system be provided in
accordance with (a) this Standard, (b) the NBCC, (c) the NFCC and (d) additional applicable
technical requirements specified in the documents of Clauses 7.3.1.1.3 and 7.3.1.1.4. Refer
to summary below.
Gap 01270 against Clause 5.7.4.2.2 It requires the automatic suppression systems be
designed and installed in accordance with Clause 7 and inspected, tested and maintained in
accordance with Clause 8. Refer to summary below.
Gap 01286 against Clause 7.3.1.1.3 It requires the design to comply with the requirements
of the AHJ for pressure-retaining components and with the NFPA standards. Refer to
summary below
Gap 01287 against Clause 7.3.1.4.1 It requires the systems be designed and installed in
accordance with the applicable NFPA documents listed in Clause 7.3.1.1.3. Refer to
summary below.
Gap 01846 against Clause 7.3.1.2 It requires the suppression, required by Clause 5.7.4.2.1,
to be provided using automatic sprinkler systems. Where not provided, the FHA is required to
Page 33 of 77
0235 AD AGGREG 0004 01

demonstrate that all the fire protection goals are met. Refer to summary below.
Gap 01850 against Clause 7.3.4.2 It requires that special extinguishing systems be in
accordance with NFPA standards. Refer to summary below.
Gap 02112 against Clause 7.3.1.1.3 It requires that sprinkler systems be installed in
accordance with NFPA 13. Some deflectors were located more than 16 inch maximum
distance below ceilings, floor decks or beams allowed by the code (up to ~ 20 inches).
The summary of the resolutions for these 7 gaps are:
- Fire Extinguishers---no action; the existing configuration is an acceptable deviation. AD
- Standpipes---no action; AD
- CO2 System---no action: AD
- Transformer Deluge Suppression System, Implement actions in E-3 of FHA report Exclude
- Foam Suppression System: Additional analysis in [R-95] Appendix A-4 points out that the Exclude
system for protecting the SG fuel tanks and dikes does not involve the use monitors and
handlines. Fixed nozzles are positioned inside the tanks and around the perimeters of the
dikes for delivering the foam-water. The existing system is acceptable and in direct
compliance with the requirements of NFPA 11 and CSA N293-07.
- Sprinkler System in Turbine Halls: Additional analysis in [R-95] Appendix A-6 on sprinkler Exclude
discharge density concluded that the benefit gained to modify this sprinkler to comply with
FM 7-101 does not justify the cost of the modification. The performance of the existing
sprinklers average discharge density meets and exceeds the code requirement.
- Sprinkler System in Storage Rooms S-119 and S-219 will be upgraded to meet NFPA 13 A/R Exclude
A/R # 28155462-33
- Sprinkler System in Powerhouse Complex FFAA Fuel Storage Areas: Additional analysis Exclude
in [R-95] Appendix A-5 (referencing gap 02601) demonstrates that the existing sprinkler
configuration satisfies the intent of the standard.
Gap 00548 against Clause 7.3.1.3 It requires that the design of suppression systems include Exclude
means to mitigate hazards created by the operation of these systems. No documentation in
the DMs to confirm this requirement was met. Moved to D430.
Gap 00551 against Clause 7.3.3.3 It sets requirements for sidewall sprinklers, where used to
protect structural steel columns. DM states that side sprinklers have been installed between Exclude
column rows T and B; however, the following requirements are not confirmed:
- Vertical distance between sprinklers does not exceed 3 m
- Highest sidewall sprinkler located within 0.3 m of the bottom of the ceiling beams
- Sprinklers placed in an alternating pattern on opposing sides of the column
- Sprinklers discharge on the web
Additional analysis in [R-95] Appendix A-3 proposes to retain the existing column protection
because it can provide effective protection against structural failure when crediting the ceiling
sprinklers. Single side protection of column webs is an approved protection option in high
challenge fires. Calculations confirmed the steel columns can withstand high heat exposure
for a time without any protection. Existing column protection plus ceiling sprinklers and
manual ERT suppression to control postulated fires will prevent serious damage.
Gap 00552 against Clause 7.3.3.4 It sets requirements for cable tray locations below Exclude
sprinklers. Design manual does not specify that the following requirements be considered in
the design. Since there are no sprinkler systems provided for cable tray protection, this gap
is closed because this requirement is not applicable.
Gap 00553 against Clause 7.3.3.5 It sets requirements for trays located above sprinklers. Exclude
DM does not specify design requirement for sprinklers to be a maximum distance of 0.15 m
below the bottom of the cable tray. Gap is closed. Direct compliance.
Gap 00554 against Clause 7.3.3.6 It sets requirements for containing water discharge for Exclude
water-based systems. DM does not mention requirements for diking and containment, to limit
the spread of flammable and combustible liquids, and to divert liquid from equipment that
becomes inoperable when wet and affects nuclear safety. Moved to D430.
Gap 01269 against Clause 5.7.4.2.1 It requires suppression be provided for all buildings,
Exclude
structures and equipment unless demonstrated by the FHA, etc. that the fire protection goals
Page 34 of 77
0235 AD AGGREG 0004 01

can be met using other fire protection measures. Moved to D430.
Gap 01288 against Clause 7.3.3.7 It requires oil-filled transformers, including their adjacent
non-absorbing ground areas, be protected with an automatic water-based spray system, in A/R Exclude
accordance with NFPA 15 or NFPA 16. A/R # 28155463-13
- The non-absorbing ground areas adjacent to the transformers are not protected by water-
based spray systems, and
- Transformers filled with silicone fluid and located within the main powerhouse are not
protected with water-based spray systems.
D048 Fire Protection Four (4) gaps from a review of NFCC 2005. Gaps 00445 and 00447 are compliant. Exclude D048
[R-42] Requirements for Gap 00444 against Clause 4.3.1.7 It does not meet requirements for storage tank and its Exclude
Storage Tanks filling and emptying connections to be identified in conformance with CPPI. Not discussed in
NK38-REP-00770- DMs pertaining to the Standby Generator and Emergency Power Generators Fuel
0421401 R001 Management Systems. Refueling truck will be escorted to the tanks, to be filled according to
site procedures by plant staff that inspect and test the oil before it is dispensed into the tanks
through site identified connections. Not applicable to DNGS
Gap 00445 against Clause 4.3.5.2 No documentation provides evidence that storage tank Exclude
vent pipe outlets for Class 1 liquids are in appropriate position relative to adjacent ground
level and building openings, and that storage tank vent pipe outlets for Class II or IIIA liquids
are in the appropriate position relative to adjacent ground level and building openings. No
Class I liquids stored on-site. DM shows vents. Closed Intent met by direct compliance.
Gap 00446 against Clause 4.3.7.2 No documentation to support the secondary containment A/R Exclude
construction requirements:
- Be made of non-combustible materials or be covered with a non-combustible material that
will not fail when the secondary containment is exposed to fire
- Have a permeability less than or equal 10-6 cm/s to the combustible material held within
and withstand full hydrostatic head
- Conform to ULC/ORD-C58.9 when impermeable
- All piping passing through secondary containment also adhere to the above requirements.
The SG secondary containment dyke will be evaluated to confirm it is suitable for the life
extension project. The SG and EPG secondary containment penetration locations will be
inspected. Any deficiencies will be corrected. A/R # 28155462-25.
Gap 00447 against Clause 4.3.7.5 No documentation provides evidence that a secondary Exclude
containment shall permit a) access to storage tank, valves, and ancillary equipment, b) egress
from the contained space, and c) access for firefighting as specified in Article 4.3.2.4. Closed
Intent met by direct compliance
D052 Identification Signs for One (1) gap from a review of NFPA-24 Standard for the Installation of Private Fire Service
[R-3] Fire Service Valves Mains and Their Appurtenances.
NK38-REP-00770- Gap 00838 against NFPA-24 Clause 6.6.1 It requires indication of function on labels for fire Credit ERT
0421404 R002 service valves. The intent is met. The valves at DNGS have adequate identifier labels. training
The ERT is trained to identify and locate these valves.
D076 Fire Safety Assessment Fourteen (14) gaps from a review of CAN/CSA N293-07 require improvements in Fire Safe Exclude D076
[R-4] NK38-REP-00770- Shutdown Analysis (FSSA) and Fire Hazard Assessment (FHA). IRF moved 8 gaps to other
0421668 R001 ISR Issues; closed 4 gaps by direct compliance and closed 2 gaps by FSSA revision.
Gap 00480 against Clause 5.4.1.2 The FSSA does not address all plant operational modes. Exclude
Gap 00482 against Clause 5.4.3.2 requires fire release of radioactivity to be ALARA. Moved Exclude
to D431.
Gaps 00484, 00485, 00486, 00490, 00493 and 00532 Moved to D430. Exclude
Gap 00611 against Clause 11.2.3 requires maintaining FSSA as living document; update Exclude
every 5 years.
Gap 00612 against Clause 11.3 Improve FSSA consideration of impact of radioactivity Exclude
outside plant.
Gap 00613 against Clause 11.4 The FSSA needs to consider: a) inventory and configuration
Page 35 of 77
0235 AD AGGREG 0004 01

of in situ combustible materials in each fire zone, and b) verification that criteria for protection Exclude
of radioactive materials outside the reactor have been met or identify additional fire protection
measures required.
Gap 00614 against Clause 11.5.1 FSSA does not cover all locations that are under scope of Exclude
N293-07.
Gap 00615 against Clause 11.5.2 FSSA does not address all plant operational modes (Gap Exclude
00480).
Gap 01264 against Clause 5.4.1.1 Same as Gap 00612. Moved to D430. Exclude
Additional OPG information in the IRF closes gaps 00611, 00612, 00613 and 00614 by Exclude
direct compliance.
Note: To close gaps 00480 and 00615, OPG justified accepting full power as the
bounding state for analysis and relying on procedural controls to mitigate impact of
fires during outages.
D080 Fire Separation Six (6) gaps five against CAN/CSA N293-07 and one against NFCC 2005. Gaps 00508,
[R-43] NK38-REP-00770- 00510 and 01276 moved to D430. Gaps 00509 and 00416 to be closed. Gap 01272 is AD.
0421794 R002 Gap 00508 against Clause 6.5.2.3 It requires all joints in a fire separation be sealed by a fire Exclude
stop system for fire resistance rating equivalent to the fire separation. Need FTH rating as per
CAN/ULC-S115. No documentation found. Moved to D430.
Gap 00509 against Clause 6.5.2.4 It requires design documentation include a record of all A/R Exclude
fire stops, including locations, fire rating requirements and methods of qualification. No
documentation found. Will prepare fire stop documents A/R # 28155462-24
Gap 00510 against Clause 6.5.4.1 It requires structures supporting fire separations to have a
fire resistance rating greater than or equal to the fire separation being supported. No Exclude
documentation found. Moved to D430.
Gap 01272 against Clause 5.7.5.1.2 It requires fire separations between floors and areas AD
within each building and between buildings be as per NBCC, NFCC and Clause 6, except in
containment. No documentation found. NBCC Clause 3.2.2.2 recognizes DNGS powerhouse
as a special and unusual structure, to be designed to good fire protection practice. For low
and medium hazard and special purpose, NFPA 101 does not specify minimum construction
requirements. The deviations are acceptable.
Gap 01276 against Clause 5.7.5.2.1 It requires fire resistance rating of fire separations to be Exclude
appropriate for the fire hazards present in a fire compartment and its adjoining fire
compartments. Maintenance shall be to NFCC and Clause 6. No documents for compliance
with Clause 6. Moved to D430.
Gap 00416 against NFCC Clause 2.2.1.1 It states the fire separation requirements for A/R Exclude
buildings and rooms/spaces within a building. No documents found to confirm the requirement
that fire separation conforms to NFCC and NBCC. A/R # 28155463-12
D110 Travel Routes Between One (1) gap from CAN/CSA N293-07 regarding smoke infiltration into travel routes from MCR
[R-5] Main Control Room and during fire
Secondary Control Gap 00512 against Clause 6.7.2.1 No evidence that all routes between MCR and Secondary AD
Room Control Room are designed to limit smoke infiltration to not more than 1% of contaminated air
NK38-REP-00770- during a fire. The intent is to maintain accessible routes in a fire, and the design provides
0421815 R002 multiple routes. The FSSA and FHA do not identify a fire scenario that would impair all routes.
D115 Fire Protection Six (6) gaps, against NFCC 2005. Gap 00468 complies; 00470, 00471, 00472 and 00473 to
[R-44] Requirements for be corrected; 01958 is AD.
Laboratories Gap 00468 against Clause 5.5.2.2 It requires a lab be separated by fire separations that Exclude
NK38-REP-00770- conform to NFCC and NBCC, but having a 1 h fire-resistant rating. No documentation.
0425531 R001 Closed by direct compliance.
Gap 00470 against Clause 5.5.3.5 It states requirements for ignition sources and A/R Exclude
combustible material control, including high temperature limit switches for heating equipment,
and restrictions when an ignition source is used in conjunction with flammable and
Page 36 of 77
0235 AD AGGREG 0004 01

combustible liquids and vapours. No documents. A/R # 28155462-01
Gap 00471 against Clause 5.5.3.6 It states requirements for cleaning, inspection and A/R Exclude
maintenance of electrical and other equipment. No documents. A/R # 28155462-03
Gap 00472 against Clause 5.5.4.3 It states requirements for enclosure exhaust ventilation, AD
including for vapours or deposits and use of control switches. No documents. Additional
analysis in [R-95] Appendix A-7 proposes to maintain existing fume hoods because the small
benefit does not justify the cost of replacing them. The majority of the work in the Lab involves
tritiated water samples; the amount of volatile chemicals is low and infrequent. PMIDs are in
place to clean fume hoods and their exhaust systems every 6 months; which is adequate
mitigation of the low condensation hazard. Analysis in [R-95] Appendix B-3 proposes (an
alternative to the resolution in D448 of installing fire dampers in all ducting in labs S-265 and
S-266, which is) to retain the existing ducting as is. The labs are penetrated only by HVAC
and contaminated air ducts from the fume hoods and other power ventilated enclosures and
equipment in the rooms. Only the contaminated air ducts in the labs have fire dampers to
protect cable the cable spreading room above (SM-299). Retention of the existing
configuration would not adversely impact the expected level of fire and life safety in the labs.
Gap 00473 against Clause 5.5.4.4 It states requirements for construction of power-ventilated Exclude
enclosures and a fire suppression system within the enclosure and restrictions on the use of
combustible materials within the enclosure. No documents. Additional analysis in [R-95]
Appendix A-7 documents that the majority of the work in the Lab involves tritiated water
samples; the amount of volatile chemicals is low and infrequent. PMIDs are in place to clean
fume hoods and their exhaust systems every 6 months; which is adequate mitigation of the
condensation hazard. Although the quantity is low, direct compliance cannot be demonstrated
because flammable liquids are handled. Due to the low frequency and measures to prevent
accumulation of combustible deposits in the hoods and their exhausts, the existing design
does not adversely impact the expected level of fire and life safety. The existing fume hoods
and their exhausts are acceptable for extended plant life. Complies with intent of code.
Gap 01958 against Clauses 5.5.3.1.(2) and 5.5.3.1.(5) It requires fire drills at intervals not
longer than 3 months and designation of lab as an area containing dangerous goods. No AD credits
documents for Chemistry Lab fire drills. Presence of signage not confirmed. Site staff does ERT
annual fire drill. ERT conducts training exercises to maintain knowledge and skill. Relevant
info regarding the chemical lab is contained in a pre-fire plan. Credit ERT
D116 Fire Protection Thirteen (13) gaps, 6 against NFCC 2005 and 7 against N293-07.Gaps 00418, 00435, 01937, Exclude D116
[R-45] Requirements for 00513, 00515, 00516, 01265, 01266 closed by compliance. Gaps 01939 and 00517 will close
Building Materials by compliance. Gap 00514 moved to D430.
NK38-REP-00770- Gap 00418 against NFCC Clause 2.3.1.4 It requires combustible contents within the Exclude
0425532 R001 interconnected floor spaces in the turbine hall to be less than 16 g/m3. No documents. For low
and medium hazard building and special purpose occupancies can use NFPA 101, which
does not specify any minimum construction requirements. Alternate compliance.
Gap 00435 against Clause 3.2.7.8 It requires floors in areas where dangerous goods are
stored to be of impermeable materials, and that Class 5 oxidizing substances not be stored Exclude
on combustible platforms. No documents (N-INS-07080-10002 does not cover this). Minimal
dangerous goods on site in rooms with concrete floors. Oxidizing substances are in steel
cabinets dedicated for oxidizing agents. Closed by compliance.
Gap 01937 against Clause 2.3.1.2 It requires movable partitions or screens not have a flame Exclude
spread rating greater than that required for the inner finish of the area in which they are
located. No info on design of interior finishes. After more reviews, no deviations from code
were found with respect to flammability of the interior partitions or screens. Design complies.
Gap 01938 against Clause 2.3.1.3 It requires decorative materials on walls or ceiling have Exclude
flame-spread rating not greater than that required for the interior finish of the space in which
they are located. No info on design of interior finishes. After reviews no deviations from code
were found with respect to flammability of the interior decorative materials. Design complies.
Gap 01939 against Clause 2.3.2.1 It requires drapes, curtains and other decorative materials A/R Exclude
including textiles and films to conform to CAN/ULC-S109, when they are used in any
Page 37 of 77
0235 AD AGGREG 0004 01

assembly occupancy or Group B, Division 1 care or detention occupancy, any lobby or exit, or
any open floor area >500 m2, etc, except when the floor area is divided into fire compartments
and separated by 1 h rated fire separations. Most out buildings do not meet the 500 m 2 size
limit, and no info found. Complies; A/R # 28155459-25 write procedure for new purchases
Gap 01940 against Clause 2.3.2.2 It requires flame retardant treatments be renewed as
required to meet match flame test in NFPA 705. No info found. There are curtains/blinds in Exclude
several locations, including the cafeteria, coffee shop, TRF Annex and other out buildings.
The contributions of such materials to the combustible loading for each room and area was
considered in the FHA and deemed acceptable. Design complies with intent of code.
Gap 00513 against N293-07 Clause 6.8.1.2 It requires metal roof deck designs not
propagate fire under the deck, and roof coverings not readily ignite. No documents found. Exclude
Civil Design confirms that roofs do meet code requirements. Closed by compliance.
Gap 00514 against Clause 6.8.1.3.1 It requires building fixtures containing combustible Exclude
materials be minimized in plant buildings. No documents found. Moved to D430.
Gap 00515 against Clause 6.8.1.3.2 It requires no exposed foam plastics be used as parts
for buildings or fixtures. No documents found. FSSA and FHA show compliance. Closed Exclude
Gap 00516 against Clause 6.8.1.3.3 It requires shelves and racks for equipment installation Exclude
and storage not be of combustible materials. No documents found. Closed by compliance.
Gap 00517 against Clause 6.8.1.4 It requires that interior finishes:
a) Interior wall or ceiling finishes shall have a flame spread rating less than or equal to 25 and A/R Exclude
smoke development of less than 100 when tested by CAN/ULC-S102. The acoustic panels
are compliant.
b) Interior floor finishes shall have a Class 1 rating when tested by CAN/ULC-S102.2. The
MCR carpet will be replaced by compliant carpet or best alternative. A/R # 28155459-26
Additional analysis in [R-95] Appendix A-8 recommends retaining existing floor coatings in
the powerhouse, recently refreshed. Removing and replacing it would entail costs that are
not justified by the gained benefit. The coating would have negligible impact in a fire
c) Epoxy liner on the containment wall shall have a flame spread rating less than or equal to
40 when tested by CAN/ULC-S102 or S102.2. Additional analysis in [R-95] Appendix 8
states that this epoxy coating is not a significant fire hazard.
Gap 01265 against Clause 5.7.1.1 It requires that buildings be constructed using non- Exclude
combustible materials. No documents found; later shown to comply. Closed by compliance.
Gap 01266 against Clause 5.7.1.2 It requires minimization of combustible building fixtures Exclude
and interior finishes. No documents found; later shown to comply. Closed by compliance.
D125 Underground Fire Four (4) gaps from a review of NFPA-24 (Aug 2006) Standard for the Installation of Private Exclude D125
[R-6] Piping Acceptance Fire Service Mains and their Appurtenances - 2007 regarding hydrostatic test requirements
Tests of underground fire protection piping.
NK38-REP-00770- Gap 00842 shown in IRF to be not applicable and is Closed. Exclude
042557 R001 Gaps 00839, 00840 and 00841 No record has been found regarding the original hydrostatic Exclude
tests that were carried out more than 30 years ago. This is primarily a workmanship test and
not a materials performance test. While no documentation was located, the system has been
continuously subjected to its working pressure. Since that time, any leaks or other related
problems would have been found and corrected by this time. This piping meets the intent of
the code. This AD has no aggregate effect in combination with any of the other FP ADs
D171 Industrial Trucks Two (2) gaps from a review of NFCC-2005 regarding industrial trucks
[R-7] NK38-REP-00770- Gap 00429 against Clause 3.1.3.1 requires trucks to conform to NFPA 505-2002; fuel-fired Exclude
0425577 R001 trucks to conform to ULC/ORD-C558-1975, and battery-powered trucks to conform to
ULC/ORD-C583-1974, but documentation confirming compliance was not found. The IRF
demonstrates direct compliance.
Gap 00430 against Clause 3.1.3.3, which specifies requirements for the locations of battery AD
charging installations and requires installations to be equipped with at least one portable
extinguisher of minimum rating 2-A:30-B:C. The latter requirement has not been implemented
Page 38 of 77
0235 AD AGGREG 0004 01

due to restrictions on ABC-rated extinguishers. The IRF states the intent to reduce the
likelihood that fire suppression will be delayed or ineffective and points out that the batteries
remain on the vehicles, which carry such as a fire extinguisher. So the intent is met.
Furthermore the Station is protected by a highly trained ERT that always brings additional
extinguishers and hoses to a fire call. No further action.
D176 Fire Emergency One (1) gap from a review of NFCC 2005 regarding emergency planning for laboratories
[R-8] Planning of Laboratories Gap 00469 against Sub-Clauses 5.5.3.1.(2) and 5.5.3.1.(5), which require, in Subsection AD
NK38-REP-00770- 2.8.3, that fire drills be held at intervals not greater than 3 months in a laboratory and labs be
0425580-R001 designated a dangerous goods area. No documents found to indicate that fire drills are
conducted every 3 months for chemistry labs, and signage in the labs has not been
confirmed. The IRF demonstrates the intent is met through alternate compliance. The Fire
Safety Plan (FSP) addresses the entire site. A Pre-Fire-Plan exists for the labs and provides
the required information in conjunction with the FSP. The DNGS site has annual drills. The
ERT has the Pre-Fire-Plan, it and conducts regular training exercises.
D181 Fire Safety Training Three (3) gaps, one from review of NFCC 2005 and two from N293-07. Gap 00460 to be
[R-46] Requirements closed.
NK38-REP-00770- Gap 00460 against Clause NFCC Clause 4.5.10.2 It requires all employees concerned with A/R Exclude
0425764-R001 operations involving the transfer of flammable or combustible liquids to be trained in: No
documentation found that outlines the training requirements. A/R # 28155459-19
Gap 00565 against N293-07 Clause 8.2.1.4 It requires fire safety training to include the AD
following topics and procedures: (a) to (i). No evidence located to demonstrate this is met.
The ERT are responsible to respond to fire; the remaining staff is to safely evacuate the
affected area. DNGS gives the required training and equipment to the ERT and specific work
groups. This will continue for the extended station life.
Gap 00566 against N293-07 Clause 8.2. 7.2.1.2 It requires all staff to have hands-on training AD
in the use of portable fire extinguishers. DNGS does not train regular employees to fight a fire.
D215 Fire Department 26 gaps , 24 gaps from reviews of NFPA-24 (2006) and 2 from NBCC 2005. Nine (9) gaps are Exclude D215
[R-47] Connections to Fire ADs, and 17 are closed or will be closed.
Mains Gap 00807 against Clause 5.3.1 It requires jurisdictional permission to install pressure- Exclude
NK38-REP-00770- regulating valves in the fire water system. DNGS has self-regulating valves (PRVs) in some
0425798-R001 buildings, but permission could not be located. The Authority Having Jurisdiction (AHJ),
the Clarington Fire Department has accepted this.
Gap 00808 against Clause 5.9.1.1 It states that fire department connections (FDC) are to be Exclude
approved by jurisdictional authority. Fire department connections to fire mains are not
provided as required by NFPA-24. Approval by the authority for not providing a FD connection
not located. AHJ has accepted this.
Gap 00809 against Clause 5.9.1.2 It states that fire department connections are to be Exclude
properly supported. Approval by jurisdictional authority for not providing a FD connection
could not be located. Direct compliance with intent where applicable.
Gap 00810 against Clause 5.9.1.3 It requires FD connections to be of the approved type.
Approval by jurisdictional authority for not providing a FD connection could not be located. Exclude
Direct compliance with intent where applicable.
Gap 00811 against Clause 5.9.1.4 It requires FD connections be equipped with listed plugs
or caps. Approval by jurisdictional authority for not providing a FD connection could not be Exclude
located. Direct compliance with intent where applicable.
Gap 00812 against Clause 5.9.2.1 It requires FD connections to use National Hydrant (NH) Exclude
internal threaded swivel fittings with NH threads. Approval by jurisdictional authority for not
providing a FD connection could not be located. Not applicable.
Gap 00813 against Clause 5.9.2.2 It requires at least one of the connections be of the 2.5 - Exclude
7.5 NH standard thread Approval by jurisdictional authority for no FD connection not
located. Not applicable.
Page 39 of 77
0235 AD AGGREG 0004 01

Gap 00814 against Clause 5.9.2.3 It states the jurisdictional authority is to designate the FD
connection to be used wherever local connections do not conform. Approval by jurisdictional Exclude
authority for no FD connection not located. Direct compliance with intent where
applicable.
Gap 00815 against Clause 5.9.2.4 It states use of threadless couplings shall be permitted Exclude
where required by jurisdictional authority. Approval by jurisdictional authority for no FD
connection not located. Not applicable.
Gap 00816 against Clause 5.9.3.1 It states that a listed check valve is to be installed in each
FD connection. Approval by jurisdictional authority for no FD connection not located. Direct Exclude
compliance where applicable.
Gap 00817 against Clause 5.9.3.2 It states that no shutoff valves are permitted in FD Exclude
connection piping. Approval by jurisdictional authority for no FD connection not located.
Direct compliance with intent where applicable.
Gap 00818 against Clause 5.9.4.1 It states that the pipe between check valve and outside A/R Exclude
hose coupling to be equipped with an approved automatic drip. Approval by jurisdictional
authority for no FD connection not located. Gap updated based on reanalysis. In dwg. F1H,
FD connection for the TRF Annex is shown without an automatic drip device. In dwg. D0H,
the FD connection is fitted with inch check valve, but BM shows IE 44 drip valve. Drawing
to be revised A/R # 28156258-05.
Gap 00819 against Clause 5.9.4.2 It states an automatic drip shall not be required in areas
Exclude
not subject to freezing. Approval by jurisdictional authority for no FD connection not located.
Not applicable. Closed.
Gap 00820 against Clause 5.9.5.1 It states FD connections to be located on the street side of Exclude
buildings. Approval by jurisdictional authority for no FD connection not located. Direct
compliance with intent where applicable.
Gap 00821 against Clause 5.9.5.2 It states FD connections are to be located and arranged
Exclude
so that hose lines can be attached without nearby interferences. Approval by jurisdictional
authority for no FD connection not located. Direct compliance with intent where
applicable.
Gaps 00822 and 00823 against Clauses 5.9.5.3 and .4 They impose requirements for
A/R Exclude
signage for FD connections to sprinkler systems. Approval by jurisdictional authority for no FD
connection not located. Regarding gap 00822, it was determined that a FDC was provided for Exclude
the TRF Annex, however, the sign is marked Sprinkler instead of Standpipe and auto SPRK.
Revise sign, A/R # 28156258-06 to be completed. Gap 00823 Closed; Not applicable
Gap 00824 against Clause 5.9.5.5 It states a sign is to be attached to indicate portions of the
A/R Exclude
building supplied by FD connections. Approval by jurisdictional authority for no FD connection
not located. A FDC was provided for the TRF Annex, but it serves only the annex, not TRF
and D2O management building. So a sign is required. A/R # 28155459-22.
Gap 00825 against Clause 7.1.1.2 It imposes need for jurisdictional authority approval for fire
hydrant design and protection. Approval by jurisdictional authority for the hydrant protection Exclude
not located. AD. HY-22 and HY-23 comply with reg. requirements; wall hydrants are
satisfactory. Not relevant for evaluation of aggregate effects.
Gap 00826 against Clause 7.2.4 It imposes need for jurisdictional authority approval for fire
hydrant location where closer than 40 feet to a building. Approval by jurisdictional authority Exclude
not located for a hydrant located ~ 30 feet from D2O mgmt building. AHJ is aware of and
accepted the FW supply and arrangement, which meets the intent of the code.
Gap 00827 against Clause 13.3 It imposes need for jurisdictional authority approval for the Exclude
size of private fire service mains. Approval by jurisdictional authority for the size of the private
fire service mains not located. AHJ is aware of and accepted configuration; the design and
water supply are documented and are satisfactory.
Gap 00833 against Clause 7.2.1 It states that hydrants are to be provided and spaced in
Exclude
accordance with the requirements of the jurisdictional authority. No approval by jurisdictional
authority found for the hydrants provided and their spacings. AHJ aware; design satisfactory
Page 40 of 77
0235 AD AGGREG 0004 01

Gap 02000 against Clause 5.9.1 It requires that a FD connection be provided as described in
Section 5.9 of this Standard. FD connections are provided for the TRF Annex FP system, for Exclude
Turbine Hall Fire Water Dry Riser systems and for the Turbine Hall sprinkler systems, but no
FD connection is attached directly to the Powerhouse private water service mains (or in
consequence to the Standpipe systems) in the Powerhouse. The private water service mains
are fitted with an alternate branch connection (complete with cap and control valve) which is
to be used to connect a temporary water supply if the ESW system is out of service, but this
configuration does not constitute a FD connection as illustrated in NFPA 24, Fig A.5.9(a)
and/or (b). IRF explains in detail that the existing FDCs are very good and comply with intent
of the code.
Gap 02005 against Clause 6.2.3 It states that where more than one sources of water supply
exists, a check valve shall be installed in each connection. Two incoming water lines from the A/R Exclude
ESW Pumping system provide normal water supply to the private service water mains, and a
cross connection in the Central Service Area provides an alternative emergency supply.
There is a check valve and PRVs; however, the TRF Annex supplies do not have a check
valve. Design change A/R # 28156258-07.
Gap 01893 against NBCC Clause 3.2.5.9.(6) It requires a FD connection for every standpipe
system. Requirement came after DNGS built. There are generally no FD connections to Exclude
standpipe systems, except TRF Annex and Turbine Building. The other systems use EWS,
which is fully acceptable. AHJ is aware of arrangement. Alternate compliance with intent.
Gap 01894 against NBCC Clause 3.2.5.16 It requires the FD connection for a standpipe
system and sprinkler system be located so the distance from the FD connection to a hydrant Exclude
is not more than 45 m and is unobstructed. The FD connection serving the D2O/TRF building
is located ~54 m from the hydrant. Complies with intent. Hoses are sufficient size/length.
D222 Public Address System Three (3) gaps from reviews of CAN/CSA N293-07 on performance requirements of public
[R-9] NK38-REP-00770- address system
0425804-R001 Gap 00534 against Clause 7.2.1.2 It requires integrated, supervised one-way voice AD
communication in all structures and exterior areas and in areas where SSCs directly support
the plant. The PA system does not meet requirements for circuit supervision, speaker Gap 00534
coverage or treatment for high noise level places. To comply, the IRF states that DNGS intent is met
implemented a monitoring program of periodic inspection, testing and maintenance of the PA by program to
system to achieve the intended level of reliability. To maintain audibility, the program requires inspect, test
employees to raise SCRs if they do not hear test announcements during weekly testing. In and maintain
addition, a speaker audibility walk down is performed monthly by Emergency Response PA system.
Maintenance. Visual signal strobes have not been installed in high noise areas; the alternative
approach of posting warning signs and limiting access to high noise rooms is used. The intent
of the requirements is met. No further action.
Gap 01285 against Clause 7.2.3.2 It requires fire alarm signals and voice announcements to
be audible and intelligible in interior areas as per NBCC-2005 and CAN/ULC S524-01. Fire AD
alarm signals and voice messages are not clear in some locations due to high noise or poor
speaker coverage. IRF indicates the Fire Protection Code Compliance Review report states
the alternative measures meet the intent of the codes provisions for circuit supervision and
speaker coverage for the PA systems. No further action.
Gap 01845 against Clause 7.2.3.1 It requires that accessible spaces be equipped audible AD
and/or visual fire alarm signal devices. However, some accessible areas of the station are not
covered. The resolution in the IRF for this gap is the same as the resolution in the IRF for Gap
00534 above. No further action.
D225 Fire Protection Water Six (6) gaps, five (5) from reviews of CAN/CSA N293-07 and one from RD-337. Four gaps will
[R-48] Supply be closed; gap 00550 provides equivalent/better performance, and gap 01847 credits ERT.
NK38-REP-00770- Gap 00459 against Clause 7.3.2.1.2 It specifies requirements for FP water supply volume, A/R Exclude
0425807-R001 which is to be based on largest expected flow rate for 2 h, the hose stream demand include
an attack demand of 2850 L/min, delivering the demand when the most favourable portion of
the fire main loop is out of service. The DMs indicate the maximum demand is 315 L/s. The
DM doesnt fully address the requirements of this clause, and need to address deterioration of
Page 41 of 77
0235 AD AGGREG 0004 01

the water supply piping over next 30 years. A/R # 28155462-40.
Gap 00550 against Clause 7.3.2.2 The FP water supply is via the ESW pumps. It does not Exclude
meet the requirement to have pumps in accordance with N293-07 and NFPA 20. ESW
pumps are effective, more reliable. The design exceeds the intent of the requirement.
Gap 01847 against Clause 7.3.2.1.6 It states that the FP water supply may be used on an A/R Exclude
emergency basis to provide backup to nuclear safety systems, as long as the FP water supply
systems are designed to deliver the combined fire and nuclear safety flow demands for the
duration specified. The deterioration of the water supply (ESW) piping should be assessed.
A/R # 28155462-41.
Gap 01848 against sub clause [a, b, c] of Clause 7.3.2.3 It requires the FP water distribution AD
system be in accordance with NFPA 24, including
a) Distribution of water shall be through a loop main such that water can reach each Credit ERT
connection from two independent directions. Water mains not to be buried under buildings. action
b) At least two independent connections to the loop main for each major building, that each
connection is capable of providing the flow to meet demand and pressure requirements.
c) Means for inspection and flushing of the piping systems
For item b), two separate connections are not provided to D2O mgmt bldg, water treatment
plant or the unit pumphouses. ERT has hoses and other water sources to meet intent for
these low risk buildings.
Gap 01849 against Clause 7.3.3.1 It states that where a sprinkler system is required, it shall A/R Exclude
be as per NFPA 13 and 15. Legacy sprinklers are to the 1981 edition, while new sprinklers
are to the 1996 edition. A new facility is subject to the later editions of NFPA 13 and 15. A/R #
28155462-31 to -35.
Gap 01483 against RD-337 Clause 8.8 It requires that if fire water supply is interconnected to
the emergency heat removal system (EHRS), operation of one does not impair operation of A/R Exclude
the other. The ESW supplies water to Fire Water and Distribution Systems during normal
operation. The ESW includes two 14 inch flow paths to FP water system, each with a single
normally-open isolation valve. Both single isolating valves on the parallel flow paths have to
be available (able to close), to isolate non-essential loads following a seismic event. The
firewater load is safety-related, but a fire is not postulated at the same time as a LOCA or a
seismic event. However, for a fire and coincident LOCA or seismic event, either EHRS or
firewater would be impaired. A/R # 28155463-17.
D226 Control Room Complex Seven (7) gaps, from reviews of CAN/CSA N293-07. Gaps 00498 and 00499 are ADs. Three Exclude D226
[R-49] Fire Protection ADs moved to D430. Gap 01750 to be closed.
NK38-REP-00770- Gap 00497 against Clause 5.7.8.1 It requires that the safety measures in Clauses 5.7.8.2 to Gap 00497 is
0425808-R003 5.7.8.6 be complied with for the control room complex. Gaps identified for Clauses 5.7.8.2, covered by
5.7.8.3 and 5.7.8.5. Gaps 00498 and 00499 are ADs. Gap 01750 (5.7.8.3) will be closed. other gaps in
Gap 00498 against Clause 5.7.8.2 It requires control room complex be separated from D226
adjoining areas by a fire separation. MCR is not separated from the CER with fire-resistant Exclude
rated separation. FHA determined design meets the 2 h requirement.
Gap 00499 against Clause 5.7.8.5 It requires that areas of the control room complex outside Exclude
of the MCR and CER and control computer room be protected by fire suppression systems
and be separated from the MCR and CER by a fire separation. The office areas do not have
suppression systems. Moved to D430..
Gap 00544 against Clause 7.2.2.3 It requires the control room complex be equipped with a Exclude
fire alarm system that uses very early warning fire detection technology. The MCR has state-
of-the-art addressable smoke detectors, but not a very early warning fire detection system.
Moved to D430.
Gap 01281 against Clause 6.7.1.1 It requires the control room complex be separated from Exclude
the rest of the building by a fire separation with a 2 h rating, unless greater rating required by
the FHA. N-STC-27800-10000 requires barriers provide satisfactory level of fire protection,
but does not specify a separation with 2 h rating. Moved to D430.
Gap 01282 against Clause 6.7.1.3 It prescribes air quality within the complex for a fire Exclude
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0235 AD AGGREG 0004 01

occurring outside the complex. DM does not specify a maximum of 1% contaminated air.
Moved to D430.
Gap 01750 against Clause 5.7.8.3 It requires special consideration be given to prevention of A/R Exclude
fires in the control room complex. Section 6.8 provides the FP requirements. Some clauses
were determined to be gaps. A/R # 28155462-22.
D227 Fire Hydrant Seven (7) gaps, four from CAN/CSA N293-07 and three from NFPA-24 2007
[R-50] Requirement Gap 00555 against Clause 7.3.6.2 It requires fire hydrants be spaced a maximum of 75 m Exclude
NK38-REP-00770- apart. DM states maximum of 90 m apart. AHJ accepts. Same as gap 00833 of D215.
0425809-R001 Gap 00556 against Clause 7.3.6.4 It requires that isolation valves that control only water AD
supplies to a hydrant are post-indicating valves and may be locked open in lieu of fire alarm
supervision. DM states that each hydrant is isolated by a gate valve but does not state if they Credit ERT
are post-indicating valves or if they are locked open. AD. The 2 yard hydrants by the VB are action
isolated by buried valves. Valve keys are nearby. Credit ERT and procedures/WA to close.
Gap 00557 against Clause 7.3.6.5 It states wall hydrants shall not be a substitute for yard Credit ERT
hydrants. All yard hydrants except HY22 and HY23 near the vacuum bldg are wall mounted. action
Wall hydrants are accessible in a fire by ERT.
Gap 00558 against Clause 7.3.6.6 It requires hydrants be marked in accordance with NFPA A/R Exclude
291-2007. DM does not state that hydrants are marked. Action to flow test and mark as per
NFPA-291 A/R # 28155459-23.
Gap 02012 against NFPA-24 Clause 7.1.4 It requires hydrants on private service mains shall
not be equipped with pumper outlets unless the calculated demand for large hose, 3 inch Exclude
and larger, is added to attack hose and sprinkler system demands when determining the total
demand on the FP supply. The two yard hydrants HY22 and HY23 are equipped with pumper
outlets; however, as per DM, the allowance for one hydrant is just 31.5 L/s (350 USGPM)
which can be satisfied by the two 2 inch hydrant butts. No documents located that analyzed
the fire load, but the IRF evaluation demonstrates the fire load within reach of these hydrants
is much less than their capability. ERT will not exceed flow capacity. Design complies with
intent of Clause 7.1.4..
Gap 02013 against NFPA-24 Clause 7.2.3 It requires that hydrants be located not less than
40 ft from the buildings to be protected. HY22 and HY23 are located close to the Vacuum Credit ERT
Bldg and about 30 ft from other adjacent buildings. The remaining hydrants are wall hydrants. action
No approval from the AHJ for these hydrant locations. Additional analysis in [R-95] Appendix
A-9 documents that falling walls are very unlikely. Interior fires attacked by ERT using
standpipe systems or an adjacent wall hydrant. Same as gap 00557.
Gap 02014 against NFPA-24 Clause 7.3.2.2 It requires that hydrants in cold climates
A/R Exclude
requiring pumping out after usage shall be marked to indicate the need for pumping out after
usage. HY22 and HY23 have no signs. A/R # 28155459-24.
D233 Manual Fire Alarm Pull One (1) gap from CAN/CSA N293-07 Exclude D233
[R-10] Stations Gap 01284 against Clause 7.2.2.1 It requires manual alarm pull stations be located at all exits Exclude
NK38-REP-00770- and along each main isle. DNGS has no manual pull stations along the main egress routes
0425813-R001 (powerhouse) to maintain the 30 m maximum travel distance requirement for unsprinkled
areas and 45 m for sprinkled areas. Powerhouse staff is familiar with the building, egress
routes and exits, and is trained in fire safety actions. The existing pull station locations
are adequate. No action required. Not applicable to DNGS
D251 Fire Protection Nine (9) gaps, from review of ASME N509-2002. Gaps 01333 and 01334 are ADs. The other
[R-51] Requirements for Air- gaps will be closed.
Cleaning Units Gap 01332 against Clause 4.11.1 It requires components in air-treatment systems minimize A/R Exclude
NK38-REP-00770- use of combustible materials. No documents on compliance. Gap equivalent to D297 Gaps
0425829-R001 00522 and 02065, and D439 Gap 01764 against N293-07 Clauses 6.8.3.2 to 6.8.3.4. A/R #
28155459-12, -13 and A/R # 28155462-39.
Gap 01333 against Clause 4.11.2 It requires fire detection mechanisms in the air-treatment
systems, inclusive of two-stage alarms. No documents on compliance. This requirement is
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0235 AD AGGREG 0004 01

part of the strategy to prevent smoke recirculation, which is D457 Gap 01887 against NBCC AD
Clause 3.2.4.12. D457 is AD because fan shutdown would have a negative impact on
nuclear safety. The two-stage alarms are already covered in D044 Gaps 00535 to 00537
against N293-07 Clauses 7.2.1.6.1 to .3.
Gap 01334 against Clause 4.11.3 It requires fire brigade be called upon the first-stage high
temp alarm. No documents on compliance. This is related to a two-stage fire alarm, which Exclude
is covered in D044 Gap 00536 against N293-07 Clause 7.2.1.6.2. Exclude.
Gap 01335 against Clause 4.11.4 It requires FHA for all air-cleaning units and components
as per 10CFR50 Appendix R and NFPA 803. No documents on compliance. Gap equivalent A/R Exclude
to D439 Gap 01764 against N293-07 Clause 6.8.3.4. A/R # 28155462-39.
Gaps 01336 to 01339 against Clauses 4.11.5 to 4.11.8 They require FP measures to be in
place if FHA deems. No documents on compliance. Gaps equivalent to D439 Gap 01764 A/R Exclude
against N293-07 Clause 6.8.3.4. A/R # 28155462-39.
Gap 01340 against Clause 4.11.9 It requires remedial steps to reinstate air-cleaning unit in A/R Exclude
event that carbon becomes wet. No documents on compliance. Gap equivalent to D439 Gap
01764 against N293-07 Clause 6.8.3.4. A/R # 28155462-39.
D298 National Fire Code Seven (7) gaps from NFCC 2005 Exclude D298
[R-11] Storage Room Design Gap 00431 against Article 3.2.2.2 It specifies requirements for access aisles in storage Exclude
Requirements rooms, including firefighting access, minimum dimensions and obstruction restrictions. No
NK38-REP-00770- documentation that demonstrates compliance. Analysis of the CSA storage areas
0426328-R001 indicates the upper stores and control maintenance stores meet requirements. The
ERT confirmed the aisle widths in the lower stores are acceptable. Intent is met.
Gap 00432 against Article 3.2.2.3 It specifies clearance requirements for walls, ceiling, Exclude
sprinkler system and exhaust ventilation system in storage rooms. An additional requirement
is for clearance between stored products and ducts of the exhaust ventilation systems. No
documentation that demonstrates compliance. Gap is closed by direct compliance.
Gap 00434 against Article 3.2.2.7 It specifies the maximum permitted height of storage in an
area to be according to base area, shape, stability and potential height limitations. No Exclude
documentation that demonstrates compliance. Gap is closed by direct compliance
Gap 00439 against Article 4.2.8.4 It species that, in general storage areas, the height of Exclude
storage of flammable and combustible liquids not exceed that permitted for unprotected
storage. No documentation that demonstrates compliance. The DNGS fire safety plan limits
the amount in the Central Service Area Stores. DNGS procedures provide requirements
for these liquids. Approved storage cabinets are used. Gap is closed by direct
compliance.
Gap 00441 against Article 4.2.9.2 It specifies that rooms for storing and dispensing flammable
liquids be liquid-tight where the walls join the floor. No documentation that demonstrates Exclude
compliance. Not applicable.
Gap 00442 against Article 4.2.9.3 It specifies 1 m minimum aisle width in rooms for storing Exclude
and dispensing flammable liquids. No documentation that demonstrates compliance. Not
applicable.
Gap 00443 against Article 4.2.9.5 It specifies requirements for venting of storage rooms
without critical structural and mechanical damage from an internal explosion. No Exclude
documentation that demonstrates compliance. Not applicable.
D428 Detection of Significant Two (2) gaps from review of CSA N293-07 Exclude D428
[R-52] Fire Hazards Gap 02045 against Clause 5.3.3 It requires means be provided to quickly detect and Exclude
NK38-REP-00770- extinguish or control fires. Rooms in the FHA Table 4-1.1 contain fire hazards that need
0462011-R001 automatic detection to improve emergency response time. The rooms do not have automatic
detection. Perform assessment to determine adequacy of existing provisions to detect a fire in
the areas. A/R #28155463-03 was completed.
Additional analysis in [R-95] Appendix B-2 explains why the code cannot be met in four areas
and how the alternative achieves the intended safety function. This is an economic issue. The
Page 44 of 77
0235 AD AGGREG 0004 01

analysis recommends that, since the Fire Safe Shutdown Analysis (FSSA) goals are met
by the existing provisions and there is no life-safety issue, a benefit cost analysis be
prepared to determine whether a change should be made to address the ESW pump oil
hazard from an economic loss standpoint. Not a safety concern...Exclude
Gap 01268 against Clause 5.7.3.1 It requires a fire alarms system be installed in buildings.
The types, performance levels and associated safety features to be in accordance with this Exclude
Standard and the NBCC. Rooms in FHA Table 4-1.1 ... same as above.
D429 Fire Separations Seven (7) gaps, four from review of NBCC 2005, one from NFPA 20 2007, one from N293-07 Exclude D429
[R-52] Corrective Actions and one from NFCC 2005. Six gaps will be closed, and the seventh can be excluded.
NK38-REP-00770- Gap 00420 against NBCC Clause 2.4.1.2 It requires that rooms for storage of combustible A/R Exclude
0462012-R000 waste materials conform to NBCC. No documents confirm compliance. Room D-107C in D2O
mgmt bldg will be upgraded. A/R # 28156258-03.
Gap 01860 against NBCC Clause 3.1.8.4 It requires fire-protection rating of a fire separation
closure conform to Table 3.1.8.4 for the required fire-resistance rating (FRR). Table requires a A/R Exclude
minimum 45 min fire protection rating for a closure in a fire separation with a 1 h FRR.
Closures in a 1 h rated separation are not indicated as being fire-rated doors. Door will be
replaced A/R # 28155463-10.
Gap 01917 against NBCC Clause 3.4.4.1 It requires an exit to be separated from the
remainder of the building by a separation having a FRR not less than required by subsection A/R Exclude
3.2.2, but not less than 45 min for the floor assembly above the storey, or the floor assembly
below the storey if there is no floor assembly above. The FRR of the fire separation is not
required to be more than 2 h. Gap 01917 identifies exit enclosures in the powerhouse that fail
to provide the required FRR they were designed to provide ... Some have been corrected and
the remainder will be A/R # 28155462-27
Gap 02083 against NBCC Sentence 3.4.4.4.(8) It requires storage rooms, washrooms, toilet A/R Exclude
rooms, laundry rooms, etc. Not to open directly into an exit. Storage room R3-241 opens
directly into an exit stair. A/R # 28155463-11.
Gap 01927 against NBCC Clause 3.6.2.5 It requires a room for storage of combustible refuse
to be sprinklered and separated from the building by a separation with FRR not less than 1 h. A/R Exclude
Room D107-C in D2O mgmt bldg is sprinklered but not enclosed by a 1 h fire separation. A/R
# 28156258-04.
Gap 01968 against NFPA 20 Clause 5.12.1.1.2 It requires indoor fire pumps in non-high-rise
Exclude
buildings to be physically separated or protected by fire-rated construction in accordance with
Table 5.12.1.1.2. Fire pumps in DNGS are on open floor areas; not in rated enclosures. The
CNSC accepted that an enclosure to protect the pump, etc. from damage by external hazards
is not applicable to pump locations on Elevation 122.500. Also, the pumps are backed up
by other pumps, not in a fire prone area, and other justifications in the IRF.
Gap 02046 against N293-07 Clause 5.3.4 It requires provision of fire separations or other
measures to limit the spread of fire and its effects, minimizing the impact on the plant and its A/R Exclude
occupants. The existing plant configuration does not fully comply with the fire separation
requirements for a new plant design, as detailed in Section 6. These deviations are covered in
other issues, with 2 corrective actions A/R # 28155463-12.
D437 2hr Emergency Lighting One (1) gap from CAN/CSA N293-07
[R-12] Requirement Gap 01762 against Clause 6.6.1.3 It requires emergency lighting be provided with a minimum AD
NK38-REP-00770- 2-hour emergency power supply. In most locations, DNGS emergency lighting is fed by Class
0462020 R000 II power. In the locations not served by Class II power, the battery packs provided are
adequate for the required evacuation time, which is less than 2 hours. The ERT and the
Operators can perform their necessary actions using battery-powered flashlights. The
intent of this clause is met. No further action is required.
D438 Access for Fire Fighting One (1) gap from CAN/CSA N293-07
[R-13] NK38-REP-00770- Gap 01763 against Clause 6.6.3 which provides an exemption for a NPP, regarding NBCC AD
0462021 R000 requirements on window openings and access hatches, for plant security and protection from
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0235 AD AGGREG 0004 01

external events, where compensatory measures acceptable to the CNSC are provided. No
documentation found to demonstrate compliance. DNGS has multiple building interior
access locations to fight fire and a full-time ERT, with ventilation to manage smoke.
The DNGS ERT has the necessary training and equipment to perform its duties.
Acceptable deviation. No further action.
D439 Fire Protection of One (1) gap from review of CAN/CSA N293-07
[R-53] Charcoal Filters Gap 01764 against Clause 6.8.3.4 It requires fire protection for charcoal filters to be provided AD
NK38-REP-00770- to ensure fires do not spread beyond the filter housing and prevent uncontrolled release of Credit ERT
0462022 R000 contamination. HVAC contaminated exhaust units use charcoal filters, which are not fire action
protected. Additional analysis in [R-95] Appendix A-7 demonstrates that from a fire hazard
perspective, the existing filter design is acceptable. The existing design provides a filter high
temperature signal to U0 operator, who sends the ERT to spray water on the filter units to
prevent filter ignition at 330 degC and spread of fire beyond the housing. Present protection
measures do not fully meet code requirement to prevent uncontrolled release of radioactivity
into the atmosphere because a fire in the filter housing would release contaminated smoke. A
means to suppress the charcoal filter fire within the housing during the early stages would
limit the amount of material consumed and reduce the radioactive release. The potential
release from a charcoal filter fire is 60 MBq or 0.14% of the weekly DRL. Costs to retrofit
filter enclosures not justified by the gained benefit for this very unlikely event.
D440 Combustible Material in Six (6) gaps, four from NBCC 2005 and two from CAN/CSA N293-07 Exclude D440
[R-14] Electrical Equipment Gap 01865 against NBCC Clause 3.1.13.4 It permits the flame-spreading rating of Exclude
NK38-REP-00770- combustible light diffusers and lenses to exceed limits specified elsewhere in NBCC. No
0462023 R000 evidence found regarding DNGS compliance. Assessed to be compliant.
Gap 01765 against N293-07 Clause 6.8.4.2 It requires that electric and control cabinets be
designed to minimize flame spread across adjacent cabinets. This level of the design was not
inspected. FSSA analyzed failure of all credited cabinets and demonstrated the fire safe
shutdown goals are achieved. Complies with code.
Gap 01766 against N293-07 Clause 6.8.4.4 It requires electrical cables have low (1.5 m) Exclude
flame-spread rating and produce low smoke and corrosive gases. Cable systems DM
indicates all cables comply except for power cables 5 kV and above, which have a 2 m
flame spread. Assessed to be acceptable compliance with code.
Gap 01857 against NBCC Clause 3.1.5.18 It permits optical fibre cables and electrical wires Exclude
and cables with combustible insulation, jackets or sheathes, but places limits on their use.
The exposed power cables do not conform. Assessed to be acceptable compliance.
Gap 01858 against NBCC Clause 3.1.5.20 It permits use of totally enclosed non-metallic
raceways, not more than 175 mm in outside diameter or an equivalent rectangular area, to Exclude
enclose optical fibre cables and electrical wires and cables, provided their vertical char is not
more than 1.5 m. No documentation found to confirm DNGS compliance. Assessed to be
acceptable compliance.
Gap 01930 against NBCC Clause 3.6.4.3 It permits the materials in a concealed space used
as a plenum within a floor or a roof assembly not to conform to Sentence 3.1.5.15 (1) and Exclude
article 3.6.5.1. It applies to Central Services Areas such as MCR and the Cafeteria. Specified
for a vertical char limit of 2 m, the DNGS power cables do not meet the CSA C22.2 No.
0.3 FT4 rating of 1.5 m. Assessed to be acceptable deviation. No action required.
D443 Location of Five (5) gaps, three from CAN/CSA N293-07 and two from NBCC 2005
[R-15] Extinguishers and FHCs Gap 01851 against N293-07 Clause 7.3.5.1 It requires all areas to be protected by portable AD
(fire hose cabinets) fire extinguishers as per NFCC-2005 and NFPA 10-2007, but FHA identified 276 deviations.
NK38-REP-00770- DNGS limits extinguishers to ERT, who are trained in their proper use. No action required.
0462026-R000 Gap 01852 against N293-07 Clause 7.3.7 It requires standpipes as per NFPA 14-07. The
areas inside containment are to be provided with Class I standpipe systems and a dry AD
connection through the containment structure, which may be manually connected to the
standpipe. ... CCR indicates that hose connections are not provided throughout. Actions: 1)
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0235 AD AGGREG 0004 01

one connection installed for sufficient overlap, 2) the locations where hose station separation
exceeds 130 ft were analyzed in FHA; issue resolved by crediting ERT who have 100 ft hoses
with appropriate connections to extend coverage, 3) reactor vaults are access controlled
areas; during outages, safe fire prevention practices followed with manual fire suppression
equipment provided. No further action required.
Gap 01853 against N293-07 Clause 7.3.8.1 It requires a means for manual firefighting as per AD
NBCC-2005 and/or the FHA. FHA Section 4.3 identifies multiple deviations regarding areas
not adequately provided for. A total of 1515 portable extinguishers are strategically located in
protected areas and training provided to selected people. Numerous FHCs are provided as
detailed in FHA, and the ERT has sufficient firefighting equipment. No further action
required.
Gap 01895 against NBCC-2005 Clause 3.2.5.10 It states: 1) hose connections required in AD
exits as per NFPA 14, 2) hose connection not required within a floor area, 3) hose
connections to have clearance to permit use of standard fire department hose key, 4) 64 mm
diam. hose connections shall be installed in a standpipe system, except for a building not
more than 25 m high and in which an automatic sprinkler system is not installed. The CCR
Sect. 4 identified multiple deviations regarding areas not adequately provided for. OPG has
provided 63 mm hose connections in key areas to provide overlapping coverage with 38 mm
station coverage. The ERT knows the locations of the connections, and can attach hoses to
connections in safe areas, to attack fires without being put in danger. Occupants are trained
to initiate fire alarms, not to use hoses. Deviations are acceptable. No further action
required.
Gap 01896 against NBCC-2005 Clause 3.2.5.11 It requires hose stations for 38 mm diam.
hose for a standpipe system in a building that is not sprinkled throughout, within every floor AD
area, within 5 m of exits and at other locations to provide coverage of the entire area. Fully
opened hose cabinet door not to obstruct egress. The CCR Section 4 identifies multiple
deviations regarding areas not adequately provided for. The full-time, trained ERT is available
with additional hose lengths and booster pumps. Deviations are acceptable. No further
action required.
D445 Combustible Insulation Three (3) gaps from review of NBCC 2005. Gaps 01855 and 1929 to be closed. One N/A Exclude D445
[R-54] NK38-REP-00770- Gap 01855 against Sentences 3.1.5.12.(2), (3), (4) and (6) They pertain to foamed plastic Exclude
0462028-R000 insulation, combustible insulation and thermosetting foamed plastic insulation. Four DNGS
drawings lacked information. Additional analysis in [R-95] Appendix A-12 states that interior
walls that are insulated with (50 mm) Styrofoam SM and protected by 13 mm gypsum board
are non-compliant. Compliance requires a type X gypsum board at least 16 mm thick.
Changing or adding gypsum board (in 93 rooms) would be costly and disruptive compared
with the small benefit. Based on a review of usage, entry control, supporting fire protection
measures that exist for these rooms and the FSSA, FHA and FP code compliance review
reports, the continued operation with the existing 13 gypsum board does not compromise life
safety and nuclear safety.
Gap 01879 against Sentence 3.2.3.19.(2) It requires that a walkway connected to a building Exclude
be non-combustible. Documents on insulation not located. Insulation assessed to comply.
Gap 01929 against Clause 3.6.3.2 It requires foamed plastic insulation in a vertical service Exclude
space be protected in accordance with Clause 3.1.5.12 (gap 01855 above). No documents
found. Additional analysis in [R-95] Appendix A-12 is applicable also to this gap. A thorough
field inspection was carried out and found no foam plastic. DNGS is compliant.
D446 Combustible Material in Six (6) gaps from review of NBCC 2005. Gaps 01856 and 01934 will be closed. For the other Exclude D446
[R-55] Ducts four gaps, intent is met by alternate compliance.
NK38-REP-00770- Gap 01856 against Clause 3.1.5.15 It permits combustible duct linings, etc., providing they A/R Exclude
0462029-R000 conform to Subsection 3.6.5. Vibration isolation on ventilation systems is typically rubber or
similar material. A/R # 28155462-23.
Gaps 01931 against Clause 3.6.5.1 It requires acceptable flame spread rating and smoke-
development properties ... No evidence found that duct connectors are non-combustible, or Exclude
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0235 AD AGGREG 0004 01

conform to the criteria of this requirement. The properties of the sealant should be confirmed.
It is not reasonable to replace all existing ductwork, so the material is deemed acceptable for
the extended life. Future mods will use sealant that conforms to this code. The intent is met
through alternate compliance.
Gap 01932 against Clause 3.6.5.2 It requires vibration isolation connectors ... No evidence
found to confirm that vibration isolation connectors conform. The existing isolators are Exclude
deemed acceptable. The intent is met through alternate compliance.
Gap 01933 against Clause 3.6.5.3 It requires duct tape meet flame-resistance requirements Exclude
in CAN/ULC-S109. No evidence found. The existing tape is deemed acceptable. The intent
is met through alternate compliance.
Gap 01934 against Clause 3.6.5.4 It requires (1) to (5) and (7) ... coverings, etc. for surfaces A/R Exclude
more than 120 degC be of non-combustible material ... flame-spread rating, smoke
developed classification ... not flame, glow, smoulder or smoke when tested as per ASTM
C411 ... foamed plastic insulation ... not penetrate a fire separation. Insufficient evidence
found. A/R # 28155462-23.
Gap 01936 against Clause 3.6.5.7 It states that combustible grills, diffusers, etc. for supply,
return and exhaust-air openings shall to conform to the flame-spreading rating and smoke Exclude
developed classification requirements. Insufficient evidence found. The existing grills,
diffusers, etc. are deemed acceptable. The intent is met through alternate compliance.
D447 Fire Separations Three (3) gaps from NBCC 2005 Exclude D447
[R-16] Acceptable Deviations Gap 01859 against Sentence 3.1.7.5 (1) It requires load bearing walls, columns, and arches Exclude
and Alternate in the storey immediately below a floor or roof assembly to have an adequate fire-resistance
Compliances rating (FRR) for the supported floor or roof. Some DNGS buildings have unprotected
NK38-REP-00770- structural steel members that void the fire ratings of the assemblies they support.
0462031 R000 These DNGS buildings are suited to the Life Safety Code NFPA 101-2012. This gap is
closed because DNGS complies with the alternate code that addresses this issue.
Gap 01861 against Sentence 3.1.8.5 (2) It requires every door, window assembly or glass Exclude
block used as a closure in a required fire separation be installed in conformance with NFPA
80 on fire doors and other opening protectives. Not all doors required to be fire rated
doors are equipped with fire rating labels. The unlabeled doors were assessed, and
they comply.
Gap 01862 against Article 3.1.8.6 It limits the size of an opening in an interior fire separation
required to be protected by a closure. DNGS has openings through floors and hatches that Exclude
exceed the limits. Since resolution of this gap depends on CNSC acceptance of the FHA,
this gap has been moved to Issue D431.
D450 Building Height Eleven (11) gaps from NBCC 2005
[R-17] Determination and Fire Gap 01866 against Clause 3.2.1.1. (3), (4) and (7) This clause specifies how mezzanine AD
Resistance space to be used in determining building height. The change in the NBCC from 1980 to 2005 Procedural
NK38-REP-00770- changed the Unit 0 building height from 6 to 8 stories. The implications to upgrade the controls limit
0462034 R000 existing building to meet this NBCC 2005 clause are substantial and the cost is prohibitive. combustible
Clause 3.2.2.2 provides for special considerations for Special and Unusual Structures, which materials, for
applies here. Acceptable deviation. No further action. all gaps
Gaps 01867, 01868, 01869, 01901, 01902, 01903, 01904, 01905, 01906 and 01907 against
Clauses 3.2.1.4, 3.2.1.5, 3.2.2.6, 3.2.8.1, 3.2.8.4, 3.2.8.5, 3.2.8.6, 3.2.8.7, 3.2.8.8 and 3.2.8.9
are all classified as acceptable deviations in this IRF based on OPG procedural controls to
limit combustible materials and considerations that are similar to Gap 01866 above. No
further actions are required.
D451 Building Classification Three (3) gaps from NBCC 2005 Exclude D451
[R-18] and Sprinkler Gap 01870 against Clause 3.2.2.18 (1) It requires an automatic sprinkler system be installed Exclude
Requirements throughout a building regulated by one or more of Articles 3.2.2.20 to 3.2.81 and as per
NK38-REP-00770- Clause 3.2.2.18 (2). The Tritium Removal Facility (TRF) and the Powerhouse are not
0462036 R000 provided with automatic sprinkler protection throughout as required. This gap is closed
Page 48 of 77
0235 AD AGGREG 0004 01

because of special considerations in the NFPA 101 code that address this issue that
DNGS complies with for these buildings.
Gap 01871 against Clauses 3.2.2.63 (1) and (2) It states that a building classified at Group F Exclude
Division 1 shall conform to Sentence 3.2.2.63 (2), provided it is not more than 4 stories in
height and has an area not more than 2,250 sq m. It is required to be of non-combustible
construction, sprinkled throughout and floor assemblies constructed as fire separations with 2
h or more rating. The mezzanines, walls, columns and arches are to be fire resistant. The
TRF is a high hazard F-1 building with area exceeding the limits of this clause. It does not
comply with these requirements. This gap is closed because of special considerations in
the NFPA 101 code that address this issue that DNGS complies with for this building..
Gap 01872 against Clause 3.2.2.73 (1) and (2) It states that a building classified as F-3 shall Exclude
conform to Sentence 3.2.2.73 (2) and be sprinkled throughout, noncombustible construction
with fire-resistant floor assemblies, walls, columns and arches. The Powerhouse fits under
this classification, but is not protected by sprinklers throughout. This gap is closed because
of special considerations in the NFPA 101 code that address this issue that DNGS
complies with for this building.
D452 Spatial Separation and Six (6) gaps from a review of NBCC 2005, Gaps 01873 to 75 ADs. Gap 01876 to be closed.
[R-56] Exposed Building Face Gap 01873 against Clause 3.2.3.1 AD
NK38-REP-00770- - Sentence (1) lists the minimum limiting distances and area of unprotected openings of
0462037 R000 exposed building faces ...
- Sentence (2) requires that the area of the unprotected openings shall be the aggregate area
of unprotected openings expressed as a percentage of the exposed building face ...
- Sentence (3) requires that for the purpose of determining the type of construction and
cladding and the fire resistance of the exterior wall ...
- Sentence (4) requires that for the purpose of determining the actual percentage of
unprotected openings permitted in an exterior wall ...
The D2O/TRF building does exceed the maximum permitted openings of these requirements.
This gap is AD with no action required due to mitigating factors, the existing bldg construction,
and the bldg exposures provided relative to the D2O/TRF bldg. No significant impact on fire
and life safety. Bldg is constantly attended, low likelihood of fire and fast ERT response.
Gap 01874 against Clause 3.2.3.2 It lists the required maximum permitted areas of exposed AD
building faces. The percentage of unprotected openings for each building face of the D2O/
TRF building ranges from ~ 85-96%, which exceeds the 13-46% percentage of unprotected
openings permitted. Justification is same as for gap 01873.
Gap 01875 against Clause 3.2.3.7 It states the maximum permitted unprotected openings in AD
a building face ... The existing percentage of unprotected openings for each building face of
the D2O/TRF building ranges from ~ 85-96% and the percentage permitted is ranging from
13-46%. The existing percentage of unprotected openings and the limiting distances exceed
those permitted. Justification is same as for gap 01873.
Gap 01876 against Clause 3.2.3.8 It requires that foamed plastic insulation used in an
exterior wall of a building more than 3 storeys in height be protected by concrete or masonry A/R Exclude
or non-combustible material that complies with Section 3.2.3.8.(2), in addition to ...
Documents not found. A/R # 28155462-21.
Gap 01877 against Clause 3.2.3.13 Sentence (1) states if the plane of an exterior wall of an
exit enclosure forms an angle less than 135 with the plane of an exterior wall of the building, Exclude
and an opening in the wall of the exit could be exposed to fire from an opening in the wall of
the building, then the opening shall be protected ... Sentences (3) and (4) state except as
permitted by ... the exit opening shall be protected ...
The exit stairs on the south side of the RB do not comply with these requirements. The doors
have 1.5 h fire rating. Exit stairs are enclosed by fire separations and are separate fire
compartments. Requirement is satisfied, based on additional information in IRF.
Gap 01878 against Clause 3.2.3.14 Sentence (1) states that if an unprotected opening in an
Exclude
exterior wall of a fire compartment is exposed to an unprotected opening in the exterior wall of
another fire compartment, and the planes of the 2 walls are parallel or at an angle less than
Page 49 of 77
0235 AD AGGREG 0004 01

135 ... the unprotected openings shall be separated by a distance not less than ... If it is
within the distance, then it shall have a fire resistance rating not less than ... Sentence (3)
states the requirements in Sentence (1) do not apply if ...
The exit stairs on the south side of the RB do not comply with these requirements. The door
of stairs RX-ST3 and RX-ST4 are exposed by the doors from RX-146 and RX-147. The
doors in the stair and the exposing room are not fire rated. The exposing wall of rooms RX-
146 and RX-147 is concrete---sufficient to protect the stairs. No significant combustibles in
stairs. Complies with intent, based on additional information in IRF.
D453 Fire Department One (1) gap from NBCC 2005
[R-19] Notification Gap 01883 against Clause 3.2.4.7 It requires a fire alarm system and its waterflow-indicating AD
NK38-REP-00770- devices be designed to notify the fire department when an alarm is initiated. The intent is to Credit action
0462038 R000 limit the probability that emergency responders will not be promptly notified. The DM does not of U0 operator
indicate automatic relay of a signal to local fire department. Fire and emergency tones are
initiated by Operator action. This is a single-stage system as the ERT tones are sounded
upon receipt of an alarm or notification via phone. All alarms from local panels are received in
the CER and are monitored by the Unit 0 Operator. The fire location is announced and the
ERT is instructed to respond over the PA system. In addition, the Unit 0 Operator is required
to call the Clarington Emergency and Fire Services. The intent is met by prompt Operator
action. This gap is reclassified as an acceptable deviation. No action required.
D454 Fire Alarm Annunciator One (1) gap from NBCC 2005
[R-20] NK38-REP-00770- Gap 01884 against Clause 3.2.4.8 It requires an annunciator in close proximity to a building AD
0462040 R000 entrance that faces a street or an access route for fire department vehicles. The intent is to Credit action
limit the probability that emergency responders will be delayed in locating the annunciator and of U0 operator
the area of fire. The main Powerhouse annunciator is in the MCR, not as required by NBCC.
The Unit 0 Operator monitors the station at all times and reports any alarms to ERT and
Clarington, including the location of the incident. The intent is met by prompt Operator
action. This gap is reclassified as an acceptable deviation. No action required.
D455 Emergency Notification Three (3) gaps from NBCC 2005
[R-21] System Gap 01885 against Clause 3.2.4.9 It requires electrical supervision for a fire alarm system AD
NK38-REP-00770- and transmission of indication of a supervisory signal to the fire department. Open-circuit, Credits action
0462041 R000 short-circuit, ground faults and loss of data are signaled; however, voice system amplifier and of U0 operator
speakers are not supervised, so announcements may not reach all occupants, including local
ERT. Supervisory signals are not automatically relayed to the local fire department. They are
received at the main fire alarm control panel in the MCR. The Operator tests the PA system
speakers monthly and initiates repairs. Supervisory signals in MCR lead to Operator action to
determine the cause and initiate repairs. The intent is met. This gap is reclassified as an
acceptable deviation. No action required.
Gap 01888 against Clause 3.2.4.18 It requires audible signal devices that are audible AD
throughout the floor area. The sound pattern shall conform to the temporal pattern of ISO
8201. The sound pressure level shall not exceed 110 dBA. The sound pressure level shall not Credits U0
be less than 10 dBA above the ambient noise level and not less than 65 dBA. Visual signal operator and
devices shall supplement audible devices where required. maintenance
In DNGS: Emergency tone testing indicated numerous deficiencies relating to audibility of the
alarm signal. The audible signal does not meet ISO 8201. Emergency tone testing identified
locations where measurement exceeded 110 dBA. Many locations tested did not meet the
minimum audible requirement. There are noise areas of the Powerhouse where strobes have
not been provided. This gap is reclassified as an acceptable deviation. The intent is met
by the alternative measure of sounding emergency tones and voice announcements
over the PA system. No action required.
Gap 01889 against Clause 3.2.4.19 It requires visual signal devices be installed where
audible alarm is not effective. There are no visual signal devices. This gap is reclassified as AD
an acceptable deviation. The intent is met by the alternative measure of posting Credits action
warning signs and limiting access to high noise areas. No action required. to post signs,
Page 50 of 77
0235 AD AGGREG 0004 01

limit access
D456 Requirements of Two (2) gaps from NBCC 2005. No combustible loads; closed. Exclude D456
[R-22] Janitors Closets Gap 01886 against Clause 3.2.4.10 It requires fire detectors in storage rooms, service rooms, Exclude
NK38-REP-00770- etc. where sprinkler protection is not installed. The janitors rooms at DNGS do not have fire
0462042 R000 protection. They are small and do not contain significant combustible loads. Not
applicable because no combustible loads.
Gap 01911 against Clause 3.3.1.21 It requires fire separation for janitorial rooms. Not Exclude
provided in DNGS. These rooms are non-combustible spaces. Not applicable.
D457 Smoke Recirculation One (1) gap from NBCC 2005.
[R-23] NK38-REP-00770- Gap 01887 against Clause 3.2.4.12 It requires an air-handling system to prevent the AD
0462044 R000 circulation of smoke. The required prevention of smoke circulation between floors or fire
compartments in the Powerhouse is not satisfied, because fan shutdown is not provided in
some systems. Auto fan logic modification, if implemented, could result in decreased system
availability in response to FWLB/MSLB, due to the possibility of spurious smoke detector
signal shutting down fans credited for steam protection. These fans are credited to operate
following power restoration to pressurize and cool the associated steam protected rooms. If
the fans do not operate, excessive steam ingress and room overheat could occur. The
resultant harsh conditions could fail the critical equipment credited to function in the safety
analysis. Provision of fan shutdown would have a negative impact on nuclear safety.
This gap is reclassified as acceptable.
D458 Fire Fighter Access to Three (3) gaps from NBCC 2005. Gaps acceptable because the on-site ERT will respond All gaps credit
[R-24] Above and below grade quickly. Fire attack within the buildings is according to ERT pre-plans, which are based on ERT action
NK38-REP-00770- buildings as they exist and existing openings. Upgrading access for NBCC would be of
0462045 R000 little value.
Gap 01890 against Clause 3.2.5.1 It requires direct access for firefighting from outdoors to
every storey not sprinkled and floor level less than 25m above grade. The Powerhouse and AD
D2O-TRF building do not have windows or access panels to floors less than 25m above
grade.
Gap 01891 against NBCC Clause 3.2.5.2 It requires direct access from at least one street into AD
each basement of a building that is not sprinkled. The Powerhouse partially satisfies this
clause. The south side has stairwells connected to the exterior; however, the north side of the
basement does not have stairwells directly to the exterior. The basement areas of the Turbine
Building are accessible by open stairways; however its basements are sprinkled.
Gap 01892 against Clause 3.2.5.5 It requires access routes be located so that the principal AD
entrance and every access opening are not less than 3 m and not more than 15 m from the
closest portion of the route required for fire department use. While the access routes are
provided to each required building exterior face, the openings for fire department access are
not in accordance with the clauses.
D461 Means of Egress Five (5) gaps from NBCC 2005. Acceptable; exclude these gaps. Exclude D461
[R-57] NK38-REP-00770- Gap 01908 against Clause 3.3.1.5.(1) It requires a minimum of two egress doorways ... in the A/R Exclude
0462050 R000 room or suite .... The following rooms require two egress doorways: D-001, D-002, D-003, D-
025, R1-013/026, R4-014, S-141, S-510, SM-106, Tx-109 and Tx-111. Some rooms have
acceptable provisions; some require upgrades via A/R # 28156258-01.
Gap 01909 against Clause 3.3.1.6 It requires that if more than one egress doorway required,
the travel distance within the room or suite to the nearest doorway shall not exceed ... The Exclude
following rooms do not meet this requirement: SM-229, SM-301, VS-002, VS-003 and W-001.
The powerhouse and other building are special and unusual structures, which are permitted
to be protected via good fire protection engineering practice. NFPA 101 used in these cases
as it offers a more detailed analysis of fire and life safety compliance on the basis of specific
use. It permits travel distances up to 91 m. Alternate compliance.
Gap 01910 against Clause 3.3.1.11.(2) It requires that, except as permitted by Article A/R Exclude
3.3.1.12, a door that opens into a corridor or other facility providing access to exit room/suite
Page 51 of 77
0235 AD AGGREG 0004 01

that is used ... shall swing in the direction of travel of travel to the exit. The TRF building
should be classified as a high hazard occupancy. There are 3 doors that do not swing in the
direction of egress travel. The swing direction of two doors will be changed. A/R # 28156258-
02. The third door will not be changed, as it would obstruct the exit corridor.
Gap 01913 against Clause 3.4.2.1 It requires that, except as ..., every floor area shall be
served by at least two exits. There are floor areas in the powerhouse which do not have two Exclude
exits, such as Elev. 93.5 in the TB (Tx-109). Rooms are sprinklered and grating floor above,
so no smoke or heat accumulation, allowing adequate time for egress. Building complies
with the intent of the requirement, which is to enable workers to evacuate in a fire.
Gap 01914 against Clause 3.4.2.2 It requires that the space above a mezzanine shall be
served by means of egress leading to exits accessible at the mezzanine level on the same Exclude
basis as floor areas unless specific criteria are met. Egress from mezzanines is required to be
to be on the same basis as floor areas, but there are areas in the powerhouse that do not
comply, e.g., Rx-406, and Rx-407. These areas are for infrequent access to equipment for
inspection, testing and maintenance. Building complies with the intent of the requirement,
which is to enable workers to evacuate during a fire.
D462 Volatiles in Basements One (1) gap from NBCC 2005 Exclude D462
[R-25] NK38-REP-00770- Gap 01912 against Clause 3.3.5.3 It requires that a basement shall not be used for the Exclude
0462051 R000 storage, manufacture or handling of volatile solids, liquids or gases that generate explosive
air-vapour mixtures or for processes that involve explosive dusts. The TRF contains hydrogen
processes, and the floor of the hydrogen compressor is 4 m below grade. Other rooms that
are part of the tritium removal process are also below grade. Assessment determined that the
design and arrangement are satisfactory. The intent of the code to avoid explosions of
volatile gas has been met by alternate means.
D463 Exiting Requirements Three (3) gaps from NBCC 2005 Exclude D463
[R-26] NK38-REP-00770- Gap 01915 against Sentence 3.4.2.5 (1) It specifies maximum travel distances to an exit, Exclude
0462052 R000 where more than one exit is required from a floor area, Powerhouse areas are identified that
do not meet the 30 m limit for travel to an exit. The powerhouse and other building are
special and unusual structures, which are permitted to be protected via good fire protection
engineering practice. NFPA 101 used in these cases as it offers a more detailed analysis of
fire and life safety compliance on the basis of specific use. Areas were assessed according
to NFPA 101 and deemed compliant. Alternate compliance.
Gap 01916 against Sentence 3.4.3.2 (1) It specifies minimum aggregate required width of
exits serving floor areas. Powerhouse areas with deficient exit capacities are identified. The Exclude
areas were assessed according to NFPA 101 and deemed compliant. Alternate
compliance.
Gap 01918 against Sentence 3.4.4.4 (1) It requires a fire separation that separates an exit Exclude
from the remainder of the building to have no openings, except as allowed. Unprotected
openings in exit stair enclosures are identified and an exit corridor that has openings that are
not exit doorways is identified. The openings (penetrations) in stair enclosures were sealed.
Assessment of the design indicates it complies with the intent of this requirement.
D464 Signage Requirements Three (3) gaps, two from NBCC 2005 and one from NFCC 2005. Gaps to be closed. Exclude D464
[R-58] NK38-REP-00770- Gap 01919 against Clause 3.4.5.2 It requires a building of more than 2 storeys to have signs Gap 01919 to
0462053 R000 posted on an exit ramp or stairway that continues up or down past the lowest exit level to be closed
indicate that it does not lead to an exit. No signs posted in powerhouse on elevation 100 in
exit stair indicating that level is the level of exit discharge. Same in D2O bldg. Gap to be
closed by A/R # 28155459-10.
Gap 01922 against Clause 3.4.6.18 It requires numerals indicating assigned floor number Exclude
shall be mounted ... This sentence requires floor numbering within exit stair shafts. Floor
numbering is provided that conforms to contrast colour clause (d), but compliance to position
and size clauses (a), (b) and (c) varies by location. No visually impaired people are in the
buildings. Complies with intent, and compliance will improve when walls are painted.
Page 52 of 77
0235 AD AGGREG 0004 01

Gap 01941 against NFCC Clause 2.7.1.4 It requires signs of room/area occupant load ... A/R Exclude
Cafeteria in Unit 0 has no sign posted. A/R # 28155459-11.
D465 Elevator Requirements Two (2) gaps from NBCC 2005. All elevators are licensed by TSSA; appropriate inspection
[R-27] NK38-REP-00770- and testing occurs prior to approval. Maintenance instructions require design changes/mods
0462054 R000 to meet ASME A17.1-CSA-B44-10. Elevators in TRF-D2O building not installed because of
code requirement, so stretcher capability is not needed. ERT responds to medical
emergencies.
Gap 01923 against Clause 3.5.2.1 It requires compliance with local regulations/laws or CSA Exclude
B44. Design Manual references B44-1975; no confirmation that elevators meet B44-2000.
Elevators are inspected and licensed annually to current CSA code. Alternate compliance.
Gap 01926 against Clause 3.5.4.1 It requires elevators accommodate patient stretcher. TRF
annex and D2O building elevators are too small. Signage lacking on which elevators AD
accommodate stretchers (for responders not familiar with elevators). ERT is trained to know Credits ERT
which elevators cannot accommodate stretchers. ERT is trained in medical emergencies and
movement of people on stretchers.
D466 Elevator Hoistway and Two (2) gaps from review of NBCC 2005. Exclude D466
[R-59] Machine Room Gap 01924 against Clause 3.5.3.1.(1) It requires a vertical service space used as a elevator Exclude
Requirements hoistway be separated from all other portions of each storey by a fire separation having a fire
NK38-REP-00770- resistance rating conforming to ... Fire barrier drawings in FHA did not indicate that elevator
0462055 R000 shafts have fire resistance rating. The powerhouse is a special or unusual structure under
NBCC. The floor assemblies are very large in area, containing equipment openings and
unprotected steel supporting structures. The lack of fire separation between vertical service
spaces does not reduce level of fire performance. Openness between floor areas is
necessary. CCR, FSSA and FHA examined design basis fire impacts and demonstrated
that safety and structural objectives are met. Additional analysis in [R-95] Appendix A-13
provides further justification for this acceptance of the existing fire separation.
Gap 01925 against Clause 3.5.3.3 It requires a room containing elevator machinery be Exclude
separated from all other parts of the building by a fire separation ... Fire barrier drawings in
FHA indicate that elevator machine rooms have 1 h fire resistance rating instead of 2 h rating.
Additional analysis in [R-95] Appendix A-13 provides further justification for acceptance of the
existing fire separation.
D469 Inspection, Testing and Eight (8) gaps from a review of NFCC 2005. Gaps 01956, 61 and 62 to be closed. Others ok. Exclude D469
[R-60] Maintenance Gap 01942 against Clause 2.7.2.1 It requires all doors forming part of the means of egress Exclude
Requirements shall be tested at intervals not greater than one month to ensure they are operable. Other
NK38-REP-00770- requirements for revolving, sliding and e/m locks. Fire doors are tested monthly, but means of
0462058 R000 egress doors are not all captured by these inspections. Alternate compliance---Security
checks exterior doors daily; staff is required to repair failures.
Gap 01955 against Clause 4.5.10.5 It requires a visual inspection routine for detection of Exclude
abnormal conditions for piping systems for transfer of flammable or combustible liquids once
each shift. DMs address inspection requirements. Inspection report indicates the standby
generator and EPG systems are checked only nightly. Since SGs and EPG operate only
during abnormal conditions or testing, nightly checks provide adequate assurance.
OPG governance meets intent of the requirement for inspecting this piping.
Gap 01956 against Clause 4.5.10.6 It requires frequent inspections and tests of all safety A/R Exclude
shut-off valves and other safety devices for piping systems ... with particular attention to
normally open, fusible-link-operated valves, float valves and automatic controls. DMs state
testing of the system shall be performed to OH documents, but no documentation was found
detailing testing requirements for the general oil transfer system piping valves. Procedure to
be written for periodic inspection and testing of all valves at critical points in fuel systems and
other related fire safety devices to avoid delays in shutting off flow A/R # 28155459-16.
Gap 01960 against Clause 6.2.1.1 It requires portable extinguishers be inspected, tested and
maintained as per NFPA 10, which requires monthly inspection. They are inspected every 3 Exclude
months. CNSC granted approval for inspection every 3 months instead of monthly.
Page 53 of 77
0235 AD AGGREG 0004 01

Complies with alternate authority. Intent is met.
Gap 01961 against Clause 6.4.1.1 It requires water-based fire protection systems be
inspected, tested and maintained as per NFPA 25. Third party review had several findings on A/R Exclude
testing and no documents to confirm that actions were completed. Gap will be closed A/R #
28155459-17.
Gap 01962 against Clause 6.5.1.1 It requires emergency power systems be inspected,
tested and maintained as per CAN/CSA C282. Third party review indicates testing on the Exclude
battery banks, but does not confirm whether the SGs are adequately tested to C282. The SGs
are tested every 8 weeks, which does not meet C282. Additional analysis in [R-95] Appendix
B-5 states that CSA C282 clause 11.3 requires the standby generator to be tested annually to
a 2 hour full-load test. The standby generator are currently tested to bi-annually to a 24 hour
capacity test. However the standby generators are started and loaded as part of many other
SRSTs. As a result the number of effective starts and effective load durations per standby
generator is sufficient to satisfy the intent of this requirement. Complies.
Gap 01963 against Clause 6.5.1.5 It requires liquid fuel storage tanks be drained and refilled
with fresh fuel at intervals not greater than 12 months. No evidence to confirm compliance. Exclude
Fuel quality is assured by OPG specification for chemical testing. Intent of code to ensure
fuel is acceptable is met by alternate method.
Gap 01964 against Clause 6.5.1.6.(1) It requires self-contained emergency lighting unit
equipment be inspected at intervals not greater than one month to ensure that pilot lights are Exclude
functioning, terminal connections are clean, terminal clamps are tight, and the battery surface
clean and dry. After the test in Clause (2b), the charging conditions for voltage and current
and the recovery period shall be tested. Third party review noted deviations in inspection and
testing. Intent of code is met by an alternate method of testing lighting equipment,
which has been approved by CNSC.
D470 Hazardous Material One (1) gap from NFCC 2005. Propane tank use is limited to vehicles and temporary heaters. Exclude D470
[R-28] Requirements The tanks are stored in a dedicated building, which is not in the scope of the DNGS ISR.
NK38-REP-00770- Gap 01943 against Clause 3.1.1.4 It requires that storage and handling of liquefied petroleum Exclude
0462059 R000 gases conform to CSA-B149.1 and B149.2. Storage and handling procedure requires
compliance with both NFCC and NFPA; cannot confirm compliance with CSA-B149.1 and .2.
D471 Fuel Storage/Transfer One (1) gap from NFCC 2005. Exclude D471
[R-29] Room Ventilation Gap 01944 against Clause 4.1.7.3. (2) It requires air inlet and outlet vents be no higher than Exclude
Requirements 300 mm from the floor, where flammable vapour being removed is heavier than air. The EPG
NK38-REP-00770- fuel forwarding room has low level exhaust, but supply is from natural air vents in the ceiling.
0462060 R000 The design intent is met to provide a sweeping effect along the floor where heavier than air
flammable vapours can accumulate. Exhausting at low level satisfies the intent to prevent
hazardous accumulation of vapours.
D472 Oil Storage Tank and Eleven (11) gaps from review of NFCC 2005. Four gaps will be closed.
[R-61] Piping Requirements Gap 01945 against Clause 4.3.1.2 It requires atmospheric storage tanks be built in A/R Exclude
NK38-REP-00770- conformance with 15 clauses in API and ULC standards. Although the storage tanks were
0462061 R000 constructed in conformance with acceptable standards, the editions are older than those
referenced in NFCC 2005. No inspection reports found for EPG or Lube Oil storage tanks
indicating their compliance or suitability. The four SG tanks have had recent inspections with
repairs made as required; they are acceptable for continued use---AD. The EPG and Lube Oil
tanks are expected to be suitable, but will do complete assessment of tank conditions for
extended life of station. A/R # 28155462-18 (No documents found to indicate these tanks had
met their 10-year inspection.)
Gap 01946 against Clause 4.3.3.1 It requires storage tanks be on the ground or foundations,
supports or piling made of concrete, masonry or steel as per API 650 Appendix B and API Exclude
620 Appendices C and D. ... The standards have been revised. EPG tanks are supported by
saddles more than 300 mm high. The present design does not result in a significant reduction
in the intended level of safety. The supports are not combustible and will not contribute
to a fire under the tank. Each tank storage room and other features are well designed.
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0235 AD AGGREG 0004 01

The existing design meets the intent of the code.
Gap 01947 against Clause 4.3.4.1 It requires storage tanks be provided with normal and
emergency venting as per API 2000 or standards listed in NFCC Sentence 4.3.1.2.(1). The AD
standards have been revised. Additional analysis in [R-95] Appendix A-14 states that the
normal vent sizes for the SG and EPG fuel oil tanks and the lubricating oil tanks meet code
requirements. The EPG tanks do not have emergency vents, but this is an acceptable
deviation because it does not result in a significant reduction in the intended level of safety.
Gap 01948 against Clause 4.3.7.4 It requires no part of a secondary containment wall be Exclude
less than 1.5 m from a storage tank shell. To waive the distance requirement, the storage
tank must have a capacity of not more than 50,000 L and be protected by posts or guardrails
when exposed to collision damage. The EPG tanks are 1.4 m from their containment wall,
and the capacity is 25,000 Imp gal (113,450 L). The 10 cm difference is not considered to
have significant impact in either being able to see a spill under the tank or in affecting
firefighting efforts. There is a CO2 suppression system in each fuel tank room that would
discharge, so responders do not enter in a fire. Design meets code intent.
Gap 01949 against Clause 4.3.12.8 It requires normal and emergency vents for storage
tanks in buildings. Weak roof-to-side shell seams, designed to rupture before allowable AD
design stress is reached, is not permitted as a means of emergency venting. The EPG tanks
have only a normal vent; no documents regarding emergency venting. Evaluate normal
venting and ensure compliance with current standards. Regarding EPG tank emergency
venting, the present arrangement does not result in a significant reduction in the intended
level of safety. See additional analysis in [R-95] Appendix A-14.
Gap 01950 against Clause 4.3.13.4 It requires that hose stations be provided for storage
AD
tank rooms in buildings not required to be equipped with a standpipe and hose system.
Credit ERT
Provide portable extinguishers for Class B fires. There are no hose stations near fuel storage
rooms. The only building with indoor storage tanks is the EPG fuel mgmt building. It has
sumps with level alarms in the fuel storage and pump rooms. The ERT has access to hose
stations in range of the building and to foam, which will be the most likely suppression agent
to fight a diesel fire.
Gap 01953 against Clause 4.5.6.7 It requires piping for flammable or combustible liquids be
located above ground where the piping enters a building and be fitted with inside and outside AD
shut-off valves and sleeves in wall penetrations (for pipe movement). The main fuel line from
the storage tanks enters the SG pump building below ground. The EPG fuel management
building has tanks inside, but no documents found to show how lines leave. SG flow drawing
shows valves at the SG tanks and in the SG pumphouse to shut off flow in an emergency.
The piping is deep under the building and encased in concrete protection; further settlement
will not occur. EPG flow drawing shows valves at both ends to isolate the line. The piping line
exits the EPG fuel building below ground and has a swing joint to accommodate movement.
The line enters the EPS generator building sidewall through a 2.1 m long pipe sleeve that
protects the pipe and accommodates movement. AD.
Gap 01954 against Clause 4.5.7.1 It requires valves in piping systems for flammable or
Exclude
combustible liquids be designed to ... ULC/ORD-C842 ... CAN/ULC-S620 ... ULC-S651. The
OPG design and construction requirements manual refers to ANSI/ASME code for valves, not
to the ULC standards. The intent of this NFCC clause is to limit the probability of valve failure.
For oil service, the OPG manual requires valves to be class 600 or class 1500, and for all to
meet system requirements, i.e., valves on the fuel systems are designed for combustible
liquid service. This alternate compliance meets the intent.
Gap 01957 against Clause 4.11.3.7 It requires before unloading a tank vehicle, .... If the
vents of the receiving or delivery tank are blocked, the transfer must be stopped. The tank AD
vehicle must not be parked .... The OMs do not discuss checking the vents. The SG tank vent
is on the roof; inspecting it would be a hazard. These tanks have both normal and emergency
vents. If the main vent is plugged, the emergency vent would open and prevent tank failure or
overflow. The EPG tanks are located in a below ground storage room, and the vent is located
on the building roof. There is no emergency vent. If a tank burst and the fuel ignited, the fuel
spill would be contained by the rooms secondary containment walls. The fire would be
Page 55 of 77
0235 AD AGGREG 0004 01

contained. Not inspecting the receiving tanks vent during filling is an AD.
Gap 02084 against Clause 4.3.12.4 It requires storage tanks ... be located in dedicated
storage rooms conforming to Subsection 4.3.13 and located in conformance with Table Exclude
4.3.12.4 except ... There are two tanks of 113,000 L each in the storage room of the Fuel
Management Building, so the 200,000 L limit for Class liquids in a protected storage room of
Table 4.3.12.4 is exceeded. The intent is to limit release of vapours in low areas of the
building and limit probability that a tank fire will spread outside of the storage room. Clause is
intended for rooms located inside other occupancies. The EPG Fuel Management Building is
a dedicated to storage and management of fuel. The rooms are low and have containment for
all of the liquid stored. The walls are rated for more than 2 h, and there is an on-site ERT. The
excess amount of fuel will not result in a reduction of safety. Design meets intent to limit
release of vapours and limit spread of tank fire.
Gap 02085 against Clause 4.5.7.2 It requires shut-off valves be provided in all ... piping and
pumping systems. Where practicable, these valves shall be outdoors or be immediately
accessible from outdoors. Steel shut-off valves shall be provided at connections to all Exclude
aboveground storage tanks, on supply piping ... There are no shut-off valves on the fill lines
adjacent to the SG tanks. The intent is to be able to shut valves in an emergency. This line at
the top of the tank is normally unpressurized. Action to evaluation the possibility of fuel being
siphoned out of the tank in the event of a line rupture. Additional analysis in [R-95] Appendix
A-14 indicates a siphon breaker at the top of the fill line. The design meets the code.
D473 Documentation Sixteen (16) gaps from review of NFPA 20 2007 and NFPA 24 2007. Gaps 00828 and 02015 Exclude D473
[R-62] NK38-REP-00770- will be closed. The other gaps can be excluded; no action needed.
0462062 R000 Gap 01965 against NFPA 20 Clause 5.5.2 It requires fire pump purchaser to provide certified Exclude
shop test curves showing head capacity, brake horsepower to AHJ. No documents that test
curves given to AHJ. Copies of the certified pump curves were located, are acceptable, and
were forwarded to the AHJ (with the ISR gap analysis). Complies.
Gap 01966 against Clause 5.6.5.2 It requires head available from a water supply be figured Exclude
on the basis of a flow of 150% of rated capacity of fire pump, and be indicated by a flow test.
Mod DR references flow and pressure test report to investigate availability of 100 psi and 500
USGPM; it did not extend to 150% of capacity (750 USGPM). Commissioning tests were
conducted, which always require flow test to 150% of rated pump capacity. Complies.
Gap 01967 against Clause 5.11.1.1 It requires each pump have an automatic relief valve that
is listed for fire pump service installed and set below the shutoff pressure at minimum suction Exclude
pressure. Pressure boundary relief valves located downstream of the fire pump skid, on the
discharge piping are not listed for fire pump service. Use of un-listed RVs is now documented
and dispositioned. Installation of the unlisted devices is alternate compliance.
Gap 01969 against Clause 5.12.7 It requires couplings and flexible connecting shafts be
installed with a coupling guard as per ANSI B15.1 Section 8. No document that this standard Exclude
is equivalent to, or that machine guards fitted to the pumps comply with ANSI B15.1 Section
8. Design complies with CSA Z432, which is same scope as ANSI B15.1. Equivalent
compliance.
Gap 01972 against Clause 5.22 It requires pump shaft rotation be determined and correctly
specified when ordering pumps and equipment involving that rotation. No documents that Exclude
pump shaft rotation was investigated or specified when ordering fire pumps. Commissioning
results confirm correct rotation. Complies with intent.
Gap 01980 against Clause 9.3.8.1 It requires that listed conduit hubs be used to terminate
raceway (conduit) to the fire pump controller. No document to demonstrate compliance. Site
inspection confirms that robust, tightly sealed conduit hubs were used. Design complies Exclude
with better Canadian Electrical Code and NEMA 2 enclosure. Equivalent compliance.
Gap 1981 against Clause 9.3.8.2 It requires that the type rating of the conduit hub(s) be at
least equal to that of the fire pump controller. No documents. Site inspection confirmed Exclude
robust tightly sealed conduit hubs were used, which satisfy Canadian Electrical Code
and NEMA 2 enclosure. Equivalent compliance.
Page 56 of 77
0235 AD AGGREG 0004 01

Gap 01982 against Clause 9.3.8.3 It requires the manufacturers installation instructions be Exclude
followed to terminate raceways for the fire pump controller. No documents show compliance.
Manufacturers manual has no instructions. Site inspection confirmed compliance with the
Canadian Electrical Code.
Gap 01983 against Clause 9.3.8.4 It requires any alterations to the fire pump controller be Exclude
approved by the AHJ. No documents to demonstrate compliance for the mod to retrofit an
external printer. External printer mounted to prevent exposure to 600 V hazard. Printer was
supplied by and its installation coordinated with manufacturer of the controller. Alteration
complies with code intent.
Gap 00828 against NFPA 24 Clause 4.1.3 It requires working plans be drawn on sheets of A/R Exclude
uniform size, with a plan of each floor and include items that pertain to the design of the
system: ... (9)(b) whether hose houses and equipment are to be provided, and by whom. No
yard hose houses were observed during site walkdown. Some drawings show HY-10 deleted;
others still show it. Documents for PCP 84900 could not be located. Revise non-conforming
drawing A/R # 28155463-05.
Gap 02015 against Clause 8.1.1 It requires a supply of hose and equipment be provided A/R Exclude
where hydrants are intended for use. DM indicates hose houses for fire hydrants are located
~ 270 m (900 ft) apart at every third hydrant. However, no yard hose houses were observed
during a site walkdown. Same document problem as Gap 00828. Revise non-conforming DM
and drawing to delete hose houses A/R # 28155463-06.
Gap 02016 against Clause 8.1.1.2 It requires the AHJ be consulted regarding quantity and
A/R Exclude
type of hose. No documentation found on AHJ acceptance of all hose houses being removed.
Same document problem as Gap 00828. Revise non-conforming DM and drawing to delete
hose houses A/R # 28155463-06. The existing configuration has been accepted.
Gap 02033 against Clause 10.10.1 It requires (1) notifying AHJ and owners representative of
Exclude
the time and date testing is to be performed; (3) completing and signing contractors material
and test certificates. No documents regarding notification of original installation, testing and
certificates. FP water system was turned over in an operational state by Construction. Since
commissioning, system has been continuously inspected, tested and maintained. Not
applicable.
Gap 02034 against Clause 10.10.2.1.1 It requires that underground piping be flushed before Exclude
connection is made to downstream FP piping. No documents on original flushing. System has
been flushed as per procedures since commissioning. Intent has been met.
Gap 02035 against Clause 10.10.2.1.2 It requires the flushing be continued for sufficient time Exclude
for thorough cleaning. No documents. As in Gap 02034, the intent has been met.
Gap 02086 against Clause 10.10.2.1.3 It requires minimum rate of flow. No documents on Exclude
original flushing. As in gaps 02034 and 02035, the intent has been met.
D474 Mains Supplying Three (3) gaps from NFPA 24 2007. NFPA 24-1981 illustrated wall hydrants with minimum 4 Exclude D474
[R-30] Hydrants inch supply. Code changed due to concern that pipes smaller than 6 inch do not permit full
NK38-REP-00770- flow capability for hydrant. This applies to long runs of underground piping, not to short runs
0462063 R000 of overhead pipe to wall hydrants where there is no significant difference in pressure for 500
US gpm flow. (ERT can boost line pressure if needed by adjusting pump control of fire truck.)
Gap 01999 against Clause 5.2.1 It requires pipe not smaller than 6 inch not be installed as a Exclude
private service main to hydrants. Wall hydrants are supplied with 4 inch mains. All gaps, not
Gap 02011 against Clause 7.1.1 It requires hydrants not have less than 6 inch connections to applicable for
the mains. Except for 2 yard hydrants, all are wall hydrants with 4 inch connections from the short runs to
main lines. Documents approving this configuration not located. wall hydrants
Gap 02088 against Clause 13.1 It requires pipe not smaller than 6 inch not be installed as a
private service main to hydrants. Wall hydrants are supplied with 4 inch mains.
D475 Valves Controlling Ten (10) gaps Two are from review of NBCC 2005; one from NFPA 20 2007, and seven from
[R-63] Water Supplies NFPA 24 2007. Gaps 01897 and 01898 addressed by alternate action. Five gaps closed or to
NK38-REP-00770- be closed. Three gaps credit ERT action.
Page 57 of 77
0235 AD AGGREG 0004 01

0462064 R000 Gap 01897 against NBCC Clause 3.2.5.12 If a fire alarm system in a building is required to AD
have an annunciator, all valves in a standpipe system shall have an electrically supervised
switch for transmitting a trouble signal to the annunciator in the event of movement of the
valve handle (prevent wrong position to go unnoticed). Not all control valves are electrically
supervised. NFPA 14 permits supervision by locking or sealing valves with weekly recorded
inspection as per NFPA 25. See OPG procedure on control of position-assured components.
Employees are trained to operate only when authorized. Alternate action meets intent.
Gap 01898 against Clause 3.2.5.13 If a water supply serves both a sprinkler system and a
system serving other equipment, control valves shall be provided so that either system can be AD
shut off independently. In D2O mgmt bldg, the sprinkler protecting room D-107 is fed from the
standpipe system, so the standpipe system cannot be isolated without shutting off supply to
the sprinkler. The sprinkler for TRF room TR-103 is also fed from the standpipe system. The
same is true for the sprinkler protecting Unit 1/2 Zone 2 Coffee Shop and the CSA Waste
Handling area. Intent is to prevent sprinkler being shut off when maintaining other systems.
Sprinklers are more likely to require maintenance. Each sprinkler affected protects no more
than a few rooms, and compensatory measures are put in place when standpipe system is
isolated. Alternative action meets intent.
Gap 01971 against NFPA 20 Clause 5.19.3.1.1 It requires that hose valves be listed. Valves A/R Exclude
in DCP 80362 are not listed and not rated for the new design pressure. No documents correct
this situation. There are five hose valves on each standpipe, downstream of the fire booster
pumps---25 valves in total will be replaced by listed valves A/R # 28155463-07.
Gap 02010 against NFPA 24 Clause 6.7 It requires check valves be installed in a vertical and
A/R Exclude
horizontal position in accordance with their listing. Pressure regulating valves 0-67810-PRV3,
PRV13, PRV4 and PRV 14 which serve as non-return valves (check valves) were installed
horizontally. The check valve on Elevation 107.500 is in neither a horizontal nor a vertical
orientation, but angled upward. These positions meet the intent. However, the check valve at
107.500 did not indicate a listing (UL, ULC or cUL) on the label. Check valve will be removed
and the piping capped off; the cross-connection serves no purpose A/R # 28155463-08.
Gap 02087 against Clause 10.10.2.4.4 Where fire pumps are available, the operating tests A/R Exclude
shall be completed with the pumps. Documents on the original installations acceptance
testing and pump operation not found. The operability of all of the control valves on the fire
service mains will be tested as per NFPA 25 with the pumps A/R # 28155462-26.
Gap 02004 against Clause 6.1.5 It states that non-indicating valves, such as underground
gate valve with approve roadway box, complete with T-wrench, and accepted by the AHJ, AD
shall be permitted. The two yard hydrants HY22 and HY23 are provided with underground ERT action is
non-indicating gate valves in road boxes. No documents that AHJ accepted this configuration. credited
ERT is aware of the locations of the valves and road boxes and are prepared to operate
them. A work authorization is required to close these valves. AD.
Gap 02007 against Clause 6.2.10 It requires all control valves be located where readily
accessible and be free of obstructions. Many valves to isolate portions of the fire service Exclude
mains are at ceiling levels---not readily accessible. The word readily is unenforceable and
has been deleted in latest edition of the standard. Complies with revised code. .
Gap 02006 against Clause 6.2.5 It requires that where more than one water supply exists, a
check valve be installed in each connection and listed indicating valves or post indicator A/R Exclude
valves be installed on both sides of all check valves. Only one control valve in the lines from
ESW and no control valves are in the vicinity of check valve on Elevation 107.500. In ESW
pumphouse, the supply piping has 0-72800-V17 and V18, which fulfill the requirement for
valves upstream. There are valves on both sides of check valves. Remove cross connection
and check valve at Elev. 107.500, and capped off. See gap 02010. A/R # 28155463-09.
Gap 02008 against Clause 6.3.1 It requires every connection from the fire service main to a AD
building be provided with a listed post indicator valve, located to control all sources of water
supply. Drawings show when connections were made from the fire service mains in the Credit ERT
powerhouse to other buildings, the isolating control valves of the outside screw and yoke
(OS&Y) type gate valve were located within the powerhouse. No post indicator valves (PIV)
identified. PIV provides outside control of the water supply by the FD, which is not needed for
Page 58 of 77
0235 AD AGGREG 0004 01

DNGS because the municipal FD does not normally respond to fire. The ERT is aware of the
location of the valves and has complete access to all areas, so they can operate them as
needed.
Gap 02009 against Clause 6.3.2 It requires every connection from the fire service main to a
building be provided with a listed post indicator valve located to control all sources of water AD
supply. The AHJ is permitted to waive the requirement for the post indicator valves where the Credit ERT
provisions of Section 6.1 and 6.4 are met. Drawings indicate, when connections were made
from fire service mains in the powerhouse to other buildings, the isolating control valves of the
OS&Y gate valve type were located within the powerhouse. No post indicator valves were
identified and no documents found that AHJ accepted this configuration. The ERT is aware of
the location of the valves and has complete access to all areas, so they can operate them as
needed.
D476 Underground Pipe Sixteen (16) gaps from review of NFPA 24 2007. Five gaps, 02017 to 02021, will be resolved.
[R-64] NK38-REP-00770- Gap 02022 is not applicable, and ten gaps, 02023 to 02032, are no action ADs.
0462065 R000 Gap 02017 against Clause 10.1.1 It requires piping be listed for fire protection service and A/R Exclude
comply with the standards in Table 10.1.1. The buried piping between the Water Treatment
Plant and the pumphouses is Class A carbon steel pipe. Class A CS pipe is not listed for
underground service. OPG will inspect and conduct a study to determine the state of the
buried steel pipe (interior and exterior) to determine if it is still suitable for life extension.
Replace with listed pipe, if necessary. Past experience indicate there is a high potential for
failure with buried steel pipe. A/R # 28155462-07.
Gap 02018 against Clause 10.1.2 It requires steel piping not be used for general A/R Exclude
underground service unless specifically listed for such service. The buried piping between the
WTP and pumphouses is Class A CS, which is not listed for underground fire service. Action
same as Gap 02017. A/R # 28155462-07.
Gap 02019 against Clause 10.1.6.1 It requires that unless Clause 10.1.6.2 is met, all ferrous A/R Exclude
metal pipe be lined as per standards in Table 10.1.1. The buried CS piping between the WTP
and pumphouses is not lined. Action same as Gap 02017. A/R # 28155462-07.
Gap 02020 against Clause 10.2.4 It requires buried joints be approved. The buried CS piping A/R Exclude
from the WTP is not listed, so the joints are not approved. Action same as Gap 02017. A/R #
28155462-07.
Gap 02021 against Clause 10.2.5 It requires buried fittings be of an approved type with joints
A/R Exclude
and pressure class ratings compatible with the pipe used. As per Clauses 10.1.1 and 10.1.2
above, Class A CS pipe is not meant to be buried, so its associated fitting are not either.
Action same as Gap 02017. A/R # 28155462-07.
Gap 02022 against Clause 10.6.5 It requires where a riser is located close to building
foundations, underground fittings of proper design and type be used to avoid locating pipe Exclude
joints in or under the foundations. No documents to confirm absence of pipe joints under the
foundations. Intent is to prevent damage to fittings and joints from settling of foundations.
DNGS in place for 30 years, so any settling has already occurred. Not applicable now.
Gap 02023 against Clause 10.8.3.1.1.1 It requires clamps to have following dimensions ...
Could not determine and no documents found to confirm the correct clamp sizes, strap sizes, Gaps 02023
bolt sizes, washer sizes, etc. were installed on the associated 4, 6, 8 and 10 underground to 02032 are
main restraint systems. Intent is to ensure the restraint joint systems are designed and all ADs
installed to resist the thrusts imposed throughout plant life. They cannot be examined, so
there is no sure way to confirm that all bolts, clamps, etc. were sized and installed correctly.
OPG specifications were in place, giving confidence of proper construction. AD.
Gap 02024 against Clause 10.8.3.1.1.2 It requires diameter of a bolt hole on the clamps be
1/16 (1.6 mm) larger than the bolt. Could not determine and no documents found. Same as
Gap 02023; no action. AD
Gap 02025 against Clause 10.8.3.1.3 It requires clamp bolts have the following diameters ...
Could not determine and no documents found. Same as Gap 02023; no action. AD
Gap 02026 against Clause 10.8.3.1.4.2 It requires clamp cast-iron washers have dimensions
Page 59 of 77
0235 AD AGGREG 0004 01

... Could not determine and no documents found. Same as Gap 02023; no action. AD
Gap 02027 against Clause 10.8.3.1.4.3 It requires clamp steel washers have dimensions ...
Could not determine and no documents. Same as Gap 02023; no action. AD
Gap 02028 against Clause 10.8.3.2.1 It requires restraint straps for tees have dimensions ...
Could not determine and no documents. Same as Gap 02023; no action. AD
Gap 02029 against Clause 10. 8.3.2.2 It requires diameter of rod holes of restraint straps for
tees be 1/16 larger than that of rods. Could not determine and no documents. Same as Gap
02023; no action. AD
Gap 02030 against Clause 10.8..3.2.3 It requires Figure 10.8.3.2.3 and Table 10.8.3.2.3 be
used in sizing restraint straps for both mechanical and push-on joint tee fittings. Could not
determine and no documents. Same as Gap 02023; no action. AD
Gap 02031 against Clause 10.8.3.4 It requires clamps, rods, rod couplings or turnbuckles,
bolts, etc. be of a material that has physical and chemical characteristics that indicate its
deterioration under stress can be predicted reliably. Could not determine and no documents.
Same as Gap 02023; no action. AD
Gap 02032 against Clause 10.8.3.5 It requires that after installation, rods, nuts, bolts, and
other restraining devices be cleaned and thoroughly coated with tar or other acceptable
corrosion-retarding material. Could not determine and no documents. Same as Gap 02023;
no action. AD
D477 Size of Bypass Two (2) gaps from review of NFPA 20 2007. Exclude D477
[R-65] NK38-REP-00770- Gap 01973 against Clause 5.28.3 Regarding the booster fire pump, it requires packaged and Exclude
0462066 R000 prefabricated skid unit(s) meet all requirements in Sections 5.12 to 5.15. There are three gaps
from these four sections. Two are tracked in D429 (all gaps to be closed) and in D473, which
has been excluded (gaps excluded or to be closed). The third is gap 01970, below, which will
be closed. Therefore, this gap will be closed.
Gap 01970 against Clause 5.14.4.2 It requires the size of the bypass of the pump be at least Exclude
as large as the pipe size required for the discharge pipe, as per Section 5.25. The bypass is
4 whereas Table 5.25 requires the discharge pipe be 5 minimum. Perform hydraulic analysis
to demonstrate that 4 pipe is acceptable. Additional analysis in [R-95] Appendix A-14 states
that the bypass was provided to the existing 4 standpipe system piping. The benefit gained
from modifying the bypass does not justify the cost. There is only a 3.6 psi difference. For a
60 to 80 psi supply pressure, this difference is not significant.
D478 Compliance with NFPA One (1) gap from review of NFPA 20 2007. The codes referenced outweigh/overrule NFPA Exclude D478
[R-31] 70 for Booster Pumps requirements.
NK38-REP-00770- Gap 01974 against Clause 9.1.3 It requires electrical equipment and installation comply with Exclude
0462067 R000 NFPA 70, Article 695 and others. Documentation references Ontario and Canadian electrical
codes and OPG standards and procedures, but not NFPA 70. Alternate compliance.
D479 Fire Pump Four (4) gaps from review of NFPA 20 2007 regarding fire protection booster pumps. Two
[R-66] Disconnecting Means gaps 01976 and 1978 to be closed. Intent of gaps 01975 and 1977 achieved alternate way.
NK38-REP-00770- Gap 01975 against Clause 9.2.3 It requires fire pump installations have no more than one AD
0462068 R000 (power) disconnecting means and associated overcurrent protection device installed in the
power supply to the fire pump controller. It permits one upstream disconnect (in MCC) for OPG
maintenance. 1) Drawing shows additional disconnects installed between the manual transfer governance
switch and the controller for each pump. 2) The manual transfer switches have a disconnect
feature (Off position) incorporated into them between the Odd and Even positions. DCP
states the additional disconnects are a safety measure because the power supply voltage
could not be completely isolated from the controllers by the controller disconnect switch. OPG
requires complete separation between Odd and Even power supplies. All disconnecting
means are near the pumps. The intent is achieved by OPG governance.
Gap 01976 against Clause 9.2.3.1 It requires that where disconnecting means are installed,
the disconnecting means be lockable in the closed position and have signage indicating their A/R Exclude
function. While switches are lockable type, they were not being locked during inspection and
Page 60 of 77
0235 AD AGGREG 0004 01

are not marked as Fire Pump Disconnecting Means. OPG will seal or lock disconnects and
transfer switches in the closed position and have signage attached A/R # 28155459-20.
Gap 01977 against Clause 9.2.3.2 It requires that where the disconnecting means are
installed, a placard shall be placed adjacent to the fire pump controller stating the location of
this disconnect means and the location of the key to unlock the disconnect. Signage not Exclude
observed. Complies because controllers, disconnect switches and transfer switches are close
together. Refer to the resolutions for gaps 01976 and 1978.
Gap 01978 against Clause 9.2.3.3 It requires that where the disconnecting means are
installed, the disconnect shall be supervised in the closed position by specific means, A/R Exclude
including locking or sealing them in the closed position, electronic supervision from a central
station, and audible alarms. No electrical supervisory devices, seals or locks were observed
on the disconnects at the time of inspection. Refer to gap 01976 A/R # 28155459-20.
D480 Fire Pump Overcurrent Three (3) gaps from NFPA 20 2007. The overcurrent protection in the controller will trip before Exclude D480
[R-32] Protection the 80 A fuse will blow, so intent is met. SCR review indicates no nuisance tripping problems, (also D517
NK38-REP-00770- so the design complies. D480 is similar to D517. gap 02148)
0462069 R000 Gap 01979 against Clause 9.2.3.4 It requires that overcurrent protection devices carry Exclude
indefinitely the sum of the locked-rotor current of the fire pump motor(s) and the pressure
maintenance pump motor(s) and the full-load current of the fire pump accessory equipment.
The booster pump motor has 80 A fuse; however, the locked-rotor current is 292 A. The intent
of this requirement is not to blow the fuse when the pump is needed to extinguish a fire.
Replacing the fuse is time consuming. The intent is met because the overcurrent protection in
the controller is designed to trip before the fuse, and can be reset quickly. Intent is met.
Gap 01984 against Clause 9.5.1.7 It requires electric motor-induced transients be coordinated Exclude
to prevent nuisance tripping of motor protective devices. Compliance documents not found.
The controller overcurrent protection is designed to trip before the fuse blows. Intent is met.
Gap 01994 against Clause 14.2.8.8 It requires selection, size and settings of all overcurrent
protective devices, including fire pump controller circuit breaker, be according to the standard. Exclude
The booster pump motor has 80 A fuse; however, the locked rotor current is 292 A. As per the
resolutions of gaps 01979 and 01984, the intent is met.
D481 Manual Transfer Switch Four (4) gaps from NFPA 20 2007. These transfer switches are manual and cannot be UL Exclude D481
[R-33] NK38-REP-00770- listed for fire protection. NFPA requires fire transfer switches to be automatic because it All gaps meet
0462070 R000 considers power supplies to be unreliable. Pumps must continue to run despite power intent, comply
interruptions or need for human action. In DNGS, automatic transfer switches are prohibited with OPG and
to preserve the physical separation between ODD and EVEN power. Class IV power is quite regulatory
reliable, but dual power is provided to comply with regulatory requirement for redundant fire requirements
pump installations. NFPA reliability requirement is achieved in the design without using
automatic power transfer.
Gap 01985 against Clause 10.1.2.1 It requires all controllers and transfer switches be listed
for electric motor-driven fire pumps. The transfer switches for fire pump service are not listed. Exclude
The intent of the code is achieved using controllers and transfer switches that are not listed
for fire pumps service.
Gap 01990 against Clause 10.8.1.1 It requires compliance of power transfer switches with
code relating to use, location and construction. No compliance with Section 10.1.2.1 and 10.8. Exclude
The power transfer switches must comply with OPG and nuclear regulatory requirements.
Gap 01991 against Clause 10.8.1.2 It requires manual transfer switches not be used between Exclude
the normal supply and the alternate supply to pump controller. Transfer switches associated
with the booster pump controllers are manual, as required by OPG and the nuclear regulator.
Gap 01992 against Clause 10.8.1.3 It requires that the power transfer switch be specifically
listed for fire pump service. No evidence of any listing label for fire pump service. The intent of Exclude
the code is achieved using controllers and transfer switches that are not listed for fire pumps.
D482 Monitoring of Fire Pump Eight (8) gaps from review of NFPA 20 2007 regarding fire protection booster pumps. Gaps Exclude D482
[R-67] Alternate Power Source 01986, 01987, 01988, 01995, 01996 and 01997 to be closed. Remaining 2 gaps meet intent.
Page 61 of 77
0235 AD AGGREG 0004 01

NK38-REP-00770- Gap 01986 against Clause 10.4.6.2.2 It states when power is from multiple power sources, A/R Exclude
0462071 R000 monitoring of each for phase reversal is permitted at any point electrically upstream of the line
terminals of the contactor only when all sources are monitored. No evidence that phase
reversal is being monitored. Revise/update the fire pump inspection procedures to switch the
transfer switch to its alternate position during alternate monthly tests A/R # 28155459-05.
Gap 01987 against Clause 10.4.7.2.2.3 It requires that when power is from multiple sources, A/R Exclude
monitoring of each for phase loss be permitted at any point electrically upstream of the line
terminals of the contactor, provided all sources are monitored. The power to the monitoring
loop is drawn from only two of the three phases with no evidence that a signal would be
initiated on loss of control power. No documents that phase loss signal is monitored for each
of the feeds. It is unclear whether the existing phase loss circuits in the MCCs are fail-safe.
Review these circuits and confirm that the existing monitoring provisions meet this
requirement A/R # 28155462-10.
Gap 01988 against Clause 10.4.7.2.3 It requires the fire pump alarm circuit be energized by
a separate reliable, supervised power source or from the pump motor power, reduced to not A/R Exclude
more than 125 V. The fire pump alarm shall actuate whenever three-phase power at the line
terminals of the motor contactor is reversed. No evidence that phase reversal is being
monitored. Revise/update the fire pump inspection procedures to switch the transfer switch to
its alternate position during alternate monthly tests A/R # 28155459-06.
Gap 01989 against Clause 10.4.7.2.4 It requires that when two sources of power are
supplied to a controller to meet the requirements of 9.3.2, this signal shall indicate whenever Exclude
the alternate source is the source supplying power to the controller. This signal circuit shall be
energized by a separate, reliable, supervised power source, reduced to not more than 125 V.
The transfer switches are not fitted with the required contacts. OPG considers Class IV power
more reliable than utility power, so either of the primary power sources alone meets 9.3.2.
The OPG design provides indication of which power bus is supplying power to the
controller; the design meets the intent. The specific code requirement is not applicable.
Gap 01993 against Clause 10.8.3.14 It requires auxiliary open or closed contacts
mechanically operated by the transfer switch mechanism be provided for remote indication as Exclude
per 10.4.8. No evidence that phase reversal is being monitored. OPG considers both of the
feeds to be reliable supplies, so the monitoring discussed in gaps 01986 and 01987 ensure
that power faults to all fire pump feeds are adequately monitored. Intent is met by the
reliability, testing and monitoring of the services supplies.
Gap 01995 against Clause 14.2.9.2 It requires that transfer from normal to alternate power
source and retransfer from alternate to normal source not cause opening of overcurrent A/R Exclude
protection devices in either line. No documents that manual transfer-switch testing conducted.
Testing was done using ODD power supply. Ideally, both supplies should be available.
However, if due to maintenance only one is available, the test can continue with one power
supply. The procedures do not record which power supplies are actually selected. OPG will
revise procedure for annual testing to keep record of transfer of power A/R # 28155459-07.
Gap 01996 against Clause 14.2.9.3 It requires that at least half of the manual and automatic
A/R Exclude
operations of 14.2.8.2 be performed with the pump connected to the alternate source. No
documents that manual transfer switch testing was conducted. Testing was done with ODD
supply. Ideally, both supplies should be available. However, if due to maintenance only one is
available, the test can continue with one power supply. The procedures do not record which
power supplies are actually selected. Same action as gap 01995 A/R # 28155459-07.
Gap 01997 against Clause 14.2.12 It requires that the fire pump or foam concentrate pump
be in operation for not less than 1 hour total time during all of the acceptance tests. No A/R Exclude
evidence that the pumps were operated for a minimum of one hour. OPG to revise procedure
for annual pump testing to operate for > 1 hour and record duration A/R # 28155459-08.
D492 Stair Requirements One (1) gap from NBCC 2005. Replacing the stairs to meet 2005 code is not practicable. Exclude D492
[R-34] NK38-REP-00770- Plant staff is accustomed to current stairs, which are not an obstruction to evacuation.
0462086 R000 Gap 01920 against Clause 3.4.6.7 It specifies dimensions requirements for step run, rise and Exclude
leading edge radius or bevel. Current requirements differ slightly from NBCC 1980. The plant
Page 62 of 77
0235 AD AGGREG 0004 01

employees have adapted to the existing stairs, which meet the intent.
D506 Control of the Fire One gap from a review of CAN/CSA N293-2012.
[R-68] Alarm System Gap 02134 against Clause 7.2.1.10.1 It requires a display and control centre be located in AD
NK38-REP-00770- the MCR and in each SCA. The panel operator is required to be able to control the fire alarm
0489244 R000 system without having to leave operators station. The Edwards EST3 display and control
units in the Unit 0 CER and in each of the 5 SCAs cannot be controlled without the operator
having to leave his station. There is annunciation of fire or trouble and zone of signal origin in
MCR. Travel distance and time is insignificant to reach full details on the panels in the CER.
Same for CSCA and USCAs. Design changes would add little or no functional benefit.
D507 Automatic and Manual One gap from a review of CAN/CSA N293-2012 Exclude D507
[R-69] Water-Based Fire Gap 02135 against Clause 7.3.3.5 It requires where automatic sprinkler protection is
Suppression Systems provided, and ... installed below cable trays, they should be ... 0.15 m (6) below bottom of the
NK38-REP-00770- cable tray. A passive heat barrier should be provided that protects the cables and remains in
0489245 R000 place until sprinklers activated. Cable tray protection in DNGS does not satisfy the additional
requirement of a passive heat barrier. Changes to add passive heat barriers will trigger
cost and safety issues. (The only areas that have sprinklers and sheet metal barriers to
protect cable trays are in Units 1 to 4 turbine halls adjacent to Column Line A.). The design
of the existing cable tray protection meets the intent of protecting the cables in a fire.
D509 Thread Specifications One gap from a review of NFPA 24 2013 Exclude D509
[R-70] on Drawings Gap 02137 against Clause 4.1.3.(9)(b) It requires working plans include thread size and
NK38-REP-00770- coupling adapter specifications if different from NFPA 1963. No hydrant threads on design
0489247 R000 drawings. CSA hose threads are used, which is the standard for all Ontario. Not applicable.
D510 Valves Controlling One gap from a review of NFPA 24 2013 Exclude D510
[R-71] Water Supplies Gap 02138 against Clause 6.2.11 It required all connections to fire mains be in accordance
NK38-REP-00770- with one of the following, so they can be isolated: 1) to 7). This is a new clause to identify the
0489248 R000 acceptable valve arrangements for connections to FP systems that do not require AHJ
approval. Review of drawings and site walkdowns determined that the connections from fire
service mains in powerhouse to other buildings has isolating control valves of the OS&Y gate
type located within the powerhouse. The valves are not of the underground type and they are
not located or protected within fire-rated enclosures. None of the seven permitted options
match the valve installations. The DNGS situation is special. There is access to all buildings
on site, so valves in one building can control the water supply to the others. The existing
design meets the intent of the code.
D511 Connections Between One gap from a review of NFPA 24 2013 Exclude D511
[R-72] Sectional Valves Gap 02139 against Clause 6.6.1 It requires that sectional valves should be provided at
NK38-REP-00770- appropriate points within piping sections such that the number of FP connections between
0489249 R000 sectional valves does not exceed six. There are instances where more than 6 FP connections
are between sectional valves. This should requirement offers no significant benefit and is
not mandatory. The existing design is adequate to meet the intent of this requirement.
D512 Information Indicated on One gap from a review of NFPA 20 2013 Standard for Installation of Stationary FP Pumps Exclude D512
[R-73] Plans Gap 02140 against Clause 4.2.3.1 It requires plans be drawn to an indicated scale, on sheets
NK38-REP-00770- of uniform size, and indicate, as a minimum, the following items that pertain to the design of
0489250 R000 the system: (1) to (14). New clause for guidance for the minimum amount of information
needed on a fire pump installation plan. Seven of the items are not on the DNGS drawings.
The information is all available in other OPG documents. Not applicable for existing DNGS
documents.
D513 Fire Pump Nameplates One gap from a review of NFPA 20 2013 Exclude D513
[R-74] NK38-REP-00770- Gap 02141 against Clause 4.9.2 It requires the nameplates provided for pumps be of
0489251 R000 corrosion-resistant material. The plate for pump 1-78110-P26 is on the pump skid frame,
not attached to the pump body. Plate was removed during installation of the coupling
Page 63 of 77
0235 AD AGGREG 0004 01

guard. It should be reattached to the fire pump. Since there is an ID tag on the pump skid
frame, the intent of this requirement is met.
D514 Enclosed Passageways Two (2) gaps from a review of NFPA 20 2013
[R-75] NK38-REP-00770- Gap 02142 against Clause 4.12.1.1.1 It requires fire pump rooms that are not directly AD
0489252 R000 accessible from the outside be accessible through an enclosed passageway from an Credit ERT
enclosed stairway or exterior exit. New clause to ensure fire pump rooms and equipment are
accessible under actual fire conditions. There are no enclosed passageways leading to the
fire pumps; the DNGS pumps are not separated from the facility. They are backed up by the
adjacent unit fire pumps, and they are installed in areas with limited combustible loading. The
potential for a pump to be exposed to a fire in its unit is minimal. The booster pumps are not
necessary to meet flow and pressure requirements at the hose stations on Elevation 122.500,
where they are located, or below. The ERT can access the pumps.
Gap 02143 against Clause 4.12.2.1.2 It requires the fire-resistance rating of an enclosed Exclude
passageway that leads to a fire pump room not be less than the rating of the room. There are
no enclosed passageways and no separation of the pumps from the facility. Refer to the
resolution for gap 02142. Not applicable to DNGS.
D515 Hose Valve Thread One gap from a review of NFPA 20 2013 Exclude D515
[R-76] Requirement Gap 02144 against Clause 4.20.3.2 It requires thread types to comply with
NK38-REP-00770- (1) Hose valves shall have the NH standard external thread for the valve size specified, as
0489253 R000 per NFPA 1963 Standard for Fire Hose Connections
(2) Where local fire department connections do not conform to NFPA 1963, and the
connection is used as a wall hydrant, the AHJ shall designate the threads to be used.
The corresponding requirement in NFPA 20 2007 is Clause 5.19.3.2. The 2013 edition states
when a fire pump test header is used as a wall hydrant then the threads may be designated
by the AHJ and do not need to conform to NFPA 1963-2009. In DNGS there is no test header
or wall hydrant. Standpipe outlets are used for pump testing and hose valves must use
threads that conform to NFPA 1963. CSA hose threads are used at DNGS, as per agreement
with the Town of Clarington, which is the AHJ. The means of testing is from 2 standpipe
outlets at the roof. The thread spec is not an issue because the CSA thread is the standard in
Ontario. DNGS design meets the intent and complies with the AHJ requirement.
D516 Packaged and Two (2) gaps from a review of NFPA 20 2013
[R-77] Prefabricated Fire Pump Gap 02145 against Clause 4.29.1 It requires a packaged fire pump assembly meet all the Exclude
Assembly Requirements requirements: (1) to (5). The corresponding requirement in the 2007 edition is Clause 5.28.1.
NK38-REP-00770- It was revised to add design, construction and listing requirements. No documents for ASME
0489254 R000 BPV code; no listing of the overall assembly; no AHJ approval stamps. Since piping on skid is
not welded, BPV code is not applicable; AWS D1.1 is referenced. CSA W59-03 is applicable
in Canada instead of AWS D1.1, so skid is acceptable deviation. DNGS fire pump skids were
manufactured by TSSA-registered contractor to required codes because listed assemblies
were not available. Listing the skids now adds no value. AHJ process involved 3rd party
acceptance, but no stamped documents. Complies with intent.
Gap 02146 against Clause 4.29.3 Compliance with all requirements in standard, including AD
those in Clauses 4.12 through 4.17. Two were addressed as gaps 02142 and 02143 in D514. Credit ERT
There are no enclosed passageways to reach the fire pumps. Non-separation of the pumps
from the facility by passageways is acceptable because they are backed up by the adjacent
unit fire pumps and they are in areas of low combustion loading. The booster pumps are not
necessary for meeting the flow and pressure requirements at hose station on Elevation
122.500, where they are located or below. ERT has reviewed the pump access issue. AD.
D517 Electrical Protections Five (5) gaps from a review of NFPA 20 2013 Exclude D517
[R-78] and Requirements for Gap 02147 against Clause 9.1.8.1 It requires that no ground fault interruption means be A/R Exclude
Fire Pump Systems installed in any fire pump control or power circuit. This has not been confirmed. This new
NK38-REP-00770- requirement violates OPG standard. Leave in ground-fault alarm, but remove the interruption
0489255 R000 of pump power. A/R # 28155463-69.
Page 64 of 77
0235 AD AGGREG 0004 01

Gap 02148 against Clause 9.2.3.4.1 If the overcurrent protection device is not rated to carry Exclude
indefinitely the sum of the locked rotor current of the largest pump motor and the full-load (D480 same)
current of all of the other pump motors and accessory equipment, required by Clause 9.2.3.4,
alternate compliance can be achieved with an assembly listed for fire pump service,
complying with (1) to (4). The overcurrent protection device (fuse) for the DNGS pump cannot
carry the locked rotor current indefinitely. The 80 A fuse installed can only carry 600% of the
full load amperage for 30 seconds, and the device does not meet the criteria of 9.2.3.4.1. This
clause is not in the 2007 edition; it is a new clause that was added as an alternative to
9.2.3.4. With reference to the resolution given for D480 on Fire Pump Overcurrent
Protection, above, the DNGS design meets the intent of this requirement.
Gap 02149 against Clause 9.4.1 It requires the voltage at the controller line terminals not
drop more than 15% below normal (controller-rated voltage) under motor-starting conditions,
unless the requirements of Clauses 9.4.2 and 9.4.3 are met. No documents confirm that Exclude
voltage will not drop more than 15%. IRF states that OPG calculated the voltage drops and
demonstrated the voltage drop is well below the 15% limit. Direct compliance.
Gap 02150 against Clause 9.4.4.2 It requires electrical connections at motor terminal boxes
be made with a listed means of connection. (Connections with wire nuts fail.) No documents
found to verify listed means of connection. Assess the connections at the motor terminal A/R Exclude
boxes. If listed means was not used, revise the installation to comply A/R # 28155459-38.
Gap 02151 against Clause 9.4.4.3 It prohibits use of twist-on insulation-piercing and soldered
wire connections at motor terminal boxes. No documents found to verify means of connection.
Assess the connections at the motor terminal boxes. If listed means was not used, revise the A/R Exclude
installation to comply A/R # 28155459-38.
D519 Fire Protection and Life Two (2) gaps one from a review of NFCC 2010 and one from NBCC 2010. Both comply. Exclude D519
[R-79] Safety System Gap 02153 against NFCC Clause 2.1.3.8 It states that the commissioning of life safety and Exclude
Commissioning fire protection systems must be performed as a whole to ensure the proper operation and
NK38-REP-00770- inter-relationship between the systems. No documents found to confirm integrated systems
0489257 R000 testing of FP and life safety systems. Fixed FP systems inspection, testing and maintenance
(ITM) code compliance report generally confirms that, in periodic testing of fire alarm systems
and FP systems, testing of the integrations between systems is conducted, i.e.: water supply
and distribution systems, deluge and sprinkler system, (foam FP system is manual system),
CO2 FP system, fire and smoke detection, and smoke purge system. Therefore, while the
originally fire protection system commissioning documentation could not be located, the
periodic ITM procedures do sufficiently demonstrate that the various integrations between
systems are routinely tested and recorded. Complies.
Gap 02168 against NBCC Clause 3.2.4.6 It states that where life safety and FP systems are
installed to comply with NBCC, the commissioning of these integrated systems is required to Exclude
be performed as a whole, to ensure the proper operation and inter-relationship between the
systems. DM does not indicate commissioning of integrated systems was performed as a
whole to ensure proper operation and interrelationship between the systems. Like gap 02153
the ITM procedures demonstrate that the integrations between systems are tested and
recorded. Complies.
D520 Operation and One gap from a review of NFCC 2010. Not applicable Exclude D520
[R-80] Maintenance of Gap 02154 against Clause 3.1.3.1 It requires: (1) designation, use, maintenance and Exclude
Industrial Trucks operation of industrial trucks conform to NFPA 505, except for fuel-fired trucks and battery-
NK38-REP-00770- powered trucks; (2) fuel-fired trucks conform to ULC/ORD-C558; (3) battery-powered trucks
0489258 R000 conform to ULC/ORD-C583. (Clause was revised to update the references.) Intent of this
clause is to limit the probability of an accidental ignition occurring. OPG document N-
INS-08965-10001-R005 and OPGs use, operation and maintenance of industrial trucks do
not comply with current standards and guides; however, they meet the same intent of the
current code. From a use perspective, areas where trucks are operated do not involve
hazardous locations requiring special truck designations. Compliance with intent.
D522 Tank Storage of Five (5) gaps from a review of NFCC 2010 Exclude D522
Page 65 of 77
0235 AD AGGREG 0004 01

[R-81] Combustible Liquids Gap 02156 against Sentence 4.3.1.2.(1) It requires atmospheric storage tanks to be built Exclude
NK38-REP-00770- according to a list of 13 codes. This sentence was revised (from 2005 to 2010) to update the
0489260 R000 references to the standards. The SG, EPG and Lube Oil tanks were all constructed to
acceptable standards; however, they are older than those now referenced. The four SG tanks
had recent inspections, with repairs made as required. The EPG and Lube Oil tanks are
deemed to remain fit for continued service with periodic inspection and maintenance. The
tanks comply with the intent of the code
Gap 02157 against Sentence 4.3.3.1.(3) It states that where the clearance below the base of
aboveground tanks exceeds 300 mm, the tank supports are required to have minimum 2 h Exclude
fire-resistance rating. The EPG tanks are supported by steel saddles that are more than 300
mm high. Review of the clearance distances of EPS tanks indicates the clearance below the
base of the EPS tanks also exceeds 300 mm. The intent is to protect the tank supports to limit
the probability of a premature collapse of tank supports and spread of fire to adjacent areas.
Each tank storage room in the EPS fuel management building has containment walls 1.85.m
in depth providing a volume of 400,000 L. The compartments are separated by 16 concrete
walls rated for > 4 hr. The existing arrangement meets the intent of the code.
Gap 02158 against Sentence 4.4.1.2.(1) It requires every storage tank, piping systems and Exclude. Gap
sump to be tested and monitored for leaks as per Table 4.4.1.2.A to 4.4.1.2.E, which establish to be closed;
minimum requirements for the frequency and method for: commissioning testing, in-service when DNGS
monitoring and testing when a leak is suspected. No documents found to indicate periodic or licence will
any other inspections for any of the SG or EPG tanks, which meet NFCC 2005. Present reference
predefines and procedures for continuous and periodic in-service monitoring of SG and EPG NFCC 2010
tanks and piping systems meet the intent of the latest code and will be updated to comply and OPG will
with the code when the site operating licence is updated to reference NFCC 2010. then upgrade
Gap 02159 against Sentence 4.4.1.3.(2) It states when a leak detection test detects a leak in A/R Exclude
a single-walled construction underground storage tank or piping system, the leaking
components or system are required to be replaced or taken out of service. The SG and EPS
fuel piping is single-walled CS pipe. The OPG procedure states a disposition determines if a
degraded buried piping or underground tank is accepted until the next inspection, repaired or
replaced. OPG will revise the procedure to require replacement of leaking single-walled piping
with double walled material. A/R # 28155459-37.
Gap 02160 against Sentence 4.4.4.1.(3) It requires action if inventory reconciliation for liquid Exclude
storage tanks indicates: a) a monthly loss of 0.5% or more from an underground tank or 1%
Gap 02160 to
or more from an aboveground tank, b) three consecutive losses greater than 200 L/day, c) a
be closed by
water level (in the tanks) greater than 50 mm. No documentation indicates this information is
action in D119
used for inventory reconciliation of the SG and EPG tanks; the frequency for water tests does
gap 00455 to
not comply, and no documents evaluate this sentence. OPG inspects fuel level in the SG and
implement
EPG tanks weekly for fuel consumption but not inventory reconciliation. Inventory system is
inventory
needed to comply with NFCC 2005, as documented in IRF for D119 gap 00455, and the
system
specific criteria of this sentence will be met by the system implemented for NFCC 2005.
D523 Piping System Four (4) gaps from review of NFCC 2010
[R-82] Requirements Gap 02161 against Sentence 4.5.4.1.(3) It requires transfer points in piping for flammable Exclude
NK38-REP-00770- and combustible liquids be identified as per CPPI 1990 (colour-symbol system). OPG colours
0489261 R000 are different from CPPI 1990 colours. Operations personnel are trained in station colours, and
they escort the vehicles that deliver the liquids and they transfer the liquids from the tankers
into the storage tanks. OPG identifies transfer points with different colours, but meets intent..
Gap 02162 against Clause 4.5.6.1 It required underground piping be double-walled except A/R Exclude
for vents, risers and vertical fill piping. New clause. SG and EPG piping is single-wall CS.
Revise OPG procedure. Require replacement of leaking pipe or components with double-wall
pipe or take them out of service. A/R # 28155459-37.
Gap 02163 against Clause 4.5.7.1 It states: except for hose nozzle valves and emergency
valves, valves in piping systems for flammable or combustible liquids be designed for AD
temperatures and pressures of those systems and conform to ULC/ORD-C842; hose nozzle
valves conform to CAN/ULC-S620; emergency valves conform to ULC-S651. No evidence
Page 66 of 77
0235 AD AGGREG 0004 01

that these standards followed. OPG design and construction manual and practice specified
that valves be to ASME Class 600 or Class 1500 and that all equipment be designed for the
expected service and conditions. Valves on the fuel systems are designed for combustible
liquids. AD.
Gap 02164 against Clause 4.5.7.6.(1) It requires all valves be identified as per CPPI 1990.
Walkdown confirm that ID tags or signs are attached to valves, but the tags are not colour- Exclude
coded and do not match the sizes and shapes of CPPI 1990. Like gap 02161, meets intent.
D524 Fire and Smoke Two (2) gaps from review NBCC 2010.
[R-83] Characteristics of Gap 02165 against Sentence 3.1.5.18.(2) It states optical fibre cables and electrical wires AD
Electrical Wires and and cables with combustible insulation, jackets or sheathes that are not in totally enclosed
Cables non-combustible raceways may be installed in a plenum in a non-combustible building, if their
NK38-REP-00770- horizontal flame distance is not more than 1.5 m, and average/peak optical smoke density not
0489262 R000 more than 0.15/0.5, as per CAN/ULC-S102.4 (FT6 rating). No evidence the cables and wires
are so tested. Except for MCR, several areas have suspended ceilings, and rooms are served
by ducted supply and return ventilation; the spaces above ceilings are not used as plenums.
In MCR, cables and wires in the ceiling plenum are not in totally enclosed non-combustible
raceways and no documents confirm their fire performance. It is unlikely that they satisfy FT6
rating. MCR has a manual smoke venting system and self-contained-breathing-apparatus, so
operators can see and breathe until the action to identify and extinguish fire. Can also transfer
plant control and evacuate to SCA. Gap is acceptable.
Gap 02166 against Sentence 3.1.5.18.(3) It states where totally enclosed non-combustible
raceways are used in a plenum, exposed components of wiring systems with combustible AD
insulation, jackets and sheathes, including ... are permitted provided their vertical char is not
more than 1.5 m, when tested ... . No evidence that optical fibre cables and electrical wires
are so tested. Same disposition as Gap 02165. Gap is acceptable..
D525 Elevator Requirements Two (2) gaps from a review of NBCC 2010.
[R-84] NK38-REP-00770- Gap 02167 against Clause 3.1.13.11 It requires 1) wall and ceiling surfaces of elevator cars Exclude
0489263 R000 have a flame-spreading rating not more than 75; 2) wall, ceiling and floor surfaces have a
smoke developed classification not more than 450. No DNGS documents address this new
requirement. The interior of the DNGS elevators are metallic. Complies. Gap is closed.
Gap 02170 against Sentence 3.2.4.12.(4) It requires smoke detectors in elevator machine
rooms, upon actuation, to recall the elevators that are served by the rooms. DNGS does not AD
have elevator recall on smoke detection (not required originally). OPG personnel are trained Credit staff
and PA system instruction reminds them not to use elevators. Potential impact on those in the training
elevator at the time of fire detection. Tones and alarm messages are repeated after 1 minute
to reach those who were beyond PA coverage. Intent is achieved. AD.
D526 Electronic Supervision One gap from a review of NBCC 2010. Complies with intent. Exclude D526
[R-85] of Water Supply Valves Gap 02169 against Sentence 3.2.4.10.(2) It states if a fire alarm system in a building is
NK38-REP-00770- required to have an annunciator, all valves controlling water supplies in a standpipe system,
0489264 R000 except for hose valves, are required to be equipped with an electrically supervised switch for
transmitting a trouble signal to the annunciator in the event of movement of the valve handle.
Not all valves subject to this new requirement are equipped with supervisory switches. Valves
that are not electrically supervised are locked open and routinely inspected as per NFPA 25.
Complies with intent.
D527 Entrance Walkway One gap from a review of NBCC 2010 Exclude D527
[R-86] Smoke Detector Gap 02171 against Sentence 3.2.4.12.(5) It states that smoke detectors in buildings required
NK38-REP-00770- to have a fire alarm system are to have detectors located near the entrance to walkways or
0489265 R000 vestibules. There are no buildings within the scope of this project that are classified as high
buildings, so the need for smoke detectors at vestibules is not applicable. The only walkway is
the bridge between the CSA and the Operations Support Building. There is a smoke detector
in the OSB end, but not in the CSA end. A fire in the heavily travelled bridge would not go
undetected and unreported. CSA area has many alternate means of egress. Intent is met.
Page 67 of 77
0235 AD AGGREG 0004 01

D528 Voice Communication Nine (9) gaps from a review of NBCC 2010
[R-87] Systems Gap 02172 against Sentence 3.2.4.22.(1) It requires voice communication system consist of: AD
NK38-REP-00770- a) 2-way communication between the central alarm and control facility and the mechanical
0489266 R000 control centre from each floor area, and b) loudspeakers operated from the central facility.
The 2010 revision specifies building with more than 1000 occupants; the powerhouse PA
system doesnt conform to this sentence in NBCC 2005. For the purpose of life extension, the
PA system is generally acceptable. Since, the devices and wiring will not last 30 years, the
replacement system will meet the applicable code requirements. AD.
Gap 02173 against Sentence 3.2.4.22.(2) It requires the system be capable of broadcasting
prerecorded, synthesized, or live messages with voice intelligibility scale score of 0.70. Same
Gap 02174 against Sentence 3.2.4.22.(3) It requires the system be capable of silencing the
alarm in a single-stage fire alarm system after 30 seconds, while voice instructions are
transmitted. Same resolution as for gap 02172.
Gap 02175 against Sentence 3.2.4.22.(4) Same capability as gap 02174 for a 2-stage fire
alarm system. Same resolution as for gap 02172.
Gap 02176 against Sentence 3.2.4.22.(5) It requires capability for alarm signal in a 2-stage
fire alarm system to be selectively transmitted to any zone or zones, while maintaining an
alert signal or selectively transmitting voice instructions to any other zone or zones in the
building. Same resolution as for gap 02172.
Gap 02177 against Sentence 3.2.4.22.(6) It requires a 2-way communication be installed so
that emergency telephones are located in each floor area near the exit stair shaft. Same
Gap 02178 against Sentence 3.2.4.22.(7) It requires that where a fire alarm system is
required, a voice communication system be installed where a 2-stage fire alarm system is
installed. Same resolution as for gap 02172.
Gap 02179 against Sentence 3.2.4.22.(8) It requires a voice communication system to
consist of loudspeakers that are: a) operated from the central alarm and control facility (or a
designated area), and 2) except in elevator cars, be designed and located so that transmitted
messages are audible and intelligible in all parts of the building. Same resolution as for gap
02172.
Gap 02180 against Sentence 3.2.4.22.(10) A 2-way communication system is required to:
- include a means to silence the alarm signal in a single-stage fire alarm system while voice
instructions are being transmitted, but only after the alarm has initially sounded for 30 s.
- include a means to silence the alert signal and the alarm signal in a 2-stage fire alarm
system while voice instructions are being transmitted, but only after the alert signal has
initially sounded for 30 s
- be designed so that the alarm signal in a 2-stage fire alarm system can be selectively
transmitted to any zone or zones while maintaining an alert signal or selectively transmitting
voice communications to any other zone or zones.
D529 Electrical Conductors One gap from a review of NBCC 2010. Exclude D529
[R-88] for Fire Protection Gap 02181 against Sentence 3.2.7.10.(2) Electrical conductors used with fire alarms,
Systems emergency lighting, emergency equipment, fire pumps, and mechanical systems serving
NK38-REP-00770- areas of refuge and contained use areas are required to: a) conform to ULC-S139 including
0489267 R000 the hose stream application, to provide circuit integrity rating of 1 h, and b) be located in a
service space, separated from the remainder of the building, by a fire separation that has a
fire-resistance rating of 1 h. There are no high buildings, areas of refuge, or contained use
areas; however, fire pumps are part of the standpipe and hose systems. No evidence that the
cables to the fire pumps are protected. The fire pumps are supplied from two independently
routed power sources (ODD & EVEN) thereby limiting the potential for a single fire event,
unless involving the pumps or the areas in which they are located, to impact their power
supply. The intent of the code is met through alternate means.
Page 68 of 77
0235 AD AGGREG 0004 01

D530 Exit Signage Two (2) gaps from a review of NBCC 2010. Exclude D530
[R-89] NK38-REP-00770- Gap 02182 against Sentence 3.4.5.1.(2) It requires every exit sign a) be visible on approach Exclude.
0489268 R000 to the exit, b) consist of a green pictogram and a white or lightly tinted graphical symbol
meeting the colour specifications in ISO 3864-1, and c) conform to the dimensions in ISO
7010 for the following symbols ... DNGS does not comply with these new requirements. All
staff is trained or familiar with the safety features; others are escorted by staff that is trained.
Introduction of new signs could introduce inconsistencies and confusion. The benefit of a
complete replacement of existing signs does not justify the risk and cost. Existing signs
adequately comply with the intent and are understood by all employees.
Gap 02183 against Sentence 3.4.5.1.(3) It requires internally illuminated exit signs be Exclude.
continuously illuminated, and a) where powered by an electrical circuit conform with CSA
C22.2 No. 141, or b) where illumination is not powered by an electrical circuit, conform with
CAN/ULC-S572. DNGS exit signs are mainly powered by Class II power. Some exit signs are
powered by battery pack units, but no documents confirm they comply with CSA C22.2 No.
141-10. Some are tritium type exit signs, but no documents confirm they comply with
CAN/ULC-S572-10. Same resolution as for gap 02182.
D607 Severe Accident and Thirteen (13) gaps from a review of CSA N290.3-11 Requirements for the Containment Exclude D607
[R-90] Beyond Design Basis System of Nuclear Power Plants. One gap pertains to fire protection (control of hydrogen
Accident (BDBA) production); the other 12 gaps are excluded.
Design/SAMG Gap 02286 against Clause 9.1.2 It states, The selection of the containment concrete
NK38-REP-00770- material for new builds shall take into account the effects of severe accidents involving A/R Exclude
0488763 R000 interaction of a melted reactor core and concrete. Note: Examples of these severe accident
effects include the generation of (a) combustible gases; (b) aerosols; and (c) corrosive
conditions. DNGS was not designed for core-concrete interaction (CCI), but the shield tank
overpressure protection (STOP) and containment filtered venting system (CFVS) can
compensate for this new build requirement by promoting in-vessel retention (IVR) to prevent
CCI.
OPG is implementing changes to compensate for the inability of the concrete to adequately
resist CCI. Passive autocatalytic recombiners (PARs) were installed in U2 & U4 to recombine
hydrogen and oxygen A/R # 28131142-01, A/R # 28131143-01. A/R # 28153869-15 and -16
will track severe accident management guidance (SAMG) actions. A/R # 28154049-06 will
track design changes arising from BDBA analysis. DSR IP0030-1 will track implementation of
the CFVS. DSR IP0540-1 will track implementation of the STOP. A/R # 28131145-01, A/R #
28131146-01 will track completion of PARs implementation. In light of the changes to be
completed before life extension, DNGS will comply with the fire protection requirement.
Page 69 of 77
0235 AD AGGREG 0004 01

Appendix 2: Acceptable Deviation Gaps that were examined in

this evaluation report for Aggregate Effect
# Gap Issue Resolution A/R # Issue Resolution Form # Code Clause

1 415 D041 Acc. Dev. NK38-REP-00770-0421331 NFCC 2.1.3.5
7 472 D115 28155462-02 NK38-REP-00770-0425531 NFCC 5.5.4.3
Acc. Dev. AAR [R-95] Appendix A-7
AAR [R-95] Appendix B-3
8 473 D115 28155462-03 NK38-REP-00770-0425531 NFCC 5.5.4.4
9 480 D076 Acc. Dev. NK38-REP-00770-0421668 CSA N293-07 5.4.1.2
13 517 D116 28155459-26 NK38-REP-00770-0425532 CSA N293-07 6.8.1.4
28155462-37
Acc. Dev. 28155459-26 AAR [R-95] Appendix A-8
15 535 D044 Acc. Dev. NK38-REP-00770-0421334 CSA N293-07 7.2.1.6.1
18 538 D044 28155462-38 NK38-REP-00770-0421334 CSA N293-07 7.2.1.6.4
19 540 D044 28155462- NK38-REP-00770-0421334 CSA N293-07 7.2.1.9
Acc. Dev. AAR [R-95] Appendix B-1
20 547 D045 Acc. Dev. 28155462-33 NK38-REP-00770-0421335 CSA N293-07 7.3.1.1.2
22 551 D045 28155462-35 NK38-REP-00770-0421335 CSA N293-07 7.3.3.3
Page 70 of 77
0235 AD AGGREG 0004 01


28 615 D076 Acc. Dev. NK38-REP-00770-0421668 CSA N293-07 11.5.2
29 807 D215 Acc. Dev. NK38-REP-00770-0425798 NFPA 24 5.3.1
30 808 D215 Acc. Dev. NK38-REP-00770-0425798 NFPA 24 5.9.1.1
33 827 D215 Acc. Dev. NK38-REP-00770-0425798 NFPA 24 13.3
36 839 D125 Acc. Dev. NK38-REP-00770-0425537 NFPA 24 10.10.2.2.2
39 1268 D044 Moved D428 NK38-REP-00770-0421334 CSA N293-07 5.7.3.1
D428 Acc. Dev. NK38-REP-00770-0462011
46 1333 D251 Acc. Dev. NK38-REP-00770-0425829 ASME N509-2002 4.11.2
47 1334 D251 Acc. Dev. NK38-REP-00770-0425829 ASME N509-2002 4.11.3
50 1764 D439 28155462-39 NK38-REP-00770-0462022 CSA N293-07 6.8.3.4
Page 71 of 77
0235 AD AGGREG 0004 01


54 1846 D045 Acc. Dev. 28155462-33 NK38-REP-00770-0421335 CSA N293-07 7.3.1.2
56 1850 D045 Acc. Dev. 28155462-33 NK38-REP-00770-0421335 CSA N293-07 7.3.4.2
60 1855 D445 28155462-19 NK38-REP-00770-0462028 NBCC 3.1.5.12
61 1857 D440 Acc. Dev. NK38-REP-00770-0462023 NBCC 3.1.5.18
Page 72 of 77
0235 AD AGGREG 0004 01


115 1924 D466 28155462-42 NK38-REP-00770-0462055 NBCC 3.5.3.1
Acc. Dev. 28155462-43 AAR [R-95] Appendix A-13
Page 73 of 77
0235 AD AGGREG 0004 01


116 1925 D466 NK38-REP-00770-0462055 NBCC 3.5.3.3
Page 74 of 77
0235 AD AGGREG 0004 01


174 2013 D227 NK38-REP-00770-0425809 NFPA 24 7.2.3
177 2023 D476 Acc. Dev. NK38-REP-00770-0462065 NFPA 24 10.8.3.1.1.1
Page 75 of 77
0235 AD AGGREG 0004 01


190 2045 D428 Acc Dev NK38-REP-00770-0462011 N293-07 5.3.3
196 2137 D509 Acc. Dev. NK38-REP-00770-0489247 NFPA 24 4.1.3(9)(b)
207 2153 D519 Acc. Dev. NK38-REP-00770-0489257 NFCC-2010 2.1.3.8
Page 76 of 77
0235 AD AGGREG 0004 01


209 2156 D522 Acc. Dev. NK38-REP-00770-0489260 NFCC-2010 4.3.1.2.(1)
216 2165 D524 Acc. Dev. NK38-REP-00770-0489262 NBCC-2010 3.1.5.18.(2)
219 2168 D519 Acc. Dev. NK38-REP-00770-0489257 NBCC-2010 3.2.4.6
Page 77 of 77
ONTARIOFiiiiEiI
GENERATION Report
Document Number:
NK38-REP-03680-10195
N/A
Sheet Number: Revision:
N/A R001
I ~CCEPTABLE DEVIATIONS AGGREGATE ASSESSMENT

Ontario Power Generation Inc. , 2014. This document has been produced and distributed for Ontario Power Generation Inc.
purposes only. No part of this document may be reproduced, published, converted, or stored in any data retrieval system , or
Acceptable Deviations Aggregate

Assessment
NK38-REP-03680-10195-R001
Accepted by: _~~-----'A- _ _----=O=--- =.L'-I- t4- Authorized by:

V_! _ ""2.
Date tiaz Malek Date
Manage, Director, Nuclear Safety
0235 AD AGGREG 0005 01
Title: Acceptable Deviations Aggregate Assessment

P. Wiebe Date
Consultant
CPUS Ltd.

R. Arora Date
Consultant
CPUS Ltd.

VP Engineering
Page 1 of 39
0235 AD AGGREG 0005 01
Record of Revisions
Rev Date Description Prepared by Reviewed by Approved
No. by
00 2013 09 30 Issued for Use T.J. (Ravi) K.C. Garel M. Jansen
Ravishankar
01 2014 05 20 Revised to include ADs from P. Wiebe R. Arora M. Jansen
the Emerging Issues Report
and additional open issues
that were converted to ADs.
Page 2 of 39
0235 AD AGGREG 0005 01
SUMMARY
CNSC regulatory document RD-360 [R-1] specifies that as a part of the Global
Assessment, an assessment of interactions between Safety Factors, ISR (Integrated
Safety Review) Gaps, and resolutions to Open ISR Issues and plant strengths, be
undertaken for their impact on plant safety. The goal is to determine if there are any
aggregate effects on public safety from such interactions that might indicate practical
remedial actions.
This report documents the aggregate effect assessment that was performed as an
input to the Darlington NGS Global Assessment. The aggregate effect assessment
considered only Acceptable Deviations identified by the Integrated Safety Review
(ISR) and in subsequent related reviews (e.g. CNSC comments on the ISR). This is
acceptable as:
Interactions between Safety Factors were assessed during the ISR;

When implemented, the resolutions of the ISR Open Issues will ensure that
Darlington NGS is compliant with the requirements against which the
constituent ISR Gaps were assessed
Safety improvements which will remedy the ISR Open Issues, will be carried
out in accordance with OPG and Darlington NGS change control governance,
which is well established, and any issues with regards to interactions between
the planned Safety Improvements will be resolved during the review and
assessment stage of the change control process.
The aggregate effect assessment was carried out using a combination of symptom
classification (i.e. symptom binning) and barrier analysis techniques [R-15], and a
strictly qualitative similarity analysis. The symptom classification and barrier analysis
techniques were employed by the Global Assessment Report (GAR) Team to identify
the barriers associated with each Acceptable Deviation. Examples of the 25 barriers
identified include Special Safety Systems, Fire Protection and HVAC systems. The
following sub-set of eight (8) barriers, which relate to the Control, Cool and Contain
(CCC) functions and accident management, were selected for further detailed
aggregate effects assessment based on their significance to public safety (the
Special Safety Systems consists of three barriers as shown):
Accident Management
Fire Protection
Human Performance
Pressure Boundary
Seismic
Special Safety Systems (Shutdown Systems, Emergency Coolant Injection,
Containment)
Page 3 of 39
0235 AD AGGREG 0005 01
An assessment of a total of 208 ISR Acceptable Deviations was performed to

determine any aggregate effects between them that would indicate a practical
remedial action. Of these, a total of 183 Acceptable Deviations were associated with
the eight (8) barriers. The detailed aggregate effects assessment of the Acceptable
Deviations associated with each of the eight barriers were performed by Subject
Matter Experts. Collectively their assessments identified 46 groups of Acceptable
Deviations each of which shared one or more attributes, e.g., component, systems
and programs.
A total of 95 Acceptable Deviations were associated with the remaining 17 (non-

significant) barriers. In most cases these were also associated with the eight
significant barriers. These 95 were assessed by inspection using judgment. Only two
(2) of the 208 Acceptable Deviations were judged to be not associated with any of the
25 barriers.
The assessments concluded that the aggregate impact from each of the 46 groups of
Acceptable Deviations was either negligible or nil, or any non-negligible aggregate
impact was mitigated by existing plant provisions such that any residual aggregate
impact was negligible or nil. Thus, there was no additional practical remedial action
indicated.
Page 4 of 39
0235 AD AGGREG 0005 01
Table of Contents
SUMMARY ...................................................................................................................... 3
1 Introduction.............................................................................................................. 6
2 Methodology ............................................................................................................ 6
Figure 1: Interaction Assessment Process ............................................................... 8
3 Results .................................................................................................................. 15
Table 1: Number of Acceptable Deviations vs. Selected Barriers .......................... 16
Table 2: Acceptable Deviations in Significant Barriers ........................................... 18
Table 3: Acceptable Deviations in Non-Significant Barriers ................................... 21
Table 4: Applicable Attributes ................................................................................ 23
Table 5: Acceptable Deviation Groups with Potential Aggregate Effect ................. 25
4 Conclusion............................................................................................................. 29
5 References ............................................................................................................ 30
Appendix A Instructions to Guide Subject Matter Experts Review .............................. 32
Appendix B Barriers Assigned to Emerging Acceptable Deviations ............................ 34
Page 5 of 39
0235 AD AGGREG 0005 01
1 Introduction
CNSC regulatory document RD-360 [R-1] specifies that as a part of the Global
Assessment, an assessment of interactions between Safety Factors, ISR
(Integrated Safety Review) Gaps, and resolutions to Open ISR Issues and plant
strengths, be undertaken for their impact on plant safety. The goal is to determine if
there are any aggregate effects on public safety from such interactions that might
indicate practical remedial actions. This report outlines such an assessment
performed as an input to the Darlington NGS Global Assessment Report.
Section 2 of this report describes the methodology used to perform the aggregate
effect assessment. Section 3 presents the results of the assessments, and Section
4 presents the conclusions.
2 Methodology
Section 6.3.1 of CNSC regulatory document RD-360 [R-1] specifies that an
assessment of interactions between Safety Factors, ISR Gaps, resolutions to Open
ISR Issues and plant strengths for their impact on plant safety be undertaken as a
part of the Global Assessment Report. The scope of this interaction assessment
performed for the Global Assessment Report [R-2] was determined based on the
following consideration:
Any interactions between Safety Factors were assessed during the ISR.
These are documented in Section 3.3 of each of the Safety Factor Reports.
When implemented, the resolutions of the ISR Open Issues will ensure that
Darlington NGS is compliant with the requirements against which the
constituent ISR Gaps were assessed. Based on a detailed review of the
Safety Factor Reports by the Aggregate Review Team [R-3] and the Global
Assessment adequacy review described in [R-12] of this report, it was
determined that the proposed safety improvements will individually
contribute to an improvement in the current excellent performance of the
plant.
The safety improvements, which will remedy the ISR Open Issues, will be
carried out in accordance with OPG and Darlington NGS change control
governance, which are well established. Any issues with regards to
interactions between the planned Safety Improvements will be resolved
during the review and assessment stage of the change control process.
Darlington NGS, as part of their periodic updates of Darlington NGS
Probabilistic Risk Assessment (DARA), will be assessing the integrated
impact of safety improvements when sufficient design details become
available prior to restart.
Page 6 of 39
0235 AD AGGREG 0005 01
Thus, the only ISR Issues that will not be closed are Acceptable Deviations, which
are ISR Issues assessed to have a low or very low overall safety significance.
Therefore, the scope of the interaction assessment is limited to the ISR Issues
categorized as Acceptable Deviations. Interactions are those that could result from
common or similar design and operational features, which could lead to an
aggregate (i.e., compounded) effect.
The objective of this interaction assessment is to first determine if there are any
aggregate effects for the Acceptable Deviations and if so identify separately any
practical safety improvements using the OPG Gap Resolution Process [R-6].
Figure 1 is a schematic representation of the Interaction Assessment process.
Page 7 of 39
0235 AD AGGREG 0005 01
Figure 1: Interaction Assessment Process
1
Identify Acceptable Deviations
(ADs) for Interaction Assessment
2
Identify Significant Barriers
Affected by the ADs
3.1
Identify Attributes Relevant to Each
Significant Barrier
3.2
Identify Attributes Relevant to Each
AD that are Common within each
Significant Barrier
3.3
Are there NO 3.3
ADs sharing Common Attributes Exclude ADs Not Sharing any
within Each Significant Barrier? Common Attributes from Interaction
Assessment & Document
Conclusion
YES
3.3
Identify Groups of ADs Sharing
Same Common Attributes
Page 8 of 39
0235 AD AGGREG 0005 01
Figure 1 (Contd): Interaction Assessment Process

A
4
Determine Aggregate Impact of
Each Grouped ADs
4.1 YES
Is the Aggregate Impact for
Each Grouped ADs Nil or Document Conclusions
Negligible?
NO
NO
4.2 4.2.1
Are there Plant Provisions to
counter the Cumulative Effects
of Each Grouped ADs?
YES
5
4.2
Resolve Using Gap Resolution
Determine Any Residual
Aggregate Impact Process (NK38-INS-00770-
10004)
NO
4.2 4.2.2
Is the Residual Impact Nil
or Negligible?
5
Identify and Document
YES Potential Practical Remedial
Actions to Counter Identified
Residual Aggregate Effect
Document Conclusions
Page 9 of 39
0235 AD AGGREG 0005 01
A description of the steps (see Figure 1) in the Interaction Assessment process

follows:
1. Identify Acceptable Deviations for Interaction Assessment

Acceptable Deviations for interaction assessment were identified using a
combination of symptom classification (i.e. symptom binning) and barrier analysis
techniques [R-15] with a view to identifying any aggregate effect from the
Acceptable Deviations that might lead to a practical improvement. The following
provides a summary description of barrier analysis and symptom classification
techniques.
A barrier is a means of controlling energy sources and work process to

protect against events with undesirable public safety, worker safety,
environmental or economic consequences. Barriers can be physical
hardware such as pressure retaining components, engineered systems, or
the containment envelope. Barriers can also be administrative in nature
such as training programs, operating and maintenance procedures, and
emergency response plans. Barrier analysis is a root cause analysis
technique that is used reactively to identify weaknesses in barriers that
contributed to an undesirable event so that corrective actions can be taken
to reduce the probability of a similar event occurring in the future. In this
case, barrier analysis was used proactively to determine which barriers each
AD could potentially affect so that the aggregate impact of all relevant ADs
on each barrier could be assessed.
The symptom classification technique is used by root cause analysts to

group or bin a large number of minor problems or symptoms so that
underlying weaknesses can be identified. The technique relies heavily on
the collective experience of a team of experienced individuals with varied
backgrounds and usually involves a number of iterations to obtain
agreement on the selection of the correct bins and allocation of each
symptom to one or more bins. The output of the analysis is usually
displayed in the form of a Pareto chart which indicates the symptoms that
are being experienced most frequently. In this case, the technique was used
to determine which ADs could potentially impact each selected barrier.
Each Acceptable Deviation identified in the ISR was initially reviewed by a Global
Assessment team member with expertise in the subject area, to determine if the
Acceptable Deviation issue was adequately dispositioned. The team member was
also asked to identify which barriers (components, systems, or programs that were
specifically designed to mitigate or minimize plant risk) were potentially affected by
Page 10 of 39
0235 AD AGGREG 0005 01
not closing the gap against modern codes and standards identified in each
Acceptable Deviation.
For the purposes of the interaction assessment two specific types of barriers were
selected:
Hardware barriers- (components and systems) which were chosen based on

the understanding of the detailed Darlington NGS design.
Administrative barriers which were chosen by consideration of the programs
described in the following documents:
o CNSC RD -360 Life Extension of Nuclear Power Plants Appendix A
[R-1]
o IAEA Operational Safety Review Team Guidelines [R-4]
o WANO Performance Objectives and Criteria [R-5]
The assignment of one or more barriers to each Acceptable Deviation used a

conservative approach to include all barriers that were potentially impacted, even if
it was only in a very minor way. The initial results were reviewed to determine if the
right barriers had been selected and whether additional barriers should be included
and/or if some should be combined or subdivided. This review was a team exercise
facilitated by a Root Cause Analysis specialist where the combined expertise of the
whole team was used to ensure all the potentially impacted barriers were identified.
Then, all Acceptable Deviations were reviewed in turn and the potentially impacted
barriers were assigned. A total of 25 barriers were identified that could be impacted
by the 90 ADs1 that were documented in the ISR Safety Factor Reviews. The
results of the barrier assignment are documented in Reference 15.
An additional 118 Acceptable Deviations, identified subsequent to the issue of the

Final ISR Report [R-3] through, for example, a review of emerging issues2, were
also reviewed in turn and the potentially impacted barriers (from among the 25
barriers mentioned above) were assigned.
1
Throughout this report, when referring to the number of Acceptable Deviations addressed, it refers to the number of ISR
issues that contain at least one ISR gap classified as an Acceptable Deviation.
2
Emerging Issues are changes or additions made after the ISR Code Effective Date to the modern version of the codes
and standards listed in Appendix B of N-PROC-LE-0005 [R-7], to assess the impact of these changes on the IIP, as well
as any new significant industry OPEX as per N-PROC-LE-0007 [R-8]. Emerging issues up to February 7, 2014 have been
considered. Appendix B documents the barrier assignment for 62 new Acceptable Deviations identified as part of the
latest code refresh reviews [R-16].
Page 11 of 39
0235 AD AGGREG 0005 01
2. Identify Significant Barriers

A sub-set of the barriers identified using the conservative approach mentioned
above was selected for further assessment by the GAR Team. These were barriers
mostly pertaining to the Control, Cool and Contain (CCC) functions and accident
management function, and hence significant in terms of impact on public safety.
This was done to focus the subsequent steps in the interaction assessment on
public safety-critical Acceptable Deviations. Eight (8) barriers were judged to be
significant to public safety, with three (3) of them grouped into one area:
Accident Management
Fire Protection
Human Performance
Pressure Boundary
Seismic
Containment)
The above barriers all relate to the CCC function and to accident management. The
seismic barrier was selected for its impact on the CCC function, as well as in view of
recent international operating experience.
The above eight (8) barriers were subjected to the following analysis steps.
The remaining 17 barriers were examined by inspection to determine, based on

judgment, if there was any aggregate impact from the associated Acceptable
Deviations.
3. Analysis of Aggregate Effect of Acceptable Deviations

The Acceptable Deviations binned within each of the above eight (8) barriers, were
reviewed to identify and assess any interactions between the Acceptable Deviations
within each significant barrier and thus any aggregate effect on public safety. A
team of Subject Matter Experts (SMEs) who specialize in all elements of the design
and operation of CANDU Power Plants was assembled to assess the significance of
these Acceptable Deviations to public safety.
The SME reviews employed judgment and/or similarity analysis to determine which
of the Acceptable Deviations could result in an aggregate effect when considered
together. The similarity analysis employed was strictly qualitative and not statistical.
The SME reviews were guided by a set of instructions provided to them. These
instructions are included in Appendix A.
Page 12 of 39
0235 AD AGGREG 0005 01
3.1 Identify Attributes Applicable to Each Significant Barrier

The similarity analysis involved identifying for each barrier a set of attributes. The
attributes of each barrier were then used as a basis for determining if issues
associated with each Acceptable Deviation affecting the barrier were similar.
Examples of attributes identified as being relevant to one or more of the significant
barriers are:
Affected Components
Programs
Technical area affected, e.g., safety analysis
3.2 Identify Attributes Relevant to Each Acceptable deviation

The SME review of each barrier then involved identifying which of the attributes
applicable to that barrier, was relevant to each of the Acceptable Deviations. This
was done to identify groups of Acceptable Deviations for the interaction
assessment.
3.3 Group Acceptable Deviations sharing the same Attribute(s)

Acceptable Deviations sharing one or more attributes were grouped together.
Interaction assessments were performed on each group of Acceptable Deviations.
Acceptable Deviations sharing the same attribute(s) could potentially have a
compounding effect that might weaken the barrier.
4. Determine Aggregate Impact of Each Group of Acceptable Deviations

Employing their knowledge of the systems and processes and their judgment, the
SMEs reviewed each group of Acceptable Deviations to determine whether any
aggregate impact on the common attribute(s) and hence public safety exists.
The interaction assessment involved the following sub-steps:
4.1 No or Negligible Aggregate Impact

If the aggregate impact was assessed to be none or negligible, it meant that the
group of ADs did not warrant any remedial action and thus did not require any
further consideration.
Page 13 of 39
0235 AD AGGREG 0005 01
4.2 Non-Negligible Aggregate Impact

If the aggregate impact was assessed to be not negligible, then the SME assessed
if and to what extent plant provisions, i.e., defence-in-depth provisions and plant
strengths, mitigate the assessed aggregate impact.
4.2.1 Groups of Acceptable Deviations for which there are no plant defence-
in-depth provisions or plant strengths to mitigate the assessed
aggregate impact were identified for further resolution in accordance
with NK38-INS-00770-10004 [R-6], with the objective of identifying any
practical safety improvements additional to those resulting from the
resolution of ISR Open Issues.
4.2.2 Groups of Acceptable Deviations for which there are plant defence-in-
depth provisions and/or plant strengths to mitigate the assessed
aggregate impact, the SMEs assessed any residual aggregate impact.
Where the mitigation was not sufficient to render any residual
aggregate impact negligible, these ADs were also identified for further
resolution in accordance with NK38-INS-00770-10004 [R-6], with the
objective of identifying any practical safety improvements additional to
those resulting from the resolution of ISR Open Issues.
5. Resolve Grouped Acceptable Deviations with Residual Aggregate Impact

Each group of Acceptable Deviations that were assessed to have a residual
aggregate impact was treated like an ISR Open Issue and was subject to resolution
in accordance with NK38-INS-00770-10004 [R-6], with the objective of identifying
any practical safety improvements additional to those resulting from the resolution of
ISR Open Issues.
This process is beyond the scope of the aggregate assessments performed by the
SMEs.
The interaction assessment process required documentation of the results as

appropriate at various steps in the process.
Page 14 of 39
0235 AD AGGREG 0005 01
3 Results
The interaction assessment of Acceptable Deviations was performed as per the
methodology described in Section 2. The results from the assessments ([R-9], [R-
10], [R-11] and [R-14]) are provided below.
1 Identification of Acceptable Deviations for Interaction Assessment

The GAR team identified 25 hardware and administrative barriers using a
conservative approach including all barriers that were potentially impacted, even if it
was only in a very minor way. The 25 barriers are:
Accident Management
Ageing Management
Audit Program
Configuration Management
Containment System
Decommissioning
ECI System
Electrical Systems
Emergency Heat Sink System
Emergency Preparedness
Employee Health and Safety
Environmental Protection
Fire Protection
Human Performance
HVAC Systems
Periodic Inspection Program
Pressure Boundary Components
Radiation Protection
Reactor Components
Seismic
Shutdown Systems
Standby Power
Structures
Testing Programs
Training Programs
2 Identification of Significant Barriers

A sub-set of the 25 barriers identified was selected for further assessment by the
GAR Team. These were barriers mostly pertaining to the Control, Cool and Contain
(CCC) and accident management functions, and hence significant in terms of impact
Page 15 of 39
0235 AD AGGREG 0005 01
on public safety. The Eight (8) barriers that were judged to be significant to public
safety, with three (3) of them grouped into one area, were:
Accident Management
Fire Protection
Human Performance
Pressure Boundary
Seismic
Containment)
The above barriers all relate to the CCC function and to accident management. The
seismic barrier was selected for its impact on the CCC function, as well as in view of
recent international operating experience. The Acceptable Deviations binned within
each of the above eight (8) barriers, were assessed as to their significance to public
safety.
Table 1 summarizes the number of Acceptable Deviations that were reviewed under
each significant barrier.
Table 1: Number of Acceptable Deviations vs. Selected Barriers
Selected Barriers Number of Acceptable Deviations

3
Accident Management 51
4
Fire Protection 84
5
Human Performance 35
Pressure Boundary 43
Seismic 11
6
Special Safety Systems (Shutdown Systems, 40
Emergency Coolant Injection, Containment)
3
The count includes ISR Open Issue D044 as one or more of its gaps are assessed as acceptable deviations.
4
The count includes ISR Open Issues D517, D522 and D523 as one or more of their gaps are assessed as acceptable
deviations.
5
The count includes ISR Open Issues D044 and D260 as one or more of its gaps are assessed as acceptable deviations.
6
The count includes ISR Open Issues D013 and D607 as one or more of their gaps are assessed as acceptable
deviations.
Page 16 of 39
0235 AD AGGREG 0005 01
Table 2 lists the Acceptable Deviations considered within each significant barrier
listed above. The Acceptable Deviations considered included those from the
Integrated Safety Review [R-3] and supplemental assessments including Reference
16. Reference [R-12] contains detailed summaries of all Acceptable Deviations.
Page 17 of 39
0235 AD AGGREG 0005 01
Table 2: Acceptable Deviations in Significant Barriers
Special
Accident Fire Human Pressure
Seismic Safety
Management Protection Performance Boundary 7
Systems
D040 D041 D040 D001 D014 D010
D041 D052 D044 D003 D029 D013
D044 D076 D052 D021 D064 D014
D045 D110 D062 D022 D103 D015
D052 D125 D076 D023 D285 D017
D061 D171 D157 D085 D299 D018
D062 D176 D188 D089 D366 D021
D064 D222 D233 D090 D414 D022
D067 D233 D260 D092 D415 D029
D222 D298 D261 D099 D427 D032
D233 D437 D263 D103 D499 D060
D261 D438 D270 D151 D061
D270 D440 D272 D160 D062
D277 D443 D274 D283 D071
D278 D447 D286 D284 D146
D281 D450 D289 D340 D159
D286 D451 D290 D341 D164
D289 D453 D291 D360 D245
D290 D454 D292 D361 D261
D291 D455 D293 D362 D286
D293 D456 D298 D363 D289
D298 D457 D396 D364 D290
D437 D458 D437 D365 D291
D438 D462 D438 D366 D292
D440 D463 D440 D367 D293
D447 D465 D447 D368 D302
D451 D470 D451 D369 D305
D453 D471 D453 D392 D306
D454 D474 D454 D393 D307
D455 D478 D455 D411 D308
7
Special Safety Systems consists of three barriers: Shutdown Systems, Emergency Coolant Injection, and
Containment.
Page 18 of 39
0235 AD AGGREG 0005 01
Special
Seismic Safety
Systems
D456 D480 D456 D418 D309
D457 D481 D457 D419 D310
D462 D482 D462 D483 D327
D463 D492 D463 D485 D357
D327 D506 D608 D486 D358
D329 D507 D487 D329
D608 D509 D488 D564
D506 D510 D489 D607
D514 D511 D490 D608
D519 D512 D417 D609
D527 D513 D564 D613
D528 D514 D614
D530 D515 D615
D226 D516
D461 D517
D464 D519
D472 D520
D507 D522
D522 D523
D523 D524
D524 D525
D526
D527
D528
D529
D530
D044
D045
D048
D080
D115
D116
D181
D215
D225
Page 19 of 39
0235 AD AGGREG 0005 01
Special
Seismic Safety
Systems
D226
D227
D251
D429
D439
D445
D446
D452
D461
D464
D466
D469
D472
D473
D475
D476
D477
D479
D607
Page 20 of 39
0235 AD AGGREG 0005 01
Table 3 below lists the Acceptable Deviations in the other 17 non-significant

barriers. There are a total of 81 Acceptable Deviations associated with the 17 non-
significant barriers. Fifty-eight (58) of these Acceptable Deviations are also
associated with the eight (8) significant barriers, while 23 Acceptable Deviations are
associated only with the 17 non-significant barriers. Only two (2) Acceptable
Deviations, viz., D078 and D287, were judged to be not associated with any of the
25 barriers.
Table 3: Acceptable Deviations in Non-Significant Barriers
Barrier Acceptable Deviations

Ageing
D268
Management
Audit Program D184
Configuration
D263, D327, D473
Management
Decommissioning D070
Electrical Systems D035, D048, D072, D119, D141, D330, D482, D507
Emergency Heat
D072, D225, D277, D472, D522, D523
Sink System
Emergency
D026, D207, D209, D222, D254, D258, D259, D270
Preparedness
Employee Health D045, D110, D156, D157, D170, D176, D181, D188,
and Safety D291, D292, D466, D519, D525, D528
Environmental
D207, D209, D210, D212, D246, D251, D271, D280
Protection
HVAC Systems D167, D246, D248, D251, D254
Periodic Inspection
D151, D159, D160, D164, D202, D417, D564, D609
Program
Radiation Protection D156, D157, D170
Reactor
D021, D022, D023, D491
Components
Standby Power D048, D072, D119, D141, D472, D522, D523
D077, D080, D085, D103, D160, D283, D284, D285,
Structures
D294, D299, D401, D452, D499, D514, D609
D010, D014, D015, D017, D018, D029, D064, D125,
Testing Programs
D167, D246, D248, D254, D263, D524
Training Programs D115, D181, D225, D272, D506, D527, D530
Page 21 of 39
0235 AD AGGREG 0005 01
3 Analysis of Aggregate Effect of Acceptable Deviations

3.1 Identification of Attributes Applicable to Each Significant Barrier
The Subject Matter Experts (SMEs) identified the attributes applicable to the
significant barrier based on their review of the Acceptable Deviations they were
assessing for interactions ([R-9], [R-10], [R-11] and [R-14]). Table 4 below lists the
applicable attributes that the SMEs considered for each significant barrier. In the
case of assessment of aggregate effects of the significant barrier Special Safety
Systems (SSSs), the assessment was performed not only for each of the SSSs but
also for aggregate effects across the SSSs. A total of ten attributes that apply only
to the assessment of aggregate effects across the SSSs were identified and are
listed in Table 4 (see footnote 7).
Page 22 of 39
0235 AD AGGREG 0005 01
Table 4: Applicable Attributes
Significant Barrier
Special Safety
Fire Protection
Performance
Management
Applicable
Systems
Boundary
Pressure
Accident
Seismic
Human
Attributes
Affected
X X X X X
Components
Affected
X X X X
Systems
Defence-in-
Depth Barrier
X
for DNGS Fire
Protection
Fire Protection
X
Function
Mitigating
barriers credited
in the IRF for
X X X
AD disposition,
e.g. system
chemistry
Potential Impact
of AD on that X
component
Programs X X X X
Safety function
affected, e.g. X X
reliability
Technical area
affected, e.g., X X
safety analysis
Technical bases
used in AD
X X
disposition, e.g.
risk assessment
Page 23 of 39
0235 AD AGGREG 0005 01
Significant Barrier
Special Safety
Fire Protection
Performance
Management
Applicable
Systems
Boundary
Pressure
Accident
Seismic
Human
Attributes
Administrative
X
Controls8
Design
Mechanical X
Protection8
Design -
X
Redundancy8
Periodic
Inspection
Program/ Aging X
Management
Program8
Safety Related
System Test X
Program8
Vendor Quality
X
Requirements8
Independence
X
Requirements8
Safety Analysis X
Separation
X
Requirements8
Design
7 X
Modification
Human Factors
X
in Design
Physical
Aspects of Fire X
Protection
8
This attribute applies only to assessment of aggregate effects across the SSSs, i.e., SDS, ECI and Containment.
Page 24 of 39
0235 AD AGGREG 0005 01
3.2 Identification of Attributes Relevant to Each Acceptable Deviation

The SMEs, based on their review of the Acceptable Deviations and their knowledge
of systems and programs, identified for each Acceptable Deviation those of the
applicable attributes which they judged to be relevant to the Acceptable Deviation
([R-9], [R-10], [R-11] and [R-14]).
3.3 Groups of Acceptable Deviations sharing the same Attribute(s)

The SME assessments identified 46 groups of Acceptable Deviations, with potential
aggregate effect. They are listed in Table 5.
Table 5: Acceptable Deviation Groups with Potential Aggregate Effect
Barrier Groups of ADs with Potential Aggregate Effects

Accident D061, D261, D286, D289, D291 and D293
Management D041, D472 and D523
D044, D045, D453, D454, D455 and D528
D222 and D528
D438, D453, D454 and D455
D041, D044, D045, D052, D437, D438, D472 and D514
D044, D222, D437, D453, D454, D455, D506 and D524
D261, D286, D289, D291, D293, D044, D222, D437, D453,
D454, D455, D506 and D526
Human D233, D298, and D463
Performance D260, D261, D286, D289, D290, D291, D292, D293, and
D396
Fire Protection D080, D110, D438, D450, D452, D458, D514 and D516
D044, D045, D222, D453, D454, D455 D506 and D528
D041, D045, D052, D171, D222, D225, D227, D438, D443,
D453, D454, D458, D472, D475, D476, D479, D514, D516
and D523
D044, D251 and D457
D465 and D525
D115 and D176
D080, D115, D176, D450, D472, D523 and D524
D044, D110, D115, D176, D222, D437, D455, D525 and
D528
Page 25 of 39
0235 AD AGGREG 0005 01
D044, D045, D453, D454 and D525

37 Fire Protection ADs that credit Operator or ERT action
Pressure D360, D361
Boundary D367, D392 and D393
Seismic D014, D285, D299, D414, D415 and D499
Page 26 of 39
0235 AD AGGREG 0005 01
Special Safety SDS

Systems D021 and D022
D060, D305 and D310
D245 and D310
D245 and D306
D306 and D310
ECI
D061 and D306
D306 and D307
Containment
D061 and D306
D306 and D307
D306 and D309
D302, D308 and D309
D010, D014, D015, D017, D018, D071, D159, D309, D357
and D607
D010, D014, D017, D018, D071, D159 and D3579
SDS, ECI, Containment

D245, D302 and D307
D306 and D310
D061, D245, D306 and D310
D010, D014, D017, D018, D021, D022, D071, D159 and
D357
D015 and D029
D014, D060 and D305
D060, D305, D306 and D310
D032 and D071
D245, D306 and D307
D071 and D607
9
This group of ADs is a subset of the ten shown above these seven. Therefore, the aggregate impact of this group is
already addressed by those ten ADs.
Page 27 of 39
0235 AD AGGREG 0005 01
4 Determination of Aggregate Impact of Each Group of Acceptable

Deviations
The SMEs assessed each group of Acceptable Deviations to identify any potential
aggregate impact on public safety. If there was any impact, the SMEs assessed
further to identify any plant defence-in-depth and plant strengths that would mitigate
the identified impact.
Below is an illustrative example of the results from the SME reviews of the
Acceptable Deviations (ADs) to determine any synergy between the ADs and
assess their impact:
Among the 16 ADs related to Shutdown Systems (SDSs), ADs D021 and D022
deal with the SDS2 LISS nozzles material handling and NDE requirements
during procurement and construction. The issues are on the same component,
i.e. LISS nozzles and the technical justification used to assess the AD is also
shared, i.e. the presence of an Aging Management Plan used to assure
continued fitness for service.
Both issues independently have some limited potential to lead to material

degradation. However, the assessments performed for each concluded that the
likelihood of these issues affecting LISS nozzle material strength was very low
and therefore each posed a safety significance of 4, i.e. the lowest on the scale.
The effectiveness of the primary barriers in place, i.e. the aging management
plan and system chemistry control are not challenged given the two issues
together. Having a robust Reactor Components & Structures Life Cycle
Management Plan addressing relevant aging mechanisms, assures fitness for
service of these components for life extension of the Darlington units.
The interaction assessment concluded that the aggregate impact from each of the
46 groups of Acceptable Deviations was either negligible or nil, or any non-
negligible aggregate impact was mitigated by existing plant provisions such that any
residual aggregate impact was negligible or nil.
Therefore, the aggregate assessment did not identify any impact on public safety,
nor identify any practical risk reduction opportunities.
Examination by inspection of the remaining 17 barriers determined that there was

negligible or no aggregate impact from the associated Acceptable Deviations.
Page 28 of 39
0235 AD AGGREG 0005 01
5 Resolution of Grouped Acceptable Deviations with Residual Aggregate

Impact
There was no grouped Acceptable Deviations required to be resolved in accordance
with the Gap Resolution Process NK38-INS-00770-10004 [R-6].
4 Conclusion
An assessment of the 208 ISR Acceptable Deviations was performed to determine if
there were any aggregate effects between them and if any identified effect required
a practical remedial action. The assessment was performed using symptom
classification (i.e. symptom binning), barrier analysis techniques and judgment. The
Acceptable Deviations were judged to be associated with one or more of the 25
barriers. Of these, eight (8) barriers related to the Control, Cool and Contain (CCC)
functions and Accident Management, were considered to be potentially significant to
public safety. A total of 183 Acceptable Deviations associated with these eight (8)
barriers were subject to assessment to identify any aggregate effect between them.
A total of 95 Acceptable Deviations were associated with the remaining 17 (non-

significant) barriers. In most cases these were also associated with the eight
significant barriers. These 95 were assessed by inspection using judgment. Only
two (2) of the 208 Acceptable Deviations were judged to be not associated with any
of the 25 barriers.
The assessment concluded that the aggregate impact from each of the 46 groups of
Acceptable Deviations was either negligible or nil, or any non-negligible aggregate
impact was mitigated by existing plant provisions such that any residual aggregate
impact was negligible or nil.
Therefore, the aggregate assessment did not identify any impact on public safety,
nor identify any practical risk reduction opportunities.
Page 29 of 39
0235 AD AGGREG 0005 01
5 References
[R-1] CNSC Regulatory Document, RD-360, Life Extension of Nuclear Power
Plants, February 2008
[R-2] CPUS Report, 0235-Darlington NGS-GAR R00, DARLINGTON NGS

Global Assessment Report (GAR), September 2013.
[R-3] OPG Report, NK38-REP-03680-10104 Rev 000, Darlington NGS ISR Final
ISR Report, October 2011.
[R-4] OSART Guidelines, IAEA Operational Safety Review Team, 2005.
[R-5] WANO Report, WANO Performance Objectives and Criteria, Revision 3,

January 2005.
[R-6] OPG Instruction, N-INS-00770-10004 R001, Nuclear Refurbishment Gap

Resolution Process Darlington, April 2011.
[R-7] OPG Procedure, N-PROC-LE-0005 R003, Nuclear Refurbishment

Integrated Safety Review Darlington, April 2013.
[R-8] OPG Procedure, N-PROC-LE-0007 R002, Nuclear Refurbishment Global

Assessment Report and Integrated Implementation Plan, Darlington,
September 2012.
[R-9] CPUS Report, 0235-AD-AGGREG-0001 R01, Evaluation of Seismic,

Pressure Boundary and Accident Management ISR Acceptable Deviation
Issues for Aggregate Effects between Issues, May 2014.
[R-10] CPUS Report, 0235-AD-AGGREG-0002 R00, Evaluation of Human

Performance ISR Acceptable Deviation Issues for Aggregate Effects
between Issues, September 2013.
[R-11] CPUS Report, 0235-AD-AGGREG-0003 R01, Evaluation of Special Safety

Systems ISR Acceptable Deviation Issues for Aggregate Effects between
Issues, May 2014.
[R-12] CPUS Report. 0235-ISR-ADEQUA-0001, ISR Open Issues and Acceptable

Deviations Adequacy Review, May 2014.
[R-13] OPG Procedure, N-CMT-15345-00001 R006, Cause Analysis, November

2012.
Page 30 of 39
0235 AD AGGREG 0005 01
[R-14] CPUS Report, 0235-AD-AGGREG-0004 R01, Evaluation of Darlington NGS

Fire Protection ISR Acceptable Deviation Issues for Aggregate Effects of
Combinations of the Gaps, May 2014.
[R-15] CPUS Report, Darlington Global Assessment Acceptable Deviation

Analysis, 0235-GAR-AD-REVIEW-R00, June 25, 2013.

Safety Review Emerging Issues Report, February 2014.
Page 31 of 39
0235 AD AGGREG 0005 01
Appendix A Instructions to Guide Subject Matter Experts

Review
1. Obtain Acceptable Deviation (AD) Forms describing all of the ADs that have been
identified as having a possible impact on the barrier (component, system, or
program) you are assessing.
2. Obtain copies of all codes and standards referenced in the AD forms.
3. Determine how many gaps are identified on each AD form.
4. For each gap, determine which sub-system(s) or sub-program(s) is potentially

impacted by each of the gaps. For example:
Does a training program gap impact all training programs, or is it restricted to
one area such as radiation training or operator training?
Does a pressure boundary gap impact on all pressure boundary components,
or is it restricted to one area such as heat exchangers or relief valves?
Does a containment system gap impact all containment sub-systems or is it
restricted to one area such as the dousing system or EFADS?
5. For each gap, make a judgment about the significance of the gaps identified on
the AD form. For example:
Does the gap have any impact on performance (particularly nuclear safety
related performance and public risk)?
Is the requirement in the modern or standard fully met or exceeded by
alternate means?
Is the gap related to a lack of documented evidence when there is high
confidence that performance will not be affected?
Is the gap purely administrative and will be resolved by actions currently in
progress?
If performance can be negatively affected, how significant would you rate the
impact on a Scale of 1 to 10 (minimal =1, moderate=5, major=10)? If the gap
has been previously assessed as an Acceptable Deviation, the significance
level should be low on this scale.
6. Complete steps 1 and 2 for all the gaps that appear on AD forms for this specific
barrier (component, system, or program).
7. Clearly identify gaps that do not have an impact on performance and document
the rationale.
Page 32 of 39
0235 AD AGGREG 0005 01
8. For those gaps that can potentially impact performance, identify items that can
only affect specific part of the barrier (i.e. sub-system or sub-program).
9. Determine if there is any strength associated with this barrier that could
counteract the negative impact of the gaps.
10. Apply subject matter expertise to identify any weaknesses in the barrier that
should be addressed to ensure safe operation for the extended life of the station.
Consider the cumulative impact, i.e., aggregate effect, of all the gaps that can
have an impact on safety performance and consider if these gaps are focused in
specific sub-systems or sub-programs. Prepare a summary report that describes:
which gaps were considered
which gaps do not impact performance
the significance of each gap that impacts performance
the sub-program or sub-system that each gap affects
any weaknesses in the barrier that should be addressed
which strengths were considered and did they counteract gaps
the documentation of the assessment of aggregate effects of the Ads
Page 33 of 39
0235 AD AGGREG 0005 01
Appendix B Barriers Assigned to Emerging Acceptable

Deviations
Reference 16 was produced to document emerging ISR issues. The Emerging Issues
Report is required to identify and address any new revisions to the Darlington ISR Basis
Codes and any new significant industry operating experience (OPEX). It identified an
additional 40 Acceptable Deviations to be addressed in the aggregate assessment.
However, seven of these were already addressed in Rev 00 of this report10. Also, 29
additional Fire Protection ADs were incorporated into the aggregate assessments. This
appendix documents the barriers assigned to each of the remaining 62 ADs.
For these new ADs, the barrier assignment methodology followed the same approach
used in Reference 15. The results are shown in Table B-1.
Table B-1
Barrier Assignment for the 62 New Acceptable Deviations
Issue Title Barriers Selected
D045 Special Fire Suppression System Fire Protection

Requirements Accident Management
D048 Fire Protection Requirements for Storage Fire Protection

Tanks Electrical Systems
Standby Power
D080 Fire Separation Fire Protection

Structures
D115 Fire Protection for Laboratories Fire Protection

Training
D116 Fire Protection Requirements for Building Fire Protection

Materials
10
Two of these seven ADs, i.e. D306 and D307 are not new at all, as these same AD numbers were included previously.
The other five ADs have been designated new AD numbers, as they arose from different code reviews and are included in
Table B-1.
Page 34 of 39
0235 AD AGGREG 0005 01
D181 Fire Safety Training Requirements Fire Protection

Training
D215 Fire Department Connections to Fire Mains Fire Protection
D225 Fire Protection Water Supply Fire Protection

Emergency Heat Sink
Training
D226 Control Room Complex Fire Protection Fire Protection

Accident Management
D227 Fire Hydrant Requirement Fire Protection
D251 Fire Protection Requirements for Air- Fire Protection

Cleaning Units HVAC
Environmental Protection
D327 Post-Accident Monitoring Availability Accident Management

D329 SSS Design Accident Management

D417 ANI and/or CNSC does not approve Pressure Boundary

procedures as required by N285.4-09 UPD2 Periodic Inspection Program
D429 Fire Separations Corrective Actions Fire Protection
D439 Fire Protection of Charcoal Filters Fire Protection
D445 Combustible Insulation Fire Protection
D446 Combustible Material in Ducts Fire Protection
D452 Spatial Separation and Exposed Building Fire Protection

Face Structures
D461 Means of Egress Fire Protection

Accident Management
D464 Signage Requirements Fire Protection

Accident Management
D466 Elevator Hoistway and Machine Room Fire Protection

Requirements Employee Health and Safety
Page 35 of 39
0235 AD AGGREG 0005 01
D472 Oil Storage Tank and Piping Requirements Fire Protection

Accident Management
Standby Power
Emergency Heat Sink
D473 Documentation Fire Protection

D475 Valves Controlling Water Supplies Fire Protection
D476 Underground Pipe Fire Protection
D477 Size of Bypass Fire Protection
D479 Fire Pump Disconnecting Means Fire Protection
D482 Monitoring of Fire Pump Alternate Power Fire Protection

Source Electrical Systems
D499 Seismic Hazards in Site Evaluation for Seismic

Nuclear Installations Structures
D506 Control of the Fire Alarm System Fire Protection

Accident Management
Training
D507 Automatic and Manual Water-Based Fire Fire Protection

Suppression Systems Accident Management
Electrical Systems
D509 Thread Specifications on Drawings Fire Protection
D510 Valves Controller Water Supplies Fire Protection
D511 Connections Between Sectional Valves Fire Protection
D512 Information Indicated on Plans Fire Protection
D513 Fire Pump Nameplates Fire Protection
D514 Enclosed Passageways Fire Protection

Accident Management
Structures
D515 Hose Valve Thread Requirement Fire Protection
Page 36 of 39
0235 AD AGGREG 0005 01
D516 Packaged and Prefabricated Fire Pump Fire Protection

Assembly Requirements
D517 Electrical Protections and Requirements for Fire Protection

Fire Pump Systems
D519 Fire Protection and Life Safety System Fire Protection

Commissioning Accident Management
D520 Operation and Maintenance of Industrial Fire Protection

Trucks
D522 Tank Storage of Combustible Liquids Fire Protection

Accident Management
Standby Power
Emergency Heat Sink
D523 Piping System Requirements Fire Protection

Accident Management
Standby Power
Emergency Heat Sink
D524 Fire and Smoke Characteristics of Electrical Fire Protection

Wires and Cables Accident Management
Testing Programs
D525 Elevator Requirements Fire Protection

D526 Electronic Supervision of Water Supply Fire Protection

Valves
D527 Entrance Walkway Smoke Detector Fire Protection

Accident Management
Training
D528 Voice Communication Systems Fire Protection

Accident Management
D529 Electrical Conductors for Fire Protection Fire Protection

Systems
Page 37 of 39
0235 AD AGGREG 0005 01
D530 Exit Signage Fire Protection

Accident Management
Training
D564 DNGS Governance Documents and PIP Pressure Boundary

Plans Reference Previous Edition of Code Periodic Inspection Program Special
Safety Systems
D607 Severe Accident and Beyond Design Basis Special Safety Systems
Accident (BDBA) Design/SAMG
D608 Human Factors Design Accident Management

Human Performance
D609 DNGS Governance Documents and PIP Pressure Boundary

Plans Reference Previous Edition of Code Periodic Inspection Program
Structures
D613 Containment Boundary Leakage Special Safety Systems
D614 DNGS Governance Documents and the Pressure Boundary

Pressure Boundary Program Manual
Reference Previous Edition of Code
D615 OPG Pressure Boundary Program Document Pressure Boundary
Page 38 of 39
0235 AD AGGREG 0005 01
The number of new ADs assigned to each of the significant barriers is:
Special Safety Systems 6

Accident Management 18
Pressure Boundary 4
Seismic 1
Fire Protection 51
Human Performance 1
For these significant barriers, the pertinent new ADs are included in a revision to the
report in that area. The only exception is for the Human Performance area. D608 is the
only new AD associated with the Human Performance barrier. However, D608 is the
same issue as D040, which is already addressed in the Human Performance (HP)
aggregate assessment. Therefore, a revision to the HP report was not required.
Page 39 of 39
ONTARIOFiiiiiER Report
Document Number:
NK38-REP-03680-10201
N/A
N/A R001
IIS:R OPEN ISSUES AND ACCEPTABLE DEVIATIONS - ADEQUACY REVIEW
purposes only. No part of this document may be reproduced, published, converted , or stored in any data retrieval system , or
transmitted in any form or by any means (electronic, mechanical, photocopying , recording, or otherwise) without the prior written
ISR Open Issues and Acceptable

Deviations - Adequacy Review
NK38-REP-03680-10201-R001
Accepted by: _---r+--i~-..;,.---C'/

=->:c.::,. ./.
..<...:..........;.
-2,---'=;J- /t--'Authorized by:
ae Date iaz Malek
Manager, irector, Nuclear Safety
0235 ISR ADEQUA 0001 01

Title:ISR Open Issues and Acceptable Deviations Adequacy Review
Caution: This report contains more than 8000 pages. When a paper copy
is required, please set printer settings carefully to print only required
section(s).

P. Wiebe Date

R. Arora Date

VP Engineering, CPUS Ltd.
Page 1 of 8514
0235 ISR ADEQUA 0001 01

Record of Revisions
Rev Date Description Prepared by Reviewed by Approved
No. by
00 2013 10 31 Issued for Use T.J. (Ravi) K.C. Garel M. Jansen
Ravishankar
01 2014 05 26 Revised to include Emerging P. Wiebe R. Arora M. Jansen
Issues Report [R-5] Results:
- 15 ISR Issues
containing gaps
requiring resolution
were reviewed for
adequacy and added to
Appendix A
- 62 ISR Issues
containing gaps
classified as acceptable
deviations were
assessed and added to
Appendix B
rd
This document is the property of CPUS Limited and OPG. This document may be distributed by OPG to a 3 party
Page 2 of 8514
0235 ISR ADEQUA 0001 01

SUMMARY
The acceptance criteria for the Global Assessment Report (GAR) defined in section
6.4 of CNSC Regulatory Document RD-360 [R-1] include the following criterion:
The adequacy of proposed corrective actions and safety improvements, or
justification of proposed exemptions.
In the context of Darlington NGS GAR, corrective actions and safety improvements,
hereafter referred to as safety improvements, are associated with Integrated Safety
Review (ISR) [R-2], [R-5] Open Issues. They are the practical remedial actions that,
when fully implemented, will close the associated gaps assessed against modern
codes and standards. And, the proposed exemptions are called Acceptable
Deviations (ADs) [R-2], [R-5].
A systematic approach was undertaken to confirm the adequacy of the safety

improvements associated with 110 ISR Open Issues and their proposed
implementation schedule. The review confirmed that with a few exceptions the safety
improvements identified in the resolutions to the ISR Issues were appropriately
developed and, when implemented, the safety improvements will bring Darlington
NGS into a higher degree of compliance with the requirements of the clauses against
which the constituent ISR Gaps were originally assessed. For the few exceptions,
minor changes were made to the planned safety improvements to ensure the specific
requirements of each of the ISR Gaps within an ISR Issue have been fully addressed.
A systematic approach was undertaken to confirm the justification of the 208 ISR
Acceptable Deviations. The adequacy review of the ISR Acceptable Deviations found
that the rationale provided in the resolution of these ISR Issues support their
assessment as Acceptable Deviations.
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Table of Contents
SUMMARY ........................................................................................................................ 3
1. Introduction ............................................................................................................... 5
2. Methodology .............................................................................................................. 5
3. Results ...................................................................................................................... 6
4. Conclusion ................................................................................................................ 7
5. References ................................................................................................................ 8
APPENDIX A - ISR Open Issues and Resolutions ........................................................... 9
APPENDIX B - ISR Acceptable Deviations and Rationale.......................................... 7172
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1. Introduction
The acceptance criteria for the Global Assessment Report (GAR) defined in section
6.4 of CNSC Regulatory Document RD-360 [R-1] include the following:
The adequacy of proposed corrective actions and safety improvements, or
justification of proposed exemptions.
In the context of Darlington NGS GAR, corrective actions and safety improvements,
hereafter referred to as safety improvements, are associated with Integrated Safety
Review (ISR) [R-2], [R-5] Open Issues. They are the practical remedial actions that,
when fully implemented, will close the associated gaps assessed against modern
codes and standards. And, the proposed exemptions are called Acceptable
Deviations (ADs) [R-2], [R-5].
This report documents the reviews undertaken to confirm:

the adequacy of the safety improvements, and,
if the classification of ISR Issues as Acceptable Deviations is sufficiently
supported by the justifications provided.
2. Methodology
The purpose of the adequacy assessment is to assess:
1. If the planned safety improvements (resolutions) would fully address the gaps
identified in the ISR Open Issues
2. If the justifications provided sufficiently support the classification of the ISR Issue
as ISR Acceptable Deviations
The following outlines the methodology used in performing the adequacy assessment
for the ISR Open Issues and Acceptable Deviations documented in this report.
ISR Open Issues

The steps and methodology adopted to assess the adequacy of the scope of the
planned Safety Improvements that address ISR Open Issues are as follows:
a) Confirm that all the ISR Gaps have been evaluated and included in the ISR
Issues.
b) Confirm that the Safety Significance Ranking and Prioritization of ISR Issues
have been completed.
Safety Significance is determined by priority definitions and risk assessment
criteria in accordance with Issue Prioritization Process N-INS-00770-10005
[R-4]. The significant levels have a direct correlation with impact on nuclear
safety:
1 = High
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0235 ISR ADEQUA 0001 01

2 = Medium
3 = Low
4 = Very Low
c) Confirm that the resolutions for Open Issues have been prepared and
approved.
d) Confirm that the resolutions fully address the requirements of the clauses in
modern codes and standards against which the ISR Gaps were originally
raised. This includes obtaining any revisions to the resolutions to ensure they
fully address the requirements of the clauses in modern codes and standards.
Acceptable Deviations
The steps and methodology adopted to assess the adequacy of the scope of the
planned Safety Improvements that address ISR Acceptable Deviations are as follows:
a) Confirm that all the ISR Gaps have been evaluated and included in the ISR
Issues.
b) Confirm that the Safety Significance Ranking and Prioritization of ISR Issues
have been completed.
Safety Significance is determined by priority definitions and risk assessment
criteria in accordance with Issue Prioritization Process N-INS-00770-10005
[R-4]. The significant levels have a direct correlation with impact on nuclear
safety:
1 = High
2 = Medium
3 = Low
4 = Very Low
c) Confirm that the rationale for ISR Acceptable Deviations have been prepared
and approved.
d) Confirm that the resolutions fully support the assessment of the Issue being
an Acceptable Deviation. Where the resolutions do not fully support the
Acceptable Deviation classification, this includes:
i) requesting necessary changes to the resolutions to ensure they fully
support the Acceptable Deviation classification; and,
ii) identifying if the issue needs to be reclassified as Open or Closed and
requesting the necessary change
3. Results
ISR Open Issues
The adequacy of the planned Safety Improvements to address the ISR Open Issues
confirmed that with a few exceptions the safety improvements identified in the
resolutions to the ISR Issues were appropriately developed and, when implemented,
the safety improvements will bring Darlington NGS into a higher degree of compliance
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0235 ISR ADEQUA 0001 01

with the requirements of the clauses against which the constituent ISR Gaps were
originally assessed. For the few exceptions, minor changes were made to the
planned safety improvements to ensure the specific requirements of each of the ISR
Gaps within an ISR Issue have been fully addressed.
Appendix A includes the 110 ISR Open Issues and the safety improvements to
address the gaps in these issues, as recorded in the Darlington Gap Management
database as of February 7, 2014.
Acceptable Deviations
The rationale provided for the 208 ISR issues that were classified as Acceptable
Deviations, were judged to sufficiently support the assessment.
Appendix B includes the 208 Acceptable Deviations and the resolutions supporting
their assessment, as recorded in the Darlington Gap Management database as of
February 7, 2014.
4. Conclusion
A systematic approach was followed to ascertain the adequacy of the safety
improvements provided for the 110 ISR Open Issues. It was concluded that the
safety improvements would adequately remedy the gaps so that when the remedial
actions are fully implemented, Darlington NGS will meet the requirements of the
modern codes and standards against which the gaps were originally assessed.
The adequacy review of the 208 ISR Acceptable Deviations found that the rationale
provided in the resolution of these ISR Issues support their assessment as
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5. References
[R-1] CNSC Regulatory Document, RD-360, Life Extension of Nuclear Power
Plants, February 2008.
[R-2] NK38-REP-03680-10104 Rev 000 Darlington NGS ISR Final ISR Report
Addendum 002, 2013 11 21.
[R-3] N-CORR-00531-05970, OPG Letter, W.M. Elliott to M. Santini and P.A.

Webster, OPG RD-310 Implementation Plans - Action Item 2010OPG-05,
December 10, 2012.
[R-4] N-PROC-LE-0005 Rev 003, Nuclear Refurbishment Integrated Safety

Review - Darlington, April 2013.
[R-5] OPG Report, Darlington NGS Integrated Safety Review Emerging Issues
Report, NK38-REP-03680-10207R000, February 18, 2014.
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APPENDIX A - ISR Open Issues and Resolutions
Issue Issue Title General Description Overall Related Related Gap Accepted Resolution Resolution Update References
# Safety Gap # Title
Significance
D011 Changes to In- OVERVIEW 3 1470 Surveillance of Preferred Resolution: Verify compliance Gap 00805 Identifies that the Darlington [R-1] NK38-REP-03680-10061,
service Civil with CAN/CSA-N287.7-08 [R-2]. Ensure NGS program for inspection of the Review Of CAN/CSA-N287.7-
Examination and This ISR Issue consists of three (3) ISR Structures that resolution of any gaps is appropriate for Emergency Water Storage Tank (EWST) 08 (May 2008) In-Service
Testing Gaps from NK38-REP-03680-10061, refurbishment, including requirements for and Irradiated Fuel Bay (IFB) does not Examination and Testing
Requirements for Review of CAN/CSA-N287.7-08 (May containment structure positive pressure leak currently meet the requirements of Clause Requirements for Concrete
Concrete 2008) In-Service Examination and Testing tests and inspection of IFB interior surfaces. 6.1.8.2 of CAN/CSA-N287.7-08 [R-1]. Containment Structures for
Containment Requirements for Concrete Containment Rationale for Selection: The preferred Resolution: NK38-IR-0-03643.3-10002 [R-2] CANDU Nuclear Power Plants
Structures Structures for CANDU Nuclear Power resolution takes advantage of ongoing work identifies that the EWST is drained and for Darlington Integrated Safety
Plants for Darlington Integrated Safety (AI #20081311) to ensure compliance with inspected as part of the periodic inspection Review.
Review" [R-1] and one (1) Gap from NK38- CAN/CSA-N287.7-08 [R-2]. A review must of the interior concrete containment of the [R-2] CAN/CSA-N287.7-08, In-
REP-03680-10109, "Review of CNSC RD- be completed to ensure that resolution of AI DNGS Vacuum Building, if required. The service examination and testing
337 (September 2008), Design of New #20081311 is appropriate for extended life clause 6.1.9 states that the draining of requirements for concrete
Nuclear Power Plants for Darlington of Darlington NGS including inspection of EWST is not required subject to certain containment structures for
Integrated Safety Review" [R-11]. IFB interior surfaces. Requirements for conditions. N-CORR-03643.2-0387284 [R- CANDU Nuclear power plants,
containment structure positive pressure leak 11] communicates this requirement of May 2008.
The scope of this ISR Issue covers tests must be confirmed to address the draining of EWST to station and is part of [R-3] NK38-REP-34200-10009
requirements for inspection and monitoring requirements of CAN/CSA-N287.7-08 [R-2]. containment inspection PIPs. R000, Darlington Nuclear-2009
of concrete containment structures. As per CAN/CSA N287.1-93 [R-3] it is Main Containment Leakage
DISCUSSION implied that containment is the area where Rate Test Requirements.
Clause 6.1.8.2 of CAN/CSA-N287.7-08, In- The significance of the gaps included in this reactor process systems are. IFB is not a [R-4] N-PROC-MA-0066 R003,
service examination and testing issue are considered low based on: reactor process system, hence it does not Administrative Requirements
requirements for concrete containment NK38-IR-0-03643.3-10002 [R-8] identifies qualify as concrete containment system, for In-Service Examination and
structures for CANDU Nuclear power that the Emergency Water Storage Tank is thus does not require CAN/CSA N287.7-08 Testing for Concrete
plants [R-2], applies to the Emergency drained and inspected as part of the [R-1] inspections. NK38-DM-21500-2 [R-4] Containment Structures.
Water Storage Tank (EWST) in the periodic inspection of the interior concrete does not pose any CAN/CSA N287.7-08 [R- [R-5] CAN/CSA-N287.7-96 In-
Dousing System and the Irradiated Fuel containment of the DNGS Vacuum Building. 1] inspection requirements. Service Examination and
Bay (IFB). Use of Remote Operating This meets the requirements of Clause Hence DNGS meets the requirements of Testing Requirements for
Vehicles (ROVs) and/or divers with imaging 6.1.8.2 of CAN/CSA-N287.7-08 [R-2]. clause 6.1.8.2 of CAN/CSA-N287.7-08 [R-1] Concrete Containment
equipment is required to provide images of and no further action is required. Structures for CANDU Nuclear
the wet side of the containment structure. NK38-DM-21500-2 [R-9] identifies that the Power Plants, July 1996.
The clarity and resolution of the design of the Irradiated Fuel Bay (IFB) Gap 00806 clause 7.13 of CAN/CSA- [R-6] NK38-REP-26100-10001
photographic images must be acceptable to includes a stainless steel liner and a means N287.7-08 [R-1] requires deformation of the R000, Justification to Conduct
the engineer. A detailed inspection and test of intercepting leakage. Any leakage containment structure be monitored during Vacuum Structure Leakage
plan must be presented to the regulatory through the liner is trapped and drained to positive pressure testing to verify elastic tests at Negative Pressures
authority for acceptance. Where the sumps for collection and monitoring. behaviour of the containment structure. only During Future Vacuum
conditions specified in Clause 6.1.8.1 of Resolution: In-accordance with non- Structure Outages at Darlington
CAN/CSA-N287.7-08 [R-2] cannot be met, NK38-REP-26100-10001 [R-6] was mandatory Appendix F of CSA N287.7-08, Nuclear.
an inspection of the containment structure prepared to justify exempting vacuum this clause relates to stations which have [R-7] NK38-CORR-00531-
shall be performed with the structure retaining containment structures from instrumented monitoring installed for 14670 R000, Darlington NGS
drained. Gap 00805 identifies that the positive pressure testing, in accordance measurements of pre-stress losses, A Vacuum Structure Positive
Darlington NGS program for inspection of with Clause 7.4 of CAN/CSA-N287.7-08 [R- deformation of structures. DNGS does not Pressure Test Action Item
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This document is the property of CPUS Limited and OPG. This document may be distributed by OPG to a 3 party (including but not limited to the CNSC) for the purposes of validating the work including a review of the estimate, costs, scheduling and technical components. Expressed written agreement
from CPUS Limited or OPG is required for any other distribution or transfer.
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Significance
the EWST and IFB does not currently meet 2]. If positive pressure testing is not have instrumented monitoring installed on 20081311.
the requirements of Clause 6.1.8.2 of required, the requirements of Clause 7.13 of its containment and does not need to [R-8] NK38-IR-0-03643.3-
CAN/CSA-N287.7-08 [R-2]. CAN/CSA-N287.7-08 [R-2] for deformation comply with Appendix F. Further this 10002 R000, Inspection Report
measurements do not apply. However, the Appendix F has not been imposed as a For DNGS Vacuum Building
Clause 7.13 of CAN/CSA-N287.7-08 [R-2] CNSC has not accepted OPGs request. In mandatory requirement, as per licence Interior Concrete Containment
requires deformation of the containment addition, the majority of the containment requirements. DNGS complies with 2009 (to The Requirements Of
structure should be monitored during structure will still be subject to positive Appendix B for monitoring of pre-stress Standard CAN/CSA-N287.7-
positive pressure testing to verify elastic pressure testing, which may require losses. No further action is required. 96).
behaviour of the containment structure. deformation measurements. [R-9] NK38-DM-21500-2 R006,
Gap 00806 identifies that NK38-REP- Gap 01239 - is a Tracked Item related to Irradiated Fuel Bay Consisting
34200-10009, Darlington Nuclear-2009 OPG has a plan to become fully compliant CNSC Action Item # 20081311. This Action Of Irradiated Fuel Reception
Main Containment Leakage Rate Test with CAN/CSA-N287.7-08 [R-2]. This plan Item relates to an attempt to exempt the Bay Structure Irradiated Fuel
Requirements [R-3], does not require was communicated to the CNSC in NK38- Vacuum Structure from positive pressure Storage Bay Structure And Wet
deformation measurements. CORR-00531-14670 [R-7]. New tests testing. Cask Handling Bay Structure.
required by CAN/CSA N287.7-08 [R-2] will Resolution: This gap stems from a non- [R-10] NK38-PIP-03643.2-
Action Item (AI) #20081311 relates to an be performed when the necessary revisions mandatory Appendix E of CSA N287.7-08. 10002 R002, Darlington
attempt to exempt the Vacuum Structure to Darlington governance document have As background OPG is seeking adoption to Nuclear - Unit 0 Containment
from positive pressure testing. Gap 01239 been completed. N-PROC-MA-0066 [R-4] this non mandatory appendix in order to Periodic Inspection Program.
is a Tracked Item related to Action Item provides the administrative process for relate Vacuum Building Outage frequency [R-11] NK38-REP-03680-
#20081311. A justification for exempting conducting in-service inspections and based on VB performance. Currently VB 10109, "Review of CNSC RD-
the Vacuum Structure from positive leakage rate tests of concrete containment inspection frequency is a fixed time period, 337 (September 2008), Design
pressure testing in compliance with structures. Revision of this governance i.e. every 12 years. There are of New Nuclear Power Plants
CAN/CSA-N287.7-08 [R-2], supplemented document will ensure that preparation and communications between CNSC and OPG for Darlington Integrated Safety
by using existing and additional test results revision of inspection program plans and on how to adopt this appendix. Review".
from non-destructive examinations/tests, test specifications are in accordance with Nevertheless for the purpose of the ISR this [R-12] CNSC RD-337, Design
has been developed under the Action Item. CAN/CSA-N287.7-08 [R-2]. Compliance is a non-mandatory appendix and of New Nuclear Power Plants,
with CAN/CSA N287.7-08 [R-2] is being compliance to this appendix is not September 2008.
Clause 7.15.2 of CNSC RD-337 [R-12] tracked by AI# 20081311. mandated by regulator. Hence this is not a
provides a list of requirements for design to gap.
facilitate inspection of civil structures. Gap The containment pressure test requirement
01470 states that DNGS is not fully documents are not to be updated as part of Gap 01470 - Clause 7.15.2 of CNSC RD-
compliant with the requirements of AI 20081311. They will be updated as 337 [R-9] provides requirements for ongoing
CAN/CSA-N287.7-08 [R-2] based on the required to meet the test schedule. surveillance activities for civil structures.
Gaps identified in NK38-REP-03680-10061 Compliance with CAN/CSA-N287.7-08 [R-2] DNGS has implemented CSA N287.7
[R-1] (discussed above). cannot be verified until these documents periodic inspection program. However
are prepared and submitted to the CNSC. periodic inspections are not fully compliant
GAP SUMMARY based on the gaps identified in [R-10].
All Gaps included in this Issue relate to Periodic inspection of the IFB in accordance Resolution: Clause 7.15.2 of [R-9] does not
compliance with requirements of CAN/CSA- with NK38-PIP-03643.2-10002, Darlington mention a compliance with CSA N287.7-08.
N287.7-08 [R-2]. Gap 00805 identifies that Nuclear - Unit 0 Containment Periodic Based on the resolutions provided above
the PIP for Concrete Containment Inspection Program [R-10], do not include DNGS is in compliance with CSA N287.7-
Structures does not currently meet the the stainless steel liner. Underwater 08. However minor updates are being
requirements of Clause 6.1.8.2 for inspections of the IFB stainless steel liner performed to the stations periodic
inspection of the water side of the EWST may be required. inspection plan documents [R-5], [R-6], [R-
and IFB. Gap 00806 identifies that NK38- 7], and [R-12]. A new high level document
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REP-34200-10009, Darlington Nuclear- Verification of compliance with CAN/CSA- for leakage rate testing is also being
2009 Main Containment Leakage Rate Test N287.7-08 [R-2] with regard to positive prepared by OPG. This was communicated
Requirements [R-3], does not require pressure testing and IFB inspections will by OPG to the CNSC through NK38-CORR-
deformation measurements in accordance ensure that resolution of any gaps is 00531-15422 [R-8] and tracked under
with Clause 7.13 of CAN/CSA-N287.7-08 appropriate for refurbishment. AR#28125207. These documents
[R-2]. Gap 01239 is a tracked item related submission are scheduled for February
to exemption of the Vacuum Structure from 25th, 2015. In the interim, regulator has
positive pressure testing. allowed use of 96 version of CSA N287.7.
The submission of these documents
including the updated Periodic Inspection
Programs for Concrete Containment
Structures will ensure compliance with the
requirements identified in ISR Gap 01470.
The Integrated Implementation Plan (IIP)
will track this submission to completion and
the milestone for completion will be
provided in the IIP for the life extension of
the DNGS.
D011 Changes to In- OVERVIEW 3 806 Measurement Preferred Resolution: Verify compliance Gap 00805 Identifies that the Darlington [R-1] NK38-REP-03680-10061,
service s to Confirm with CAN/CSA-N287.7-08 [R-2]. Ensure NGS program for inspection of the Review Of CAN/CSA-N287.7-
Examination and This ISR Issue consists of three (3) ISR Elastic that resolution of any gaps is appropriate for Emergency Water Storage Tank (EWST) 08 (May 2008) In-Service
Testing Gaps from NK38-REP-03680-10061, Behaviour of refurbishment, including requirements for and Irradiated Fuel Bay (IFB) does not Examination and Testing
Requirements for Review of CAN/CSA-N287.7-08 (May Concrete containment structure positive pressure leak currently meet the requirements of Clause Requirements for Concrete
Concrete 2008) In-Service Examination and Testing Containment tests and inspection of IFB interior surfaces. 6.1.8.2 of CAN/CSA-N287.7-08 [R-1]. Containment Structures for
Containment Requirements for Concrete Containment Structure Rationale for Selection: The preferred Resolution: NK38-IR-0-03643.3-10002 [R-2] CANDU Nuclear Power Plants
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the DNGS.
D011 Changes to In- OVERVIEW 3 1239 Darlington Preferred Resolution: Verify compliance Gap 00805 Identifies that the Darlington [R-1] NK38-REP-03680-10061,
service NGS A - with CAN/CSA-N287.7-08 [R-2]. Ensure NGS program for inspection of the Review Of CAN/CSA-N287.7-
Examination and This ISR Issue consists of three (3) ISR Vacuum that resolution of any gaps is appropriate for Emergency Water Storage Tank (EWST) 08 (May 2008) In-Service
Testing Gaps from NK38-REP-03680-10061, Structure refurbishment, including requirements for and Irradiated Fuel Bay (IFB) does not Examination and Testing
Requirements for Review of CAN/CSA-N287.7-08 (May Positive containment structure positive pressure leak currently meet the requirements of Clause Requirements for Concrete
Concrete 2008) In-Service Examination and Testing Pressure Test tests and inspection of IFB interior surfaces. 6.1.8.2 of CAN/CSA-N287.7-08 [R-1]. Containment Structures for
Containment Requirements for Concrete Containment (AI Rationale for Selection: The preferred Resolution: NK38-IR-0-03643.3-10002 [R-2] CANDU Nuclear Power Plants
Structures Structures for CANDU Nuclear Power #20081311) resolution takes advantage of ongoing work identifies that the EWST is drained and for Darlington Integrated Safety
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the DNGS.
D011 Changes to In- OVERVIEW 3 805 Images of Wet Preferred Resolution: Verify compliance Gap 00805 Identifies that the Darlington [R-1] NK38-REP-03680-10061,
service Side of with CAN/CSA-N287.7-08 [R-2]. Ensure NGS program for inspection of the Review Of CAN/CSA-N287.7-
Examination and This ISR Issue consists of three (3) ISR Concrete that resolution of any gaps is appropriate for Emergency Water Storage Tank (EWST) 08 (May 2008) In-Service
Testing Gaps from NK38-REP-03680-10061, Containment refurbishment, including requirements for and Irradiated Fuel Bay (IFB) does not Examination and Testing
Requirements for Review of CAN/CSA-N287.7-08 (May Structure containment structure positive pressure leak currently meet the requirements of Clause Requirements for Concrete
Concrete 2008) In-Service Examination and Testing tests and inspection of IFB interior surfaces. 6.1.8.2 of CAN/CSA-N287.7-08 [R-1]. Containment Structures for
Containment Requirements for Concrete Containment Rationale for Selection: The preferred Resolution: NK38-IR-0-03643.3-10002 [R-2] CANDU Nuclear Power Plants
rd
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the DNGS.
D013 Long Term OVERVIEW 2 1244 Installation of Install PARS at Darlington using a phased Gap 00793 was declared against Clause [R-1] NK38 REP 03680-10024,
Control of PARS System approach (install in one unit, confirm 6.64 of IAEA NS-R-1 which requires: Review of IAEA NS-R-1
Hydrogen in This ISR Issue is comprised of 4 ISR Gaps (AI# acceptable performance, install in remaining Systems to control fission products, (October 2000), Safety of
Containment from: 20081308) units). hydrogen, oxygen and other substances Nuclear Power Plants: Design
that may be released into the reactor for Darlington Integrated Safety
-NK38 REP 03680-10024, Review of IAEA Based on industry research, PARS appears containment shall be provided as Review".
NS-R-1 (October 2000), Safety of Nuclear to be the only viable solution to long term necessary: [R-2] NK38-REP-03680-10109,
Power Plants: Design for Darlington Hydrogen control in containment, and is "Review of RD-337 Design of
Integrated Safety Review" [R-1] therefore the only option being considered. (1) to reduce the amount of fission products New Nuclear Power Plants for
-NK38-REP-03680-10109, "Review of RD- that might be released to the environment in Darlington Integrated Safety
337 Design of New Nuclear Power Plants Provided that PARS units are installed, design basis accidents; and Review".
for Darlington Integrated Safety Review" post-accident hydrogen build-up will be [R-3] NK38-DR-34610-10001
[R-2] adequately mitigated, based on NK38-REP- (2) to control the concentration of hydrogen, R000, Post Accident Hydrogen
03500-10013 [R-5], which states: It is oxygen and other substances in the Ignition System.
There are 2 Gaps from the review of IAEA expected that the combination of igniters containment atmosphere in design basis [R-4] N-CORR-00531-05221
NS-R-1: and PARS will limit the impact of H2 accidents in order to prevent deflagration or R000, Submission Of Pars
produced during a LOCA, and ensure that detonation which could jeopardize the Installation Schedules - Action
a) Gap 00793 requires systems to control post-LOCA H2 production does not cause integrity of the containment. Items 20081308 2008-4-09 And
fission products, hydrogen, oxygen and failure of the containment system in meeting 2008-8-09
other substances that may be released into its performance requirements. The Code Review Report, NK38-REP- [R-5] NK38-REP-03500-10013
the reactor containment to be provided as 03680-10024, found that hydrogen control R000, Darlington NGS long-
necessary. The functions of these systems As per N-CORR-00531-05161 [R-6], Full inside containment is provided by the Post- term Hydrogen Mixing
are: Release funding has already been obtained Accident Hydrogen Ignition System Assessment
for the development of PARS design and (PAHIS). However, PAHIS has a short [R-6] N-CORR-00531-05161
i) To minimize fission product levels that installation in one unit and common areas. mission time and is therefore not credited R000, Submission of Long-
may be released into the environment Provided that implementation and testing for longterm control of hydrogen, according term Hydrogen Mixing
following a design basis accident are successful, this issue will be resolved by to the design requirements in NK38-DR- Assessments And Update On
ii) To control the concentration of hydrogen, installation of PARS in the remaining units, 34610-10001, Post Accident Hydrogen PARS Installation Schedules -
oxygen, and other substances in the as committed in N-CORR-00531-05221 [R- Ignition System. Action Items 20081308 2008-4-
containment atmosphere following design 4]. 09 And 2008-8-09
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basis accidents, in order to prevent Resolution: Gap 00793 is closed for some [R-7] NK38-REP-01500-
deflagration or detonation of hydrogen, Gap 01244 will remain a tracked item for Darlington containment locations. Long term 0223244 R000, RELEVENT
which could jeopardize the integrity of the developments on PARS implementation. hydrogen mixing analysis for design basis ANALYSIS FILE FOR THE
containment envelope. Further updates are committed to the CNSC accidents was completed and added to the UPDATE OF DARA
under Action Item 20081308. 2012 Darlington Safety Report Appendix INITIATING EVENTS
The Emergency Filtered Air Discharge 5.6. The long-term hydrogen mixing [R-8] N-REP-03651-10011
System (EFADS) provides a controlled and assessment for LOCAs has demonstrated R000, Preliminary Assessment
monitored release path from containment to the effectiveness of AECL PARs, which are of PARs Effectiveness for
the outside environment. Hydrogen control expected to be able to prevent flammable Hydrogen Mitigation in OPG
inside containment is provided by the Post- mixtures from forming anywhere within Nuclear Generating Stations.
Accident Hydrogen Ignition System containment in the long-term once PARs
(PAHIS). However, PAHIS has a short are installed at all the required locations
mission time and is therefore not credited identified for Darlington. PARs are designed
for long-term control of hydrogen, according mainly to enhance the effectiveness of long-
to the design requirements in NK38-DR- term (up to 90 days) hydrogen mitigation to
34610-10001, Post Accident Hydrogen reduce the risk of potential hydrogen burns.
Ignition System [R-3]. As of April 2012, five AECL PARs have
been installed in the Darlington containment
b) Gap 00794 states that adequate accessible areas. According to the PARs
consideration shall be given to the control implementation plan for Darlington, the
of fission products, hydrogen and other remaining PARs are all to be installed within
substances that may be generated or the next two years during station planned
released in the event of a severe accident. outages for each unit. [OPG Letter W.M.
Although PAHIS is provided for hydrogen Elliott to M. Santini and P.A. Webster,
control, it is only credited in the short term. Status Update for OPGs Fleet-wide PARs
Implementation Plan and Request for AI
There are 2 Gaps from the review of CNSC Closures: Action Items 20081308, 2008-4-
RD-337: 09 and 2008-8-09, N-CORR-00531-05530,
February 8, 2012.] Therefore, the
a) Gap 01480 requires that the design of assessment performed for the AECL PARs
the nuclear power plant shall provide effectiveness for enhancement of hydrogen
systems to control the release of fission mitigation is not applicable in the present
products, hydrogen, oxygen, and other throughout the Darlington containment, as
substances into the reactor containment as described in Appendix 5.6.
necessary, to:
1.Reduce the amount of fission products Gap 00794 was declared against Clause
that might be released to the environment 6.66 of IAEA NS-R-1 which requires:
during an accident; and Adequate consideration shall be given to
2.Prevent deflagration or explosion that the control of fission products, hydrogen
could put the integrity or leak tightness of and other substances that may be
the containment envelope at risk. generated or released in the event of a
The design also shall be able to support the severe accident.
isolation of gases into the containment,
control the containment pressure so that it The Code Review Report, NK38-REP-
will not exceed the design limit, and provide 03680-10024, found that since PAHIS is
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isolation of compressed air sources to only credited for short term hydrogen
prevent any bypass of containment. control and since the Severe Accident
Management Program has not yet been
Although the Emergency Filtered Air implemented, Darlington does not comply
Discharge System provides for a controlled with this Clause.
and monitored pressure release to the
outside environment, and short-term Resolution: Gap 00794 is closed for some
hydrogen control is provided by PAHIS, this Darlington containment locations for severe
system was only designed to have a short accidents. OPG has already committed to
mission for the Loss of Coolant Accident install 34 AECL PARs inside containment at
(LOCA) plus loss of Emergency Coolant the DNGS prior to refurbishment to mitigate
Injection (ECI) event, per Reference [R-3]. long term hydrogen releases following
DBAs. Darlington Refurbishment - Safety
b) Gap 01481 describes the relationship Improvement Opportunities Studies, NK38-
between coatings inside containment and CORR-03611-0429175, 2012/7/30
post-accident conditions inside containment (Darlington NGS Refurbishment Safety
(i.e. the production of hydrogen from metal Improvement Opportunities Summary
corrosion). The gap states that no Report, P1496/RP/028 R02, 2012 May 30)
evidence exists to confirm that post- assessed the number and type of PARs
accident conditions inside containment needed in the IFBs, as well as the additional
were considered when choosing the type number (and type) required inside
and quantity of coating for civil structures containment for BDBA purposes. It
and steel lined reactor structures. concluded that no additional PARs are
recommended for installation in
Containment or the Irradiated Fuel Bay
GAP SUMMARY areas. This conclusion is based on crediting
Shield Tank overpressure protection and
This ISR Issue covers need for systems to makeup to provide Calandria Vessel
control the fission products, hydrogen, Retention and on crediting Irradiated Fuel
oxygen, and other substances that could be Bay makeup and ventilation to control
released into containment. OPG has hydrogen. Therefore no PARS are
effective Hydrogen Ignition Systems for H2 recommended for severe accidents in
control, and EFADS for pressure relief addition to those being installed for DBA.
venting from containment. The installation
of Passive Autocatalytic Re-combiners Gap 01244 is a Tracked Item related to GAI
(PARS) would provide an additional 88G02 and Action Item #20081308. GAI
capability to reduce hydrogen 88G02 was closed by the CNSC through N-
concentration, thereby lowering the risk of CORR-00531-04302 on 21-JUL-2008. As of
hydrogen detonation inside containment. April 2012, five AECL PARs have been
OPG has committed to implementing PARS installed in the Darlington containment
on all DNGS units pending successful accessible areas. The remaining PARs are
implementation of the pilot project to all to be installed within the next two years
implement PARS on one unit. That pilot during station planned outages for each
project is underway. unit. [OPG Letter W.M. Elliott to M. Santini
and P.A. Webster, Status Update for
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OPGs Fleet-wide PARs Implementation
Plan and Request for AI Closures: Action
Items 20081308, 2008-4-09 and 2008-8-
09, N-CORR-00531-05530, February 8,
2012.] Action Item #20081308 tracks the
completion of PARs installation and will
remain open until PARs is completely
installed by the end of July 2014, as
indicated in N-CORR-00531-05599 on 20-
FEB-2012.
Gap 01244 will remain a tracked item for

developments on PARS implementation.
See resolution of Gap 00793.
Gap 01480 was declared against Clause

8.6.10 of CNSC RD-337 which requires:
The design provides systems to control the
release of fission products, hydrogen,
oxygen, and other substances into the
reactor containment as necessary, to:
1. Reduce the amount of fission products

that might be released to the environment
during an accident; and
2. Prevent deflagration or detonation that
could jeopardize the integrity or leak
tightness of the containment.
The design also:

1. Supports isolation of all sources of
compressed air and other non-condensable
gases into the containment atmosphere
following an accident;
2. Ensures that, in the case of ingress of
non-condensable gas resulting from a PIE,
containment pressure will not exceed the
design limit; and
3. Provides isolation of compressed air
sources to prevent any bypass of
containment.
The Code Review Report, NK38-REP-

03680-10109, found that since the
Darlington implementation of the Passive
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Auto-Catalytic Recombiners (PARs), which
are designed to consume long term
hydrogen and are being tracked under
Action Item 20081308, remains in progress,
the intent of Clause 8.6.10 is not met.
Resolution: Gap 01480 is closed for some

Darlington containment locations. See
resolution of Gap 00793.

The coverings and coatings for
components and structures within the
containment are carefully selected, and
their methods of application specified to
ensure fulfillment of their safety functions.
The primary objective of this expectation is
to minimize interference with other safety
functions or accident mitigation systems in
the event of deterioration of coverings and
coatings. In addition, the choice of materials
inside containment takes into account the
impact on post-accident containment
conditions, including fission product
behaviour, acidity, equipment fouling,
radiolysis, fires, and other factors that may
affect containment performance and
integrity, and fission product release.
Gap 01481 will be addressed under ISR

Issue D071, Coatings and Coverings
Within Containment System, which has
been revised and reissued. This Gap has
consequently been removed from ISR Issue
D013
D013 Long Term OVERVIEW 2 793 Long Term Install PARS at Darlington using a phased Gap 00793 was declared against Clause [R-1] NK38 REP 03680-10024,
Control of Control of approach (install in one unit, confirm 6.64 of IAEA NS-R-1 which requires: Review of IAEA NS-R-1
Hydrogen in This ISR Issue is comprised of 4 ISR Gaps Hydrogen in acceptable performance, install in remaining Systems to control fission products, (October 2000), Safety of
Containment from: Containment units). hydrogen, oxygen and other substances Nuclear Power Plants: Design
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RD-337: 09 and 2008-8-09, N-CORR-00531-05530,
necessary, to:
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Items 20081308, 2008-4-09 and 2008-8-
09, N-CORR-00531-05530, February 8,
FEB-2012.



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The design also:

design limit; and
containment.



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D013
D013 Long Term OVERVIEW 2 794 Control of Install PARS at Darlington using a phased Gap 00793 was declared against Clause [R-1] NK38 REP 03680-10024,
Control of Substances approach (install in one unit, confirm 6.64 of IAEA NS-R-1 which requires: Review of IAEA NS-R-1
Hydrogen in This ISR Issue is comprised of 4 ISR Gaps Generated or acceptable performance, install in remaining Systems to control fission products, (October 2000), Safety of
Containment from: Released in units). hydrogen, oxygen and other substances Nuclear Power Plants: Design
the Event of a that may be released into the reactor for Darlington Integrated Safety
-NK38 REP 03680-10024, Review of IAEA Severe Based on industry research, PARS appears containment shall be provided as Review".
NS-R-1 (October 2000), Safety of Nuclear Accident to be the only viable solution to long term necessary: [R-2] NK38-REP-03680-10109,
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RD-337: 09 and 2008-8-09, N-CORR-00531-05530,
necessary, to:
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Items 20081308, 2008-4-09 and 2008-8-
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09, N-CORR-00531-05530, February 8,
FEB-2012.



The design also:

design limit; and
containment.

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D013
D013 Long Term OVERVIEW 2 1480 Post Accident Install PARS at Darlington using a phased Gap 00793 was declared against Clause [R-1] NK38 REP 03680-10024,
Control of Hydrogen approach (install in one unit, confirm 6.64 of IAEA NS-R-1 which requires: Review of IAEA NS-R-1
Hydrogen in This ISR Issue is comprised of 4 ISR Gaps Mitigation acceptable performance, install in remaining Systems to control fission products, (October 2000), Safety of
Containment from: units). hydrogen, oxygen and other substances Nuclear Power Plants: Design
rd
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RD-337: 09 and 2008-8-09, N-CORR-00531-05530,
necessary, to:
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Items 20081308, 2008-4-09 and 2008-8-
09, N-CORR-00531-05530, February 8,
FEB-2012.



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The design also:

design limit; and
containment.



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D013
D013 Long Term OVERVIEW 2 1481 Containment Install PARS at Darlington using a phased Gap 00793 was declared against Clause [R-1] NK38 REP 03680-10024,
Control of System approach (install in one unit, confirm 6.64 of IAEA NS-R-1 which requires: Review of IAEA NS-R-1
Hydrogen in This ISR Issue is comprised of 4 ISR Gaps Coatings acceptable performance, install in remaining Systems to control fission products, (October 2000), Safety of
Containment from: units). hydrogen, oxygen and other substances Nuclear Power Plants: Design
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RD-337: 09 and 2008-8-09, N-CORR-00531-05530,
necessary, to:
rd
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Items 20081308, 2008-4-09 and 2008-8-
09, N-CORR-00531-05530, February 8,
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FEB-2012.



The design also:

design limit; and
containment.

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D013
D027 Severe Accident Overview: 2 1236 Source Term The resolution of this ISR Issue requires Gap 00847 was declared against Clause [R-1] NK38-REP-03680-10102,
and Beyond interaction discussion of three factors: 5.3.3 of CNSC RD-310 which requires: "Review of CNSC RD-310
Design Basis This ISR issue consists of a total of 17 ISR with Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. Emergency 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
Analysis/ SAMG Planning/ 2)Analysis of Severe Accidents safety assessment to demonstrate that: Plants for Darlington Integrated
-Two (2) gaps are from NK38-REP-03680- SAMG 3)Role of analysis within SAMG 1. The nuclear power plant as designed can Safety Review"
10102, "Review of CNSC RD-310 meet the established safety goals; and [R-2] NK38-REP-03680-10021,
(February 2008) Safety Analysis for Background: 2. The accident management program and "Review Of IAEA NS-G-1.2
Nuclear Power Plants" [R-1] design provisions, put in place to handle the (January 2002) Safety
-Fifteen (15) Gaps are from NK38-REP- BDBAs and Severe Accidents are closely accident management needs, are effective. Assessment And Verification
03680-10021, "Review of IAEA NS-G-1.2 related concepts (and are often used The Code Review Report, NK38-REP- For Nuclear Power Plants For
(January 2002) Safety Assessment and interchangeably), however, in the Canadian 03680-10102, found that governance and Darlington Integrated Safety
Verification For Nuclear Power Plants For context, they are not exactly equivalent. the Design Guides do not require analysis Review"
Darlington Integrated Safety Review" [R-2] of BDBA [R-3] CNSC RD-310, Safety
CNSC RD-310, Safety Analysis for Nuclear Analysis for Nuclear Power
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Gaps from NK38-REP-03680-10102, Power Plants [R-3] provides the following Gap 00848 was declared against Clause Plants
"Review of CNSC RD-310 (February 2008) definitions: 5.4.4 of CNSC RD-310 which requires: [R-4] IAEA NS-G-1.2, Safety
Safety Analysis for Nuclear Power Plants" Assumptions made to simplify the analysis, Assessment And Verification
[R-1] 1)Design Basis Accident (DBA): Accident as well as assumptions concerning the For Nuclear Power Plants
conditions against which a nuclear power operating mode of the nuclear power plant, [R-5] NK30-REP-03680-00005,
Gap 00847 was declared against Clause plant is designed, and for which the damage the availability and performance of the Pickering NGS B Integrated
5.3.3 of CNSC RD-310 [R-3] which requires to the fuel and the release of radioactive systems, and operator actions, shall be Safety Review Safety
that Analysis for BDBAs shall be performed material are kept within authorized limits. identified and justified. The analysis of AOO Analysis Review
as part of the safety assessment. The Code 2)Beyond Design Basis Accident (BDBA): and DBA shall: [R-6] NK30-REP-03680-00016,
Review Report [R-1] found that governance Accident conditions less frequent and more 1. Apply the single-failure criterion to all OPG Response to CNSC
and the Design Guides do not require severe than a design basis accident. A safety systems and their support systems; Comments on Pickering NGS-B
analysis of BDBA. BDBA may or may not involve core 2. Account for consequential failures that Integrated Safety Review
degradation. may occur as a result of the initiating event; Plant Design, Safety Analysis,
Gap 00848 was declared against Clause 3. Credit actions of systems only when the Safety Performance, Ageing
5.4.4 of CNSC RD-310 [R-3] which CNSC G-306, Severe Accident systems are qualified for the accident and Equipment Qualification
provides requirements for BDBA analysis Management Programs for Nuclear conditions, or when their actions could have Safety Factor Reports and
assumptions. The Code Review Report [R- Reactors [R-10] provides the following a detrimental effect on the consequences of Discrepancy Resolutions
1] found that BDBAs were not analyzed for definitions: the analyzed accident; [R-7] NK30-REP-03680-00015,
Darlington. 4. Account for the possibility of the Pickering NGS-B Integrated
1)Severe Accident: Accident conditions equipment being taken out of service for Safety Review (ISR) - Final ISR
Please note that these ISR Gaps are also more severe than a design basis accident maintenance; and Report
associated with Issue D030: Identification (DBA) and involving significant core 5. Credit operator actions only when there [R-8] NK38-REF-03680-
and Classification of Events per CNSC RD- degradation. are: 0366713, Darlington Integrated
310, which deals with CNSC RD-310 [R-3] 2)Severe Accident Management (SAM) a) unambiguous indications of the need for Safety Review (ISR) Issue
compliance. Program: A program that establishes: 1. such actions, Prioritization under project
The actions to be taken to prevent severe b) adequate procedures and sufficient time P1362
Gaps from NK38-REP-03680-10021, damage to the reactor core, to mitigate the to perform the required actions, and [R-9] NK38-SR-03500-10002,
"Review of IAEA NS-G-1.2 (January 2002) consequences of the core damage should it c) environmental conditions that do not DN 1-4 Safety Report: Part 3
Safety Assessment and Verification For occur, and to achieve a safe, stable state of prohibit such actions. Accident Analysis
Nuclear Power Plants For Darlington the reactor over the long term; and 2. The For the analysis of BDBA, it is acceptable to [R-10] CNSC G-306, Severe
Integrated Safety Review" [R-2] preparatory measures necessary for use a more realistic analysis methodology Accident Management
implementation of such actions. consisting of assumptions which reflect the Programs for Nuclear Reactors
Gaps 01222 to 01236 were declared likely plant configuration, and the expected [R-11] COG-JP-4056-022,
against Clauses 4.105 to 4.108, 4.111, and In accordance with these definitions, the response of plant systems and operators in Severe Accident Management
4.113 to 4.122 of IAEA NS-G-1.2 [R-4] Darlington Documentation Package for the analysed accident. Guidance: Darlington
which contain various requirements for SAMG [R-11] shows that while all Severe The Code Review Report, NK38-REP- Documentation Package
Severe Accidents. Each of these ISR Gaps Accidents are BDBAs, not all BDBAs are 03680-10102, found that BDBAs were not [R-12] CNSC S-294,
share the same Gap Discussion. The Severe Accidents. In particular, a severe analyzed for Darlington. Probabilistic Safety
Code Review Report [R-2] identifies that accident is a "beyond design basis" event Assessment (PSA) for Nuclear
while some BDBA analysis has been that results in widespread physical damage Please note that these ISR Gaps are also Power Plants
performed, all sequences may not have to fuel and core structures, accompanied by associated with Issue D030: Identification [R-13] COG-09-9030,
been addressed. In addition, the Severe a large release of fission products. and Classification of Events per CNSC RD- Principles & Guidelines for
Accident Management Guidelines (SAMG) 310, which deals with CNSC RD-310 Deterministic Safety Analysis
program has not been implemented at This distinction manifests itself in analysis compliance. Used in Licensing of Current
Darlington. by differing approaches to BDBAs and CANDU Nuclear Power Plants
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Severe Accidents: Resolution to Gap 00847 and Gap 00848: Operating in Canada
Gap Summary: CNSC RD-310 [R-1] provides the following [R-14] N-CORR-00531- 05255,
-analysis of BDBAs is generally definitions: OPG Safety Analysis
The scope of this ISR Issue is a lack of a deterministic in nature and is performed in Glossary Improvement Activities, Part 3:
systematic analysis of Beyond Design accordance with CNSC RD-310 [R-3] 1. Design Basis Accident (DBA): Accident Analysis Closure of
Basis Accident (BDBA) as defined in CNSC -analysis of Severe Accidents is generally Accident conditions against which a nuclear Action Item 20100PG-01
RD-310 [R-3] and Severe Accidents as probabilistic in nature and is performed in power plant is designed, and for which the [R-15] N-PROG-RA-0016, Risk
defined in IAEA NS-G-1.2 [R-4]. The lack accordance with CNSC S-294 [R-12] damage to the fuel and the release of and Reliability Program
of a fully implemented Severe Accident radioactive material are kept within
Management Guidelines (SAMG) program Overlap between the approaches occurs. authorized limits.
was also identified. As explicitly stated in the Principles and 2. Beyond Design Basis Accident
Guidelines Document for Deterministic (BDBA): Accident conditions less frequent
Safety Analysis [R-13]: Deterministic safety and more severe than a design basis
analysis also has a role in supporting accident. A BDBA may or may not involve
demonstration of defence-in-depth, for core degradation.
determining consequences of PRA event 5.2.3 Classification of Events:
sequences, for hazards analysis of common The identified events shall be classified,
mode events, and in development of severe based on the results of probabilistic studies
accident management procedures and and engineering judgement, into the
guidelines. Similarly, BDBA can make use following three classes of events:
of probabilistic methods and results where 1. Anticipated Operational
appropriate. Occurrences (AOOs) include all events with
frequencies of occurrence equal to or
Analysis of BDBAs: greater than 10-2 per reactor year;
2. Design Basis Accidents (DBAs)
For BDBAs, compliance with CNSC RD-310 include events with frequencies of
[R-3] and generic rules regarding BDBA occurrence equal to or greater than 10-5
analysis are being pursued on an industry per reactor year but less than 10-2 per
basis via the CANDU Owners Group reactor year; and
(COG). This industry effort has led to the 3. Beyond Design Basis Accidents
issuance of a Principles and Guidelines (BDBAs) include events with frequencies of
(P&G) document from COG, COG-09-9030 occurrence less than 10-5 per reactor year.
[R-13] which presents the utilities proposed Other factors to be considered in the event
common approach for deterministic safety classification are any relevant regulatory
analysis as well as moving toward RD-310 requirements or historical practices. Events
type analysis for existing stations, including with a frequency on the border between two
the analysis of BDBAs. classes of events, or with substantial
uncertainty over the predicted event
The principles and guidelines document frequency, shall be classified into the higher
was developed in consultation with the frequency class.
CNSC. As stated in a letter to OPG from Credible common-cause events shall also
the CNSC [R-14]: CNSC staff further be classified within the AOO, DBA and
confirmed its views that this P&G document BDBA classes.
is suitable for improving safety analysis and
for implementing RD-310. This letter [R-14] CNSC G-306 [R-2] provides the following
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also closed the OPG Action Item 2010OPG- definitions:
01 which referred to various ongoing Safety
Analysis Improvement (SAI) initiatives. All 1. Severe Accident: Accident
remaining SAI activity will be linked to the conditions more severe than a design basis
OPG Action Item 2010OPG-05. OPG Action accident (DBA) and involving significant
Item 2010OPG-05 deals with OPG core degradation.
compliance with CNSC RD-310, and 2. Severe Accident Management
includes analysis of BDBAs. (SAM) Program: A program that
establishes: 1. The actions to be taken to
Completion of the CNSC RD-310 prevent severe damage to the reactor core,
compliance activities will resolve portions of to mitigate the consequences of the core
this ISR Issue dealing with the analysis of damage should it occur, and to achieve a
BDBAs. safe, stable state of the reactor over the
long term; and 2. The preparatory measures
OPG compliance with CNSC RD-310 (and necessary for implementation of such
2010OPG-05) is also discussed in ISR actions.
Issue D030 Identification and Classification In accordance with these definitions, the
of Events per RD-310. Darlington Documentation Package for
SAMG [R-24] (this is a large series of
Analysis of Severe Accidents: documents, only the reference to the
Technical Support Group Users Guide is
For Severe Accidents, the definitions from provided for brevity) shows that while all
the CNSC S-294 [R-12] and G-306 [R-10] Severe Accidents are BDBAs, not all
documents suggest that using probabilistic BDBAs are Severe Accidents. In particular,
methods is most suitable in the analysis of a severe accident is a "beyond design
severe accidents. According to the basis" event that results in widespread
regulatory standard CNSC S-294, the physical damage to fuel and core
scopes of Level 1 and Level 2 PRA are as structures, accompanied by a large release
follows: of fission products.
This distinction manifests itself in analysis
1)A Level 1 PSA identifies and quantifies by differing approaches to BDBAs and
the sequences of events that may lead to Severe Accidents:
the loss of core structural integrity and -Analysis of BDBAs is generally
massive fuel failures; deterministic in nature and is performed in
2)A Level 2 PSA starts from the Level 1 accordance with CNSC RD-310 [R-1].
results, and analyses the containment -Analysis of Severe Accidents is generally
behaviour, evaluates the radionuclides probabilistic in nature and is performed in
released from the failed fuel and quantifies accordance with CNSC S-294 [R-3].
the releases to the environment. This resolution addresses the completion of
Gap 00847 and Gap G0848 from the view
N-PROG-RA-0016, Risk and Reliability point of the Severe Accidents subset of the
Program [R-15] governs PRA at OPG. It BDBAs, as covered in the Probabilistic Risk
states: PRA be used to support in-plant Assessments (PRA).
and ex-plant consequence analyses for The Darlington Risk Assessment completed
event sequences beyond the design basis in 2011 comprises the following PRAs:
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for use in understanding severe accident 1. Level 1 Internal Events PRA [R-4].
progression and management, as allowed 2. Level 2 Internal Events PRA [R-5].
by the scope and limitations of the PRA. 3. Level 1 Internal Events Outage
PRA [R-6].
Completion of the DARA project will resolve 4. Fire PRA [R-7].
portions of this Issue dealing with the 5. Internal Flood PRA [R-8].
analysis of Severe Accidents. 6. Seismic PRA [R-9], [R-10].
These PRAs provide probabilistic estimates
OPG compliance with CNSC S-294 (and for the Severe Core Damage Frequency
completion of Level 1 and 2 PRAs) is also (SCDF) and Large Release Frequency
discussed in ISR Issue D025 DARA Scope (LRF), which are Severe Accidents by the
and Completion. above definitions. Each of the above PRA
models is developed in accordance with the
Role of analysis within Severe Accident corresponding OPG PRA Guides,
Management Guidelines (SAMG): References [R-11] to [R-16]. Therefore,
from a Severe Accident point of view Gap
Although the ISR Gaps which make up this 00847 and Gap G0848 are resolved by
ISR Issue deal primarily with analysis, many completion of the DARA (2011).
of the ISR Gaps mentioned the fact that Analysis of BDBAs:
OPG has not yet fully implemented a SAMG For BDBAs, compliance with CNSC RD-310
program. The interface between analysis and generic rules regarding BDBA analysis
and SAMG is comprehensively discussed in are being pursued on an industry basis via
the Darlington Documentation Package for the CANDU Owners Group (COG). This
SAMG [R-11]. From Section 6.1 of [R-11]: industry effort has led to the issuance of a
Principles and Guidelines (P&G)
By definition, SAMG is intended to address document from COG, COG-09-9030 which
event sequences that are beyond the presents the utilities proposed common
Design Basis upon which the plant has approach for deterministic safety analysis
been licensed to operate. As a as well as moving toward RD-310 type
consequence, comprehensive safety analysis for existing stations, including the
analysis does not usually exist for such analysis of BDBAs.
events. As outlined in Section 1.1, SAMG The principles and guidelines document
use is symptom-based and the guidelines was developed in consultation with the
have been designed to be useful without CNSC. As stated in a letter to OPG from
making any assumptions about what has the CNSC [R-17]: CNSC staff further
caused the event to occur or as to what confirmed its views that this P&G document
mitigating functions may or may not be is suitable for improving safety analysis and
available. This makes it difficult to identify for implementing RD-310. This letter [R-17]
scenarios for which it would be meaningful also closed the OPG Action Item 2010OPG-
to perform detailed safety analysis. 01 which referred to various ongoing Safety
Furthermore, since the intent of SAMG is to Analysis Improvement (SAI) initiatives. All
identify the best use of the available plant remaining SAI activity will be linked to the
capability under the circumstances, there is OPG Action Item 2010OPG-05. OPG Action
no rational basis to establish criteria to Item 2010OPG-05 deals with OPG
demonstrate acceptability of the plant compliance with CNSC RD-310, and
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response. For these reasons, SAMG includes analysis of BDBAs.
development in Canada and elsewhere is Completion of the CNSC RD-310
typically not based strongly on the results of compliance activities will resolve portions of
safety analysis In summary, safety this ISR Issue dealing with the analysis of
analysis is used to provide information in BDBAs.
support of the development of SAMG, but OPG compliance with CNSC RD-310 (and
not to demonstrate the acceptability of 2010OPG-05) is also discussed in ISR
SAMG actions in absolute terms. Issue D030 Identification and Classification
of Events per RD-310.
Implementation of the SAMG program is SAMG implications:
therefore not predicated on a As severe accident management
comprehensive analysis of severe programmes in the CANDU industry take
accidents. However, SAMG can be used as the form of guidelines rather than
an input into Severe Accident Analysis via prescriptive procedures, it is contradictory to
PRA. Operator actions are modelled in the requirement that all human interactions
PRA therefore when SAMG is complete the should be quantified with the same rigour as
resulting procedures can be credited as is done for human interactions in Level 1
operator actions. PRA, and to credit actions resulting from
SAMG in Level 2 PRA Reference [R-5]
Completion of the SAMG project will also Section 11.3.2 Omissions. That being said,
resolve portions of this Issue dealing with sensitivity studies to assess the potential
SAMG. impacts of including new design features
and operator credits to limit severe accident
OPG completion and implementation of the progression have been carried-out in
SAMG program is also discussed in ISR support of OPGs assessment of their
Issue D143 Severe Accident and Beyond benefit for possible implementation.
Design Basis Accident (BDBA) Program/
SAMG. Gaps 01222 to 01236 were declared
against Clauses 4.105 to 4.108, 4.111, and
Summary: 4.113 to 4.122 of IAEA NS-G-1.2 and all
share the same Gap Discussion: The Code
The scope of this ISR Issue will be Review Report [R-2] identifies that while
completely resolved by the resolutions of some BDBA analysis has been performed,
the following ISR Issues: all sequences may not have been
addressed. In addition, the Severe Accident
1)The analysis of BDBAs will be fully Management Guidelines (SAMG) program
addressed by the completion of CNSC RD- has not been implemented at Darlington.
310 compliance activities
2)The analysis of Severe Accidents will be Clause 4.105: The safety analysis should
fully addressed by the DARA project. aim to quantify a plant safety margin and
3)The implementation of a SAMG program demonstrate that a degree of defence in
will be fully addressed by the SAMG project depth is provided for this class of accidents.
This would include such measures where
Management action AR# 28127911 has reasonably achievable:
been raised to track the completion of - To prevent the escalation of events into
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CNSC RD-310 compliance activities, the severe accidents, control the progression of
DARA project, and the SAMG project to severe accidents and limit the releases of
completion in order to confirm that they radioactive material through the provision of
have satisfactorily resolved Issue D027. additional equipment and accident
management procedures.
Preferred Resolution: - To mitigate the radiological consequences
that might occur through the provision of
Confirm credited ongoing programs have plans for on-site and off-site emergency
resolved Issue. response. For those hypothetical severe
accident sequences (e.g. high pressure
Rationale: core melt in PWRs) that could lead to early
failure of the containment, it should be
Management action AR# 28127911 has demonstrated that they can be excluded
been raised to track the completion of with a very high degree of confidence.
CNSC RD-310 compliance activities, the
DARA project, and the SAMG project to Resolution:
completion in order to confirm that they The SAMG Guides [R-24] (this is a large
have satisfactorily resolved Issue D027. series of documents, only the reference to
the Technical Support Group Users Guide
is provided for brevity) makes use of
insights from the Level 2 analysis to guide
the emergency response on-site to
prevent/control the progression of severe
accidents and limit releases of radioactive
material. It has been issued and the
validation is in progress. Several SAM
exercise drills have already been
performed. Off-site emergency response is
managed by the provincial emergency
response organization.
The Level 2 analysis demonstrates that

there is an acceptable risk associated with
all severe accident scenarios.
Clause 4.106: The severe accident analysis

should address a set of representative
sequences in which the safety systems
have malfunctioned and some of the
barriers to the release of radioactive
material have failed or have been
bypassed. These sequences should be
selected by adding additional failures or
incorrect operator responses to the DBA
sequences (to include safety system failure)
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and to the dominant accident sequences
from the PSA.
Resolution:
A process for determining the set of
significant event sequences to be analyzed
in the context of severe accident analysis
and Level 2 PRA has been established in
[R-12] Section 2.3 Interface with Level 1
PRA Plant Damage States. This
methodology, which makes use of insights
from the Level 1 analysis combined with
engineering judgement and an
understanding of the physical phenomena,
was implemented in determining the
accident sequences to include in the DARA
Level2 PRA [R-5] Section 3.0 Development
of Plant Damage States.
Clause 4.107: The significant event

sequences that could lead to severe
accidents should be identified using a
combination of probabilistic and
deterministic methods and sound
engineering judgement.
Resolution:
See resolution to Clause 4.106 above.
Clause 4.108: The most rigorous way of

identifying severe accident sequences is to
use the results of the Level 1 PSA (see
para. 4.124). However, it might also be
possible to identify representative or
bounding sequences from an understanding
of the physical phenomena involved in
severe accident sequences, the margin
existing in the design, and the amount of
system redundancy remaining in the DBAs.
Resolution:
Clause 4.111: The assessment of severe

accidents should account for the full design
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capabilities of the plant, including the use of
some safety and non-safety systems
beyond their originally intended function to
return the potential severe accident to a
controlled state and/or to mitigate its
consequences. If credit is taken for
extraordinary use of systems, there should
be a reasonable basis to assume they can
and will be used as analysed.
Resolution:
Some of the beyond design basis accidents
(BDBAs) have already been addressed in
the original design of the plant, e.g.,
LOCA+LOECI. In response to the recent
Fukushima total loss of electrical power
BDBA, OPG has design and equipment in
place for fuel cooling, i.e., the Emergency
Mitigating Equipment (EME). Furthermore,
OPG has already identified several design
enhancements for BDBAs and to severe
accidents, and has progressed several
options to conceptual design stage, which
are as known as Safety Improvement
Opportunities (SIOs) which are to be
implemented at the upcoming Darlington
refurbishment. The EMEs and the SIOs will
also enhance SAMG capability and/or
provide additional strategies for core
cooling. Additionally, validation and
refinement of SAMG is in progress, to be
completed by the end of 2013, which
identifies modifications that are required to
implement SAMG strategies. The
recommendations from the validation and
refinement of SAMG are then to be
implemented with target completion by the
end of 2015 [R-25].

should model the wide range of physical
processes that could occur following core
damage and that could lead to a release of
radioactive material to the environment.
These should
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include, where appropriate:
-Core degradation processes and fuel
melting;
-Fuel-coolant interactions (including steam
explosions);
-In-vessel melt retention;
-Vessel melt-through;
-Distribution of heat inside the primary
circuit;
-High pressure melt ejection/direct
containment heating;
-Generation and combustion of hydrogen;
-Failure or bypass of the containment;
-Core-concrete interaction;
-Release and transport of fission products;
-Ability to cool in-vessel and ex-vessel core
melt.
Resolution:
Following the completion of the Level 2 At-
Power Probabilistic Risk Assessment for
Darlington, the physical processes that are
described in Clause 4.113 have been
modelled and assessed during the
consequence assessment component of the
PRA update to comply with S294. In
addition to the modeling that exist in
MAAP4-CANDU [R-18] and [R-19] that
include all the relevant processes listed in
Clause 4.113, detailed assessments of
many of the phenomena that occur in each
of the relevant listed processes was
performed as part of the Darlington At-
Power Branch Point Quantification report
[R-20]
Core degradation processes and
fuel melting[R-19] Section 4.2.9 Channel
Response During Heat Up;
Fuel-coolant interactions
(including steam explosions)[R-20]
Section 6.2 Calandria Assembly Integrity;
In-vessel melt retention[R-20]
Vessel melt-through[R-20]
Distribution of heat inside the
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primary circuit[R-18] subroutine PHTS
description;
High pressure melt ejection/direct
containment heatingnot relevant for
CANDU due to design of PHTS and
calandria vessel being equipped with
rupture disks;
Generation and combustion of
hydrogen[R-20] Appendix C.1 Summary
of Flammable Gas Ignition Phenomena;
Failure or bypass of the
containment[R-20] Section 4.1.2 Accident
Progression Containment Integrity
Challenges;
Core-concrete interaction[R-20]
Section 6.10 Likelihood of CCI Induced
Erosion of the FMD Floor;
Release and transport of fission
products[R-18] Section 3.8 Fission
Product & Section 4.9 Fission Product
Transport;
Ability to cool in-vessel and ex-
vessel core melt[R-20] Section 6.2
Calandria Assembly Integrity & Section 6.10
Likelihood of CCI Induced Erosion of the
FMD Floor.
Clause 4.114: The analysis would typically

involve a multi-tiered approach using
different codes, including detailed system
and containment analysis codes, more
simplified risk assessment and separate
effects codes, and source term and
radiological impact studies. Use of a full
selection of codes will ensure that all the
expected phenomena are adequately
analysed.
Resolution:
For severe accident consequence
assessment in the context of Level 2 PRA,
the primary analysis tool is the MAAP4-
CANDU code [R-18]. The MAAP4-CANDU
code has been validated and where
applicable higher fidelity codes have been
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used to compare MAAP4-CANDU models
with [R-21] to ensure that expected
phenomena are adequately modeled. In
addition, while executing the consequence
analysis for Level 2 PRA MAAP4-CANDU
results are compared to higher resolution
codes (For example in DARA: [R-5] Section
6.3.3.1 Primary System Modeling).
Clause 4.115: The assessment should

ensure that the reactor core, primary circuit
and containment are modelled accurately.
These models are particularly significant to
the analysis and are influential in
determining the course of the accident.
Resolution:
Clause 4.116: The acceptance criteria for

severe accidents are usually formulated in
terms of risk criteria (probabilistic safety
criteria). These are discussed in paras
4.219-4.231. However, there is only limited
agreement
on what these criteria should be.
Deterministic acceptance criteria have also
been specified in a number of countries,
typically as follows:
-Containment failure should not occur in the
short term following a severe accident,
-There should be no short term health
effects following a severe accident,
-The long term health effects/release of
137Cs should be below prescribed limits
following a severe accident.
Resolution:
Safety goals for Level 2 PRA have been
established for Darlington in Reference [R-
12] Section 1.5 Safety Goals Used to
Assess PRA Results, and are based on
guidance from Reference [R-22].
Clause 4.117: The aim of severe accident
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analysis should be:
-To evaluate the ability of the design to
withstand severe accidents and to identify
particular vulnerabilities. This includes
assessment of equipment that could be
used in accident management and
instrumentation that could monitor the
course of the accident.
-To assess the need for features that could
be incorporated in the plant design* to
provide defence in depth for severe
accidents.
-To identify accident management
measures that could be carried out to
mitigate accident effects.
-To develop an accident management
programme to be followed in beyond design
basis accidents and severe accident
conditions.
-To provide input for off-site emergency
planning.
* These design features might include the

following:
- Core catcher or core spreading area and
basemat concrete that is resistant to core
melt damage.
- Hydrogen recombiners sized to cope with
the rate of hydrogen generation that could
occur following a severe accident.
- Filtered containment venting system that
would be operated in the longer term to
prevent failure of the containment due to
overpressurization following a severe
accident.
Resolution:
In addition, the results from the Darlington

Level 2 At-Power PRA [R-5] are used to
inform the SAMG strategies and sensitivity
studies were conducted to evaluate the
effectiveness of the SIOs that are identified
as part of the Darlington refurbishment
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project.
Clause 4.118: The consideration of severe

accidents should be done at the design
stage for new plants. However, for currently
operating plants, a severe accident
management programme should be
developed that makes full use of all
available equipment and procedures to
mitigate the consequences of the accident.
Such measures could include the use of
alternate or diverse systems, procedures
and methods to use non-safety grade
equipment, and the use of external
equipment for temporary replacement of a
standard component. Details on the
development and implementation of the
accident management programmes are
dealt with in a separate IAEA publication [9].
Resolution:
Clause 4.119: The effectiveness of the

above design features and accident
management measures in reducing risk
should be evaluated by the PSA.
Resolution:
As severe accident management
programmes in the CANDU industry take
the form of guidelines rather than
prescriptive procedures, it is contradictory to
the requirement that all human interactions
should be quantified with the same rigour as
is done for human interactions in Level 1
PRA, to credit actions resulting from SAMG
in Level 2 PRA Reference [R-5] Section
11.3.2 Omissions. That being said, the PRA
has been used to identify risk-significant
contributors for which additional
complementary design features or other
accident management measures would be
beneficial. As a part of the Darlington
Refurbishment Safety Improvement
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Opportunities (SIO) project, a number of
SIOs were assessed using the COG
Benefit-Cost Analysis methodology. Of
these SIOs, four Environmental Assessment
(EA) SIOs have been identified as providing
significant risk reduction by means of
design features intended for accident
mitigation. In particular, the following three
(of the four) SIOs will provide
complementary design features for the
mitigation of BDBAs including severe
accidents (Darlington Refurbishment -
Safety Improvement Opportunities Studies,
[R-26]):
1. Addition of a Containment Filtered
Venting System (with Shield Tank
Overpressure relief)
2. Addition of a Third Emergency
Power Generator
3. Implementation of an Emergency
Heat Sink for make-up to the HTS
As a part of the study [R-26], the conceptual
options identified for the SIOs described
above were evaluated to determine their
potential risk benefit using PRA methods.
These results were captured as a part of the
Enhanced Darlington Risk Assessment
(DARA) including EA SIOs (Darlington
NGS Risk Assessment Summary Report,
[R-27]).
Given the information above describing the

analysis conducted to determine significant
risk contributors using the PRA, the
conceptual option development of design
features to mitigate the risks, and the
evaluation of those options using cost-
benefit analysis based on the station PRA,
the gap against IAEA NS-G-1.2, Clause
4.119 is closed.

should also provide input to civil authorities
for off-site emergency planning and
response.
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Resolution:
Performing a Level 3 PRA is not a
requirement under Canadian Regulatory
Standard S-294 [R-3]; however, OPG has
completed a Level 3 PRA for Darlington [R-
23] wherein the off-site consequences of
representative severe accidents have been
assessed. The source terms used in the
off-site consequences are from severe
accident sequences that contribute to the
various release categories that were
quantified in the Darlington Level 2 PRA [R-
5]. These results could be used by
authorities to inform their off-sight
emergency planning and response.
Clause 4.121: The results of the severe

accident analysis should be used to identify
source terms which could be used as a
basis for off-site emergency planning.
Resolution:
Clause 4.122: The source terms could also

be used to demonstrate the effectiveness of
sheltering, taking potassium iodide tablets,
food bans and evacuation.
Resolution:
See resolution to Clause 4.120 above
D027 Severe Accident Overview: 2 1235 Severe The resolution of this ISR Issue requires Gap 00847 was declared against Clause [R-1] NK38-REP-03680-10102,
and Beyond Accident discussion of three factors: 5.3.3 of CNSC RD-310 which requires: "Review of CNSC RD-310
Design Basis This ISR issue consists of a total of 17 ISR Source Terms/ Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. SAMG 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
Analysis/ SAMG 2)Analysis of Severe Accidents safety assessment to demonstrate that: Plants for Darlington Integrated
-Two (2) gaps are from NK38-REP-03680- 3)Role of analysis within SAMG 1. The nuclear power plant as designed can Safety Review"
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PRA [R-6].
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from the PSA.
Resolution:

Resolution:

Resolution:
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Resolution:
end of 2015 [R-25].

rd
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These should
melting;
explosions);
circuit;
melt.
Resolution:
[R-20]
rd
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description;
rupture disks;
Challenges;
Transport;
FMD Floor.

analysed.
Resolution:
rd
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Resolution:

agreement
Resolution:
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analysis should be:
accidents.
conditions.
planning.

following:
melt damage.
accident.
Resolution:

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project.

Resolution:

Resolution:
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[R-26]):
Power Generator
[R-27]).

4.119 is closed.

rd
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response.
Resolution:

Resolution:

Resolution:
Design Basis This ISR issue consists of a total of 17 ISR interface with Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. Emergency 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
Analysis/ SAMG Planning/ 2)Analysis of Severe Accidents safety assessment to demonstrate that: Plants for Darlington Integrated
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PRA [R-6].
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from the PSA.
Resolution:

Resolution:

Resolution:
rd
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Resolution:
end of 2015 [R-25].

rd
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These should
melting;
explosions);
circuit;
melt.
Resolution:
[R-20]
rd
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description;
rupture disks;
Challenges;
Transport;
FMD Floor.

analysed.
Resolution:
rd
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Resolution:

agreement
Resolution:
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analysis should be:
accidents.
conditions.
planning.

following:
melt damage.
accident.
Resolution:

rd
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project.

Resolution:

Resolution:
rd
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[R-26]):
Power Generator
[R-27]).

4.119 is closed.
rd
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response.
Resolution:

Resolution:

Resolution:
Design Basis This ISR issue consists of a total of 17 ISR Reactor/ HTS/ Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. Containment 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
Analysis/ SAMG models/ 2)Analysis of Severe Accidents safety assessment to demonstrate that: Plants for Darlington Integrated
rd
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rd
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PRA [R-6].
rd
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rd
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rd
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from the PSA.
Resolution:

Resolution:

rd
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Resolution:

Resolution:
end of 2015 [R-25].
rd
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These should
melting;
explosions);
circuit;
melt.
Resolution:
[R-20]
rd
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description;
rupture disks;
Challenges;
Transport;
FMD Floor.

analysed.
Resolution:
rd
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Resolution:

agreement
Resolution:
rd
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analysis should be:
accidents.
conditions.
planning.

following:
melt damage.
accident.
Resolution:
rd
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project.

Resolution:

Resolution:
rd
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[R-26]):
Power Generator
[R-27]).

rd
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4.119 is closed.

response.
Resolution:

Resolution:

Resolution:
D027 Severe Accident Overview: 2 848 Analysis of The resolution of this ISR Issue requires Gap 00847 was declared against Clause [R-1] NK38-REP-03680-10102,
and Beyond Assumptions discussion of three factors: 5.3.3 of CNSC RD-310 which requires: "Review of CNSC RD-310
Design Basis This ISR issue consists of a total of 17 ISR for AOO, Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. BDBA 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
rd
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PRA [R-6].
rd
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from the PSA.
Resolution:

Resolution:

rd
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Resolution:

Resolution:
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end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
Resolution:
[R-20]
rd
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description;
rupture disks;
Challenges;
Transport;
FMD Floor.

analysed.
rd
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Resolution:

Resolution:

agreement
rd
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Resolution:

analysis should be:
accidents.
conditions.
planning.

following:
melt damage.
accident.
Resolution:
rd
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project.

Resolution:

Resolution:
rd
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[R-26]):
Power Generator
[R-27]).

rd
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4.119 is closed.

response.
Resolution:

Resolution:

Resolution:
Design Basis This ISR issue consists of a total of 17 ISR interface with Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. PSA/ SAMG 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
rd
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PRA [R-6].
rd
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Significance
rd
Page 120 of 8514

0235 ISR ADEQUA 0001 01

Significance

rd
Page 121 of 8514

0235 ISR ADEQUA 0001 01

Significance
from the PSA.
Resolution:

Resolution:

rd
Page 122 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:
rd
Page 123 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
Resolution:
[R-20]
rd
Page 124 of 8514

0235 ISR ADEQUA 0001 01

Significance
description;
rupture disks;
Challenges;
Transport;
FMD Floor.

rd
Page 125 of 8514

0235 ISR ADEQUA 0001 01

Significance
analysed.
Resolution:

Resolution:

agreement
rd
Page 126 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

analysis should be:
accidents.
conditions.
planning.

following:
melt damage.
accident.
rd
Page 127 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

project.

Resolution:

Resolution:
rd
Page 128 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-26]):
Power Generator
[R-27]).

rd
Page 129 of 8514

0235 ISR ADEQUA 0001 01

Significance
4.119 is closed.

response.
Resolution:

Resolution:

Resolution:
D027 Severe Accident Overview: 2 1232 New and The resolution of this ISR Issue requires Gap 00847 was declared against Clause [R-1] NK38-REP-03680-10102,
and Beyond Existing Plant discussion of three factors: 5.3.3 of CNSC RD-310 which requires: "Review of CNSC RD-310
Design Basis This ISR issue consists of a total of 17 ISR Severe Beyond Design Basis Accidents Analysis (February 2008) Safety
rd
Page 130 of 8514

0235 ISR ADEQUA 0001 01

Significance
Accident (BDBA) Gaps from two (2) Code Review Reports. Accident 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
Analysis/ SAMG Analysis/ 2)Analysis of Severe Accidents safety assessment to demonstrate that: Plants for Darlington Integrated
rd
Page 131 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 132 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 133 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 134 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 135 of 8514

0235 ISR ADEQUA 0001 01

Significance

rd
Page 136 of 8514

0235 ISR ADEQUA 0001 01

Significance

from the PSA.
Resolution:

Resolution:

rd
Page 137 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:
rd
Page 138 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
Resolution:
rd
Page 139 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-20]
description;
rupture disks;
Challenges;
Transport;
FMD Floor.

rd
Page 140 of 8514

0235 ISR ADEQUA 0001 01

Significance
analysed.
Resolution:

Resolution:

agreement
rd
Page 141 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

analysis should be:
accidents.
conditions.
planning.

following:
melt damage.
rd
Page 142 of 8514

0235 ISR ADEQUA 0001 01

Significance
accident.
Resolution:

project.

Resolution:

Resolution:
rd
Page 143 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-26]):
Power Generator
[R-27]).

rd
Page 144 of 8514

0235 ISR ADEQUA 0001 01

Significance
4.119 is closed.

response.
Resolution:

Resolution:

Resolution:
D027 Severe Accident Overview: 2 1231 Aim of Severe The resolution of this ISR Issue requires Gap 00847 was declared against Clause [R-1] NK38-REP-03680-10102,
rd
Page 145 of 8514

0235 ISR ADEQUA 0001 01

Significance
Design Basis This ISR issue consists of a total of 17 ISR Analysis/ Beyond Design Basis Accidents Analysis (February 2008) Safety
rd
Page 146 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 147 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 148 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 149 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 150 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 151 of 8514

0235 ISR ADEQUA 0001 01

Significance

from the PSA.
Resolution:

Resolution:

rd
Page 152 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:
rd
Page 153 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
Resolution:
rd
Page 154 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-20]
description;
rupture disks;
Challenges;
Transport;
FMD Floor.

rd
Page 155 of 8514

0235 ISR ADEQUA 0001 01

Significance
analysed.
Resolution:

Resolution:

agreement
rd
Page 156 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

analysis should be:
accidents.
conditions.
planning.

following:
melt damage.
rd
Page 157 of 8514

0235 ISR ADEQUA 0001 01

Significance
accident.
Resolution:

project.

Resolution:

Resolution:
rd
Page 158 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-26]):
Power Generator
[R-27]).
rd
Page 159 of 8514

0235 ISR ADEQUA 0001 01

Significance
4.119 is closed.

response.
Resolution:

Resolution:

Resolution:
rd
Page 160 of 8514

0235 ISR ADEQUA 0001 01

Significance
Design Basis This ISR issue consists of a total of 17 ISR Acceptance Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. Criteria/ 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
Analysis/ SAMG SAMG 2)Analysis of Severe Accidents safety assessment to demonstrate that: Plants for Darlington Integrated
rd
Page 161 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 162 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 163 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 164 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 165 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 166 of 8514

0235 ISR ADEQUA 0001 01

Significance


from the PSA.
Resolution:

Resolution:
rd
Page 167 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:
rd
Page 168 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
Resolution:
rd
Page 169 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-20]
description;
rupture disks;
Challenges;
Transport;
FMD Floor.

rd
Page 170 of 8514

0235 ISR ADEQUA 0001 01

Significance
analysed.
Resolution:

Resolution:

agreement
rd
Page 171 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

analysis should be:
accidents.
conditions.
planning.

following:
melt damage.
rd
Page 172 of 8514

0235 ISR ADEQUA 0001 01

Significance
accident.
Resolution:

project.

Resolution:

Resolution:
rd
Page 173 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-26]):
Power Generator
rd
Page 174 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-27]).

4.119 is closed.

response.
Resolution:

Resolution:

rd
Page 175 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:
Design Basis This ISR issue consists of a total of 17 ISR Physical Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. Processes/ 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
rd
Page 176 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 177 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 178 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 179 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 180 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 181 of 8514

0235 ISR ADEQUA 0001 01

Significance


from the PSA.
Resolution:

Resolution:
rd
Page 182 of 8514

0235 ISR ADEQUA 0001 01

Significance

Resolution:

Resolution:
rd
Page 183 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
Resolution:
rd
Page 184 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-20]
description;
rupture disks;
Challenges;
Transport;
FMD Floor.
rd
Page 185 of 8514

0235 ISR ADEQUA 0001 01

Significance
analysed.
Resolution:

Resolution:

agreement
rd
Page 186 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

analysis should be:
accidents.
conditions.
planning.

following:
melt damage.
rd
Page 187 of 8514

0235 ISR ADEQUA 0001 01

Significance
accident.
Resolution:

project.

Resolution:

rd
Page 188 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:
[R-26]):
Power Generator
rd
Page 189 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-27]).

4.119 is closed.

response.
Resolution:

Resolution:

rd
Page 190 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:
Design Basis This ISR issue consists of a total of 17 ISR Assessment/ Beyond Design Basis Accidents Analysis (February 2008) Safety
rd
Page 191 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 192 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 193 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 194 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 195 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 196 of 8514

0235 ISR ADEQUA 0001 01

Significance


from the PSA.
Resolution:

rd
Page 197 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:

Resolution:
rd
Page 198 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
Resolution:
rd
Page 199 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-20]
description;
rupture disks;
Challenges;
Transport;
rd
Page 200 of 8514

0235 ISR ADEQUA 0001 01

Significance
FMD Floor.

analysed.
Resolution:

Resolution:

agreement
rd
Page 201 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

analysis should be:
accidents.
conditions.
planning.

following:
rd
Page 202 of 8514

0235 ISR ADEQUA 0001 01

Significance
melt damage.
accident.
Resolution:

project.

Resolution:

rd
Page 203 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:
[R-26]):
Power Generator
rd
Page 204 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-27]).

4.119 is closed.

response.
Resolution:

Resolution:
rd
Page 205 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:
Design Basis This ISR issue consists of a total of 17 ISR Sequence Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. Identification/ 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
rd
Page 206 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 207 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 208 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 209 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 210 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 211 of 8514

0235 ISR ADEQUA 0001 01

Significance


from the PSA.
Resolution:

rd
Page 212 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:

Resolution:
rd
Page 213 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
Resolution:
rd
Page 214 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-20]
description;
rupture disks;
Challenges;
Transport;
rd
Page 215 of 8514

0235 ISR ADEQUA 0001 01

Significance
FMD Floor.

analysed.
Resolution:

Resolution:

rd
Page 216 of 8514

0235 ISR ADEQUA 0001 01

Significance
agreement
Resolution:

analysis should be:
accidents.
conditions.
planning.
rd
Page 217 of 8514

0235 ISR ADEQUA 0001 01

Significance
following:
melt damage.
accident.
Resolution:

project.

Resolution:
rd
Page 218 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:
[R-26]):
Power Generator
rd
Page 219 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-27]).

4.119 is closed.

response.
Resolution:

Resolution:
rd
Page 220 of 8514

0235 ISR ADEQUA 0001 01

Significance

Resolution:
Design Basis This ISR issue consists of a total of 17 ISR Event Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. Sequences/ 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
rd
Page 221 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 222 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 223 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 224 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 225 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 226 of 8514

0235 ISR ADEQUA 0001 01

Significance


from the PSA.
Resolution:

rd
Page 227 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:

Resolution:
rd
Page 228 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
Resolution:
rd
Page 229 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-20]
description;
rupture disks;
Challenges;
Transport;
rd
Page 230 of 8514

0235 ISR ADEQUA 0001 01

Significance
FMD Floor.

analysed.
Resolution:

Resolution:

rd
Page 231 of 8514

0235 ISR ADEQUA 0001 01

Significance
agreement
Resolution:

analysis should be:
accidents.
conditions.
planning.
rd
Page 232 of 8514

0235 ISR ADEQUA 0001 01

Significance

following:
melt damage.
accident.
Resolution:

project.

Resolution:
rd
Page 233 of 8514

0235 ISR ADEQUA 0001 01

Significance

Resolution:
[R-26]):
Power Generator
rd
Page 234 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-27]).

4.119 is closed.

response.
Resolution:

rd
Page 235 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:
Design Basis This ISR issue consists of a total of 17 ISR Representativ Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. e Sequences/ 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
rd
Page 236 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 237 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 238 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 239 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 240 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 241 of 8514

0235 ISR ADEQUA 0001 01

Significance


from the PSA.
Resolution:
rd
Page 242 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:

Resolution:
rd
Page 243 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
Resolution:
rd
Page 244 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-20]
description;
rupture disks;
Challenges;
rd
Page 245 of 8514

0235 ISR ADEQUA 0001 01

Significance
Transport;
FMD Floor.

analysed.
Resolution:

Resolution:
rd
Page 246 of 8514

0235 ISR ADEQUA 0001 01

Significance
agreement
Resolution:

analysis should be:
accidents.
conditions.
rd
Page 247 of 8514

0235 ISR ADEQUA 0001 01

Significance
planning.

following:
melt damage.
accident.
Resolution:

project.

rd
Page 248 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:
[R-26]):
Power Generator
rd
Page 249 of 8514

0235 ISR ADEQUA 0001 01

Significance
[R-27]).

4.119 is closed.

response.
Resolution:

rd
Page 250 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:
Design Basis This ISR issue consists of a total of 17 ISR Codes/ SAMG Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
rd
Page 251 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 252 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 253 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 254 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 255 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 256 of 8514

0235 ISR ADEQUA 0001 01

Significance


from the PSA.
Resolution:
rd
Page 257 of 8514

0235 ISR ADEQUA 0001 01

Significance

Resolution:

Resolution:

Resolution:
rd
Page 258 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
melt.
rd
Page 259 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:
[R-20]
description;
rupture disks;
Challenges;
rd
Page 260 of 8514

0235 ISR ADEQUA 0001 01

Significance
Transport;
FMD Floor.

analysed.
Resolution:

Resolution:
rd
Page 261 of 8514

0235 ISR ADEQUA 0001 01

Significance

agreement
Resolution:

analysis should be:
accidents.
rd
Page 262 of 8514

0235 ISR ADEQUA 0001 01

Significance
conditions.
planning.

following:
melt damage.
accident.
Resolution:

project.

rd
Page 263 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:
[R-26]):
rd
Page 264 of 8514

0235 ISR ADEQUA 0001 01

Significance
Power Generator
[R-27]).

4.119 is closed.

response.
Resolution:
rd
Page 265 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:
D027 Severe Accident Overview: 2 1222 Margins for The resolution of this ISR Issue requires Gap 00847 was declared against Clause [R-1] NK38-REP-03680-10102,
and Beyond Severe discussion of three factors: 5.3.3 of CNSC RD-310 which requires: "Review of CNSC RD-310
Design Basis This ISR issue consists of a total of 17 ISR Accidents/ Beyond Design Basis Accidents Analysis (February 2008) Safety
rd
Page 266 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 267 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 268 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 269 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 270 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 271 of 8514

0235 ISR ADEQUA 0001 01

Significance


from the PSA.
Resolution:
rd
Page 272 of 8514

0235 ISR ADEQUA 0001 01

Significance

Resolution:

Resolution:

Resolution:
rd
Page 273 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
rd
Page 274 of 8514

0235 ISR ADEQUA 0001 01

Significance
melt.
Resolution:
[R-20]
description;
rupture disks;
Challenges;
rd
Page 275 of 8514

0235 ISR ADEQUA 0001 01

Significance
Transport;
FMD Floor.

analysed.
Resolution:

rd
Page 276 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

agreement
Resolution:

analysis should be:
accidents.
rd
Page 277 of 8514

0235 ISR ADEQUA 0001 01

Significance
conditions.
planning.

following:
melt damage.
accident.
Resolution:

project.

rd
Page 278 of 8514

0235 ISR ADEQUA 0001 01

Significance
Resolution:

Resolution:
[R-26]):
rd
Page 279 of 8514

0235 ISR ADEQUA 0001 01

Significance
Power Generator
[R-27]).

4.119 is closed.

response.
Resolution:
rd
Page 280 of 8514

0235 ISR ADEQUA 0001 01

Significance

Resolution:

Resolution:
D027 Severe Accident Overview: 2 847 Analysis of The resolution of this ISR Issue requires Gap 00847 was declared against Clause [R-1] NK38-REP-03680-10102,
and Beyond Beyond discussion of three factors: 5.3.3 of CNSC RD-310 which requires: "Review of CNSC RD-310
Design Basis This ISR issue consists of a total of 17 ISR Design Basis Beyond Design Basis Accidents Analysis (February 2008) Safety
Accident (BDBA) Gaps from two (2) Code Review Reports. Accident 1)Analysis of BDBAs for BDBAs shall be performed as part of the Analysis for Nuclear Power
rd
Page 281 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 282 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 283 of 8514

0235 ISR ADEQUA 0001 01

Significance
PRA [R-6].
rd
Page 284 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 285 of 8514

0235 ISR ADEQUA 0001 01

Significance
rd
Page 286 of 8514

0235 ISR ADEQUA 0001 01

Significance


from the PSA.
Resolution:
rd
Page 287 of 8514

0235 ISR ADEQUA 0001 01

Significance

Resolution:

Resolution:

Resolution:
rd
Page 288 of 8514

0235 ISR ADEQUA 0001 01

Significance
end of 2015 [R-25].

These should
melting;
explosions);
circuit;
rd
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melt.
Resolution:
[R-20]
description;
rupture disks;
rd
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Challenges;
Transport;
FMD Floor.

analysed.
Resolution:

rd
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Significance
Resolution:

agreement
Resolution:

analysis should be:
accidents.
rd
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Significance
conditions.
planning.

following:
melt damage.
accident.
Resolution:

project.

rd
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Significance
Resolution:

Resolution:
rd
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0235 ISR ADEQUA 0001 01

Significance
[R-26]):
Power Generator
[R-27]).

4.119 is closed.

response.
Resolution:
rd
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0235 ISR ADEQUA 0001 01

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Resolution:

Resolution:
D028 Systematic Overview: 3 1220 AOO results This ISR Issue deals with the analysis of Gap 00766 was declared against Clause [R-1] NK38-REP-03680-
Analysis of structure and Anticipated Operational Occurrences 5.24 of IAEA NS-R-1 which requires: The 10024,"Review Of IAEA NS-R-1
Anticipated This ISR issue consists of a total of 17 ISR presentation (AOOs). The ISR Gaps arise from a plant shall be designed to operate safely (October 2000) Safety Of
Operational Gaps from four (4) Code Review Reports. combination of Canadian and international within a defined range of parameters (for Nuclear Power Plants: Design
Occurrences codes. In general, the Canadian treatment example, of pressure, temperature, power), For Darlington Integrated
(AOOs) -Two (2) Gaps are from NK38-REP-03680- of AOOs (contained primarily in CNSC RD- and a minimum set of specified support Safety Review"
10024,"Review Of IAEA NS-R-1 (October 310 [R-6]) was developed and based on the features for safety systems (for example, [R-2] NK38-REP-03680-10102,
2000) Safety Of Nuclear Power Plants: international requirements. In this context, auxiliary feedwater capacity and an "Review of CNSC RD-310
Design For Darlington Integrated Safety it can be said that requirements for AOO emergency electrical power supply) shall be (February 2008) Safety
Review" [R-1], analysis in CNSC RD-310 [R-6] includes assumed to be available. The design shall Analysis for Nuclear Power
-One (1) Gap is from NK38-REP-03680- suggestions and good practice derived from be such that the response of the plant to a Plants"
10102, "Review of CNSC RD-310 international codes. wide range of anticipated operational [R-3] NK38-REP-03680-10021,
(February 2008) Safety Analysis for occurrences will allow safe operation or "Review Of IAEA NS-G-1.2
Nuclear Power Plants" [R-2], Compliance with CNSC RD-310 [R-6] and shutdown, if necessary, without the (January 2002) Safety
-Thirteen (13) Gaps from NK38-REP- generic rules regarding AOO analysis are necessity of invoking provisions beyond the Assessment And Verification
03680-10021, "Review Of IAEA NS-G-1.2 being pursued on an industry basis via the first, or at the most the second, level of For Nuclear Power Plants For
(January 2002) Safety Assessment And CANDU Owners Group (COG). This defence in depth. Darlington Integrated Safety
Verification For Nuclear Power Plants For industry effort has led to the issuance by The Code Review Report, NK38-REP- Review"
Darlington Integrated Safety Review" [R-3], COG of a Principles and Guidelines (P&G) 03680-10024, found that equipment [R-4] NK38-REP-03680-10109,
and document, COG-09-9030 [R-13], which malfunctions which have occurred during Review of CNSC RD-337
-One (1) Gap is from NK38-REP-03680- presents the utilities proposed common plant operation have been terminated by (September 2008) Design of
10109, Review of CNSC RD-337 approach for deterministic safety analysis Reactor Regulating System setback or New Nuclear Power Plants for
(September 2008) Design of New Nuclear and the movement towards RD-310 type stepback, which are considered to be the Darlington Integrated Safety
Power Plants for Darlington Integrated analysis for existing stations, including the first and second levels of defence in depth Review
Safety Review [R-4]. analysis of AOOs. but the governance* does not require [R-5] IAEA NS-R-1, Safety Of
analysis of process system effectiveness so Nuclear Power Plants: Design
rd
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Significance
Gaps from NK38-REP-03680- The principles and guidelines document Darlington safety analysis credits Shutdown [R-6] CNSC RD-310, Safety
10024,"Review Of IAEA NS-R-1 (October was developed in consultation with the Systems for some events and these are Analysis for Nuclear Power
2000) Safety Of Nuclear Power Plants: CNSC. As stated in a letter to OPG from considered the third level of defence. Plants
Design For Darlington Integrated Safety the CNSC [R-14]: CNSC staff further Crediting safety systems for some AOO is [R-7] IAEA NS-G-1.2, Safety
Review" [R-1]. confirmed its views that this P&G document an acceptable deviation as there are some Assessment And Verification
is suitable for improving safety analysis and AOOs for which SDSs will be actuated and For Nuclear Power Plants
Gap 00766 was declared against Clause for implementing RD-310. Existing OPG the plant will remain operable. However lack [R-8] CNSC RD-337, Design of
5.24 of IAEA NS-R-1 [R-5] which requires Action Item 2010OPG-05 deals with OPG of a requirement in the governance*for New Nuclear Power Plants
that the design shall be such that the compliance with CNSC RD-310 and analysis of the capability of the control [R-9] NK30-REP-03680-00005,
response of the plant to a wide range of analysis of AOOs. Action Item 2010OPG- systems for AOOs is a gap. Pickering NGS B Integrated
anticipated operational occurrences will 05 will also address Safety Analysis Safety Review Safety
allow safe operation or shutdown, if Improvement (SAI) activities which were Resolution: Gap 00766 is ongoing pending Analysis Review
necessary, without the necessity of previously associated with Action Item closure of Action Item 2010OPG-05 to [R-10] NK30-REP-03680-
invoking provisions beyond the first, or at 2010OPG-01 [R-14]. implement RD-310 by 2021 Q4**. The 00016, OPG Response to
the most the second, level of defence in governance* has been revised with a CNSC Comments on Pickering
depth. The Code Review Report [R-1] The scope of this ISR Issue will be resolved reference to an analysis guideline NGS-B Integrated Safety
found that Darlington credits Shut Down by completion of CNSC RD-310 compliance developed by the COG Safety Analysis Review Plant Design, Safety
Systems for some events and these are activities. Management action AR# Improvement Working Group. The Analysis, Safety Performance,
considered the third level of defence. 28127913 has been raised to track CNSC requirement to analyse the effectiveness of Ageing and Equipment
RD-310 compliance activities to completion level 1 and 2 defence in depth provisions for Qualification Safety Factor
Gap 00783 was declared against Clause in order to confirm that they satisfactorily AOOs is addressed in the COG Principles Reports and Discrepancy
5.71 of IAEA NS-R-1 [R-5] which requires resolved Issue D028. and Guidelines (P&G) for Deterministic Resolutions
demonstration that the management of Safety Analysis***. This P&G is referenced [R-11] NK38-REF-03680-
anticipated operational occurrences is OPG compliance with CNSC RD-310 (and in the Darlington Design Guide for Safety 0366713, Darlington Integrated
possible by automatic response of safety 2010OPG-05) is also discussed in ISR Assessment NK38-DG-03650.9-R002, Safety Review (ISR) Issue
systems in combination with prescribed Issue D030 Identification and Classification which establishes OPGs commitment to Prioritization under project
actions of the operator. The Code Review of Events per RD-310. comply with the requirements in the P&G. P1362
Report [R-1] found that such a [R-12] NK30-REP-00770-
demonstration has not been performed for Preferred Resolution: Gap 00783 was declared against Clause 00010, Pickering B Plant Life
Darlington. 5.71 of IAEA NS-R-1 which requires: The Extension - Benefit-cost
Confirm credited ongoing program has deterministic safety analysis shall include Analysis For Gap #511 -
Gap from NK38-REP-03680-10102, resolved Issue. the following: Malfunctions And Accidents
"Review of CNSC RD-310 (February 2008) (1) confirmation that operational limits and [R-13] COG-09-9030,
Safety Analysis for Nuclear Power Plants" Rationale: conditions are in compliance with the Principles & Guidelines for
[R-2]. assumptions and intent of the design for Deterministic Safety Analysis
The scope of this ISR Issue will be resolved normal operation of the plant; Used in Licensing of Current
Gap 00846 was declared against Clause by completion of CNSC RD-310 compliance (2) characterization of the PIEs (see CANDU Nuclear Power Plants
5.3.2 of CNSC RD-310 [R-6] which requires activities. Management action AR# Appendix I) that are appropriate for the Operating in Canada
that analysis for AOOs demonstrate that 28127913 has been raised to track CNSC design and site of the plant; [R-14] N-CORR-00531- 05255,
radiological doses to members of the public RD-310 compliance activities to completion (3) analysis and evaluation of event OPG Safety Analysis
do not exceed the established limits and in order to confirm that they satisfactorily sequences that result from PIEs; Improvement Activities, Part 3:
that the derived acceptance criteria are resolved Issue D028. (4) comparison of the results of the analysis Accident Analysis Closure of
met. The Code Review Report [R-2] found with radiological acceptance criteria and Action Item 20100PG-01
that the lack of a controlled analysis for design limits; [R-15] N-CORR-00531-04991,
AOOs is a Gap. This Gap is also (5) establishment and confirmation of the Progress Report on OPG
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associated with Issue D030, Identification design basis; and Safety Analysis Improvement
and Classification of Events per CNSC RD- (6) demonstration that the management of Activities, Part 3: Accident
310. anticipated operational occurrences and Analysis - Action item
design basis accidents is possible by 2010OPG-01 and RD-310
automatic response of safety systems in Implementation Plans - Action
Gaps from NK38-REP-03680-10021, combination with prescribed actions of the item 2010OPG-05 and Request
"Review Of IAEA NS-G-1.2 (January 2002) operator. for Closure of Action item
Safety Assessment And Verification For The Code Review Report, NK38-REP- 2010OPG-01
Nuclear Power Plants For Darlington 03680-10024, found that the governance*
Integrated Safety Review" [R-3]. complies with requirements 1 through 6.
However for requirement 6 demonstration
Gaps 01209 to 01221 were declared for AOOs has not been performed for the
against Clauses 4.66 to 4.71, 4.78, 4.84 to response of safety-related control/process
4.86, 4.96, 4.97, and 4.101 of IAEA NS-G- systems.
1.2 [R-7] which contain various
requirements for AOOs. Each of these ISR Resolution: Gap 00783 is ongoing pending
Gaps share the same Gap Discussion. The closure of Action Item 2010OPG-05 to
Code Review Report [R-3] found that a implement RD-310 by 2021 Q4**. The
systematic demonstration of the governance* has been revised with a
management of AOOs has not been reference to an analysis guideline
undertaken for Darlington. developed by the COG Safety Analysis
Improvement Working Group. The
Gap from NK38-REP-03680-10109, requirement to analyse the effectiveness of
Review of CNSC RD-337 (September the automatic response of process systems
2008) Design of New Nuclear Power Plants in combination with operator actions for
for Darlington Integrated Safety Review [R- AOOs is addressed in the COG Principles
4]. and Guidelines (P&G) for Deterministic
Safety Analysis. *** This P&G is referenced
Gap 01457 was declared against Clause in the Darlington Design Guide for Safety
7.3.2 of CNSC RD-337 [R-8] which Assessment NK38-DG-03650.9-R002,
contains various requirements for AOOs, which establishes OPGs commitment to
including: The design includes provisions comply with the requirements in the P&G.
such that releases to the public following an
AOO do not exceed the dose acceptance Gap 00846 was declared against Clause
criteria. The Code Review Report [R-4] 5.3.2 of CNSC RD-310 which requires:
found that AOOs have not been analysed. Anticipated Operational Occurrences and
Design Basis Accidents Analysis for AOOs
Gap Summary: and DBAs shall demonstrate that:
1. Radiological doses to members of the
The scope of this ISR Issue is a lack of a public do not exceed the established limits;
systematic analysis of Anticipated and
Operational Occurances (AOOs) for the 2. The derived acceptance criteria,
Darlington Nuclear Generating Station established in accordance with 5.3.4 are
(DNGS) as defined in IAEA NS-R-1 [R-5], met.
CNSC RD-310 [R-6], IAEA NS-G-1.2 [R-7], The Code Review Report, NK38-REP-
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and CNSC RD-337 [R-8]. 03680-10102, found that the lack of a
controlled analysis for AOOs is a Gap. This
Gap is also associated with Issue D030,
Identification and Classification of Events
per CNSC RD-310.
Resolution: Gap 00846 is ongoing pending

closure of Action Item 2010OPG-05 to
implement RD-310 by 2021 Q4**. The
governance* has been revised with a
reference to an analysis guideline
developed by the COG Safety Analysis
Improvement Working Group. The RD-310
requirement to analyse AOOs to
demonstrate that acceptance criteria are
met is addressed in the COG Principles and
Guidelines (P&G) for Deterministic Safety
Analysis***. This P&G is referenced in the
Darlington Design Guide for Safety
Assessment NK38-DG-03650.9-R002,
which establishes OPGs commitment to
comply with the requirements in the P&G.
Gaps 01209 to 01221 were declared

against Clauses 4.66 to 4.71, 4.78, 4.84 to
4.86, 4.96, 4.97, and 4.101 of IAEA NS-G-
1.2 which contain various requirements for
AOOs. Each of these ISR Gaps share the
same Gap Discussion. The Code Review
Report, NK38-REP-03680-10021, found
that a systematic demonstration of the
management of AOOs by process systems
has not been undertaken for Darlington.
Clause 4.66 requires: The plant conditions

considered in the design basis analysis
include anticipated operational occurrences
and design basis accidents (DBAs). The
division is based on the frequency of the
occurrence.

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requirement to analyse AOO based on
frequency of occurrence is addressed in the
COG Principles and Guidelines (P&G) for
Deterministic Safety Analysis***. This P&G
is referenced in the Darlington Design
Guide for Safety Assessment NK38-DG-
03650.9-R002, which establishes OPGs
commitment to comply with the
requirements in the P&G.
Clause 4.67 requires: Anticipated

operational occurrences are those events
that are more complex than the
manoeuvres which are carried out during
normal operation and that have the potential
to challenge the safety of the reactor. These
occurrences might be expected to occur at
least once during the lifetime of the plant.
Generally they have a frequency of
occurrence greater than 10^-2 per reactor-
year.

requirement to analyse AOO as events
more complex than normal operation
manoeuvres and more frequent than 10-2
per reactor year is addressed in the COG
Principles and Guidelines (P&G) for
Clause 4.68 requires: Design basis
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accidents have a lower frequency than
anticipated operational occurrences. They
would not be expected to occur during the
lifetime of the plant but, in accordance with
the principle of defence in depth, they have
been considered in the design of the
nuclear power plant. The DBAs have a
frequency of occurrence in the range of 10^-
2 to 10^-5 per reactor-year, although there
are some groups of PIEs that are
traditionally included in the design basis
analysis that may have lower frequencies.

requirement to analyse DBAs as events in
the range less frequent than AOO but more
frequent than 10-5 per reactor year is
addressed in the COG Principles and
comply with the requirements in the P&G
Clause 4.69 requires: The aim of the

design basis analysis should be to provide a
robust demonstration of the fault tolerance
of the engineering design and the
effectiveness of the safety systems. This is
done by carrying out a conservative
analysis which should take account of the
uncertainties in the modelling.

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requirement to analyse AOOs and DBAs
accounting conservatively for uncertainties
in modelling to determine the effectiveness
of safety systems is addressed in the COG
requirements in the P&G. Note that the
guidelines allow realistic assumptions for
the analysis of process system capability for
AOOs. The guidelines describe the classes
of modelling uncertainties and how they are
accounted for in the analysis methods such
as Limit of Operating Envelope (LOE) and
Best Estimate And Uncertainty (BEAU). It is
acknowledged that discussions of this are
ongoing between the industry and CNSC.
Clause 4.70 requires: For many PIEs the

control systems will compensate for the
effects of the event without a reactor trip or
other demand being place on the safety
systems (Level 2 of defence in depth).
However, the anticipated operational
occurrences category should include all the
PIEs which might be expected to occur
during the lifetime of the plant and for which
operation can resume after rectification of
the fault.

Improvement Working Group The
requirement to include as AOOs, events
that control systems will mitigate without a
demand on the safety systems and for
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which operation can resume after
rectification of the initiating fault is
Clause 4.71 requires: Typical examples of

PIEs leading to anticipated operational
occurrences could include those given
below. This list is broadly indicative. The
actual list will depend on the type of reactor
and the actual design of the plant systems:
-Increase in reactor heat removal:
inadvertent opening of steam relief valves;
secondary pressure control malfunctions
leading to an increase in steam flow rate;
feedwater system malfunctions leading to
an increase in the heat removal rate.
-Decrease in reactor heat removal:
feedwater pump trips; reduction in the
steam flow rate for various reasons (control
malfunctions, main steam valve closure,
turbine trip, loss of external load, loss of
power, loss of condenser vacuum).
-Decrease in reactor coolant system flow
rate: trip of one main coolant pump;
inadvertent isolation of one main coolant
system loop (if applicable).
-Reactivity and power distribution
anomalies: inadvertent control rod
withdrawal; boron dilution due to a
malfunction in the volume control system
(for a PWR); wrong positioning of a fuel
assembly.
-Increase in reactor coolant inventory:
malfunctions of the chemical and volume
control system.
-Decrease in reactor coolant inventory: very
small loss of coolant accident (LOCA) due
to the failure of an instrument line.
-Release of radioactive material from a
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subsystem or component: minor leakage
from a radioactive waste system.

that have the potential to adversely affect
the fundamental safety functions of control
of reactivity, removal of heat from the fuel,
and containment of radioactive releases
and that can potentially challenge the safety
or control functions of the NPP including:
1. Component and system failures or
malfunctions;
2. Operator errors; and
3. Common-cause internally and
externally initiated events
is addressed in the COG Principles and
Clause 4.78 requires: The safety analysis

of anticipated operational occurrences and
DBAs should demonstrate that the safety
systems are able to fulfil the safety
requirements in that they can:
-Shut down the reactor and maintain it in
the safe shutdown condition during and
after DBA conditions.
-Remove residual heat from the core after
reactor shutdown from all operational states
and all DBA conditions.
-Reduce the potential for the release of
radioactive material and ensure that any
releases are below prescribed limits during
operational states and below acceptable
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limits during DBA conditions.

requirement to analyse the effectiveness of
safety systems for AOO events to control
reactivity, remove heat from the fuel, and
contain radioactive releases is addressed in
the COG Principles and Guidelines (P&G)
for Deterministic Safety Analysis***. This
P&G is referenced in the Darlington Design
requirements in the P&G. This is in addition
to analysing the effectiveness of the control
systems for AOO events.

carried out for anticipated operational
occurrences is essentially the same as for
accidents. However, for the former, the
analysis need not have all the conservatism
of the analysis for DBAs. For example, the
analysis of anticipated operational
occurrences would not necessarily assume
the unavailability of all non-safety systems
and equipment.

requirement that analysis of AOO credit
control systems and use realistic
assumptions is addressed in the COG
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Clause 4.85 requires: In addition, the

anticipated operational occurrences should
not lead to any unnecessary challenges to
safety equipment primarily designed for
protection in the event of DBAs.

requirement that AOO not lead to
unnecessary challenges to safety systems

DBAs should use suitable neutron physics,
thermal-hydraulic, structural and
radiological computer codes to determine
the response of the reactor to the
operational occurrences and accidents
considered.

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requirement that AOO analysis use qualified
computer codes that have been
demonstrated to be applicable for use with
validation of key phenomena is addressed
in the COG Principles and Guidelines (P&G)

of the anticipated operational occurrences
should also include many of the
conservative assumptions of the
deterministic DBA analysis, especially those
which relate to the systems for maintaining
critical safety functions during these
transients. However, it is not necessary to
assume that all non-safety systems and
equipment are unavailable and that credit
cannot be taken for the control systems in
mitigating the effects of the initiating event
unless the PIE makes these systems
unavailable.

requirement that analysis of AOO use
conservative DBA assumptions for safety
systems but make realistic credit for control
systems unless the event includes loss of
control is addressed in the COG Principles
and Guidelines (P&G) for Deterministic
Safety Analysis***. This P&G is referenced
in the Darlington Design Guide for Safety
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Clause 4.97 requires: The results of the

assessment should be structured and
presented in an appropriate format to
provide a good understanding of the course
of the event and to allow easy checking of
the individual acceptance criteria.

requirement that AOO analysis be
documented in a manner that is retrievable
for the lifetime of the station, facilitates
independent review by qualified experts,
provides traceability, and is reproducible
including a set of the important parameters
in the course of a transient as a function of
time to evaluate the status of the safety
functions and the fulfillment of the
acceptance criteria starting from the initial
steady state up to the long term safe stable
condition is addressed in the COG
Clause 4.101 requires: The radiological

acceptance criteria for anticipated
operational occurrences are typically more
restrictive since their frequencies are
higher. In general, there should be no
failures of any of the physical barriers (fuel
matrix, fuel cladding, reactor coolant
pressure boundary or containment) and no
fuel damage (or no additional fuel damage if
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minor fuel leakage, within operational limits,
already exists).

requirement that AOOs meet the lower dose
target and fitness for service criteria is

7.3.2 of CNSC RD-337 which requires: The
design includes provisions such that
releases to the public following an AOO do
not exceed the dose acceptance criteria.
The design also provides that, to the extent

practicable, SSCs not involved in the
initiation of an AOO will remain operable
following the AOO.
The response of the plant to a wide range of

AOOs allows safe operation or shutdown, if
necessary, without the need to invoke
provisions beyond defence-in-depth Level 1
or, at most, Level 2.
The facility layout is such that equipment is

placed at the most suitable location to
ensure its immediate availability when
operator intervention is required, allowing
for safe and timely access during an AOO.

03680-10109, found that the governance*
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included the main control room and field
operation requirement but AOOs have not
been analysed for process system
effectiveness to maintain operability of
SCCs without requiring safety system
action.

requirement that the design be analysed for
AOO against AOO dose targets, for fitness
for service, without challenging safety
systems and to determine whether there is
sufficient time for operator actions to be
performed safely is addressed in the COG
* Governance refers to OPG and Darlington

programs, standards, procedures, and
design guides. In this specific usage,
governance refers to the Darlington Design
Guide for Safety Assessment, DG-9.
** In October 2009, the CNSC requested a

plan for implementation of RD-310 at
Darlington (DNGS), with the aim of eventual
incorporation in the Stations operating
license [CNSC Letter, P.A. Webster to S.A.
Seedhouse Implementation of RD-310
Safety Analysis for Nuclear Power Plants,
New Action Item 20091316 October 7,
2009. CD# N-CORR-00531-14827]. A
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detailed plan for OPG implementation of
RD-310 was submitted in December, 2012
[OPG Letter W.M. Elliot to M. Santini and
P.A. Webster OPG RD-310 Implementation
Plans - Action Item 2010OPG-05
December 10, 2012 CD# N-CORR-00531-
05970]. It includes a timeline for OPG
implementation of RD-310 in safety analysis
and its incorporation into the upgrade of the
Darlington Safety Report. The timeline
makes a commitment to have the Safety
Report comprehensively comply with RD-
310 by Q4 2021. The accident specific
schedule is shown below:
-Common mode failures will be upgraded by
2016 Q4.
- Control failures and electrical failures will
be upgraded by 2017 Q2.
- Shutdown cooling failures will be upgraded
by 2018 Q2.
- Out-of-core small LOCA will be upgraded
by 2018 Q4.
- HTS breaks outside containment and
shield cooling failures will be upgraded by
2019 Q2.
- Moderator system failures will be
upgraded by 2019 Q4.
- In-core LOCA and secondary side failures
will be upgraded by 2020 Q2.
- Fuel handling and support system failures
- The summaries in the main sections of the
Safety Report will be upgraded by 2021 Q4.
The existing Appendices 12, 13, 14, and 15
on event classification, computer codes,
LOCA methodology and HTS aging
respectively will be amalgamated within the
accident Appendices 1 to 11.
*** Compliance with CNSC RD-310 [CNSC

RD-310, Safety Analysis for Nuclear Power
Plants] is being pursued on an industry
basis via the CANDU Owners Group
(COG). This industry effort has led to the
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issuance by COG of a "Principles and
Guidelines" (P&G) document, COG-09-
9030 [COG-09-9030 R01, Principles &
Guidelines for Deterministic Safety Analysis
Used in Licensing of Current CANDU
Nuclear Power Plants Operating in
Canada], which presents the utilities
proposed common approach for
deterministic safety analysis and the
movement towards RD-310 type analysis
for existing stations.
The principles and guidelines document

was developed in consultation with the
CNSC. As stated in a letter to OPG from the
CNSC [N-CORR-00531-05255, "OPG
Safety Analysis Improvement Activities, Part
3: Accident Analysis Closure of Action Item
2010OPG-01"]: "CNSC staff further
confirmed its views that this P&G document
for implementing RD-310". Formal
submission of Revision 2 of the P&G to the
CNSC is planned for 2013.
This P&G is referenced in the Darlington

Design Guide for Safety Assessment NK38-
DG-03650.9-R002 to close gaps in the
governance* related to deterministic safety
analysis.
D028 Systematic Overview: 3 1209 Anticipated This ISR Issue deals with the analysis of Gap 00766 was declared against Clause [R-1] NK38-REP-03680-
Analysis of Operational Anticipated Operational Occurrences 5.24 of IAEA NS-R-1 which requires: The 10024,"Review Of IAEA NS-R-1
Anticipated This ISR issue consists of a total of 17 ISR Occurrences (AOOs). The ISR Gaps arise from a plant shall be designed to operate safely (October 2000) Safety Of
Operational Gaps from four (4) Code Review Reports. analysis combination of Canadian and international within a defined range of parameters (for Nuclear Power Plants: Design
Occurrences required codes. In general, the Canadian treatment example, of pressure, temperature, power), For Darlington Integrated
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per CNSC RD-310.


4.86, 4.96, 4.97, and 4.101 of IAEA NS-G-
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occurrence.


year.

requirement to analyse AOO as events
more complex than normal operation
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Significance
manoeuvres and more frequent than 10-2
per reactor year is addressed in the COG
Clause 4.68 requires: Design basis

accidents have a lower frequency than
anticipated operational occurrences. They
would not be expected to occur during the
lifetime of the plant but, in accordance with
the principle of defence in depth, they have
been considered in the design of the
nuclear power plant. The DBAs have a
frequency of occurrence in the range of 10^-
2 to 10^-5 per reactor-year, although there
are some groups of PIEs that are
traditionally included in the design basis
analysis that may have lower frequencies.

requirement to analyse DBAs as events in
the range less frequent than AOO but more
frequent than 10-5 per reactor year is
comply with the requirements in the P&G
Clause 4.69 requires: The aim of the

design basis analysis should be to provide a
robust demonstration of the fault tolerance
rd
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Significance
of the engineering design and the
effectiveness of the safety systems. This is
done by carrying out a conservative
analysis which should take account of the
uncertainties in the modelling.

requirement to analyse AOOs and DBAs
accounting conservatively for uncertainties
in modelling to determine the effectiveness
of safety systems is addressed in the COG
requirements in the P&G. Note that the
guidelines allow realistic assumptions for
the analysis of process system capability for
AOOs. The guidelines describe the classes
of modelling uncertainties and how they are
accounted for in the analysis methods such
as Limit of Operating Envelope (LOE) and
Best Estimate And Uncertainty (BEAU). It is
acknowledged that discussions of this are
ongoing between the industry and CNSC.
Clause 4.70 requires: For many PIEs the

control systems will compensate for the
effects of the event without a reactor trip or
other demand being place on the safety
systems (Level 2 of defence in depth).
However, the anticipated operational
occurrences category should include all the
PIEs which might be expected to occur
during the lifetime of the plant and for which
operation can resume after rectification of
the fault.
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0235 ISR ADEQUA 0001 01

Significance

Improvement Working Group The
that control systems will mitigate without a
demand on the safety systems and for
which operation can resume after
rectification of the initiating fault is
Clause 4.71 requires: Typical examples of

PIEs leading to anticipated operational
occurrences could include those given
below. This list is broadly indicative. The
actual list will depend on the type of reactor
and the actual design of the plant systems:
-Increase in reactor heat removal:
inadvertent opening of steam relief valves;
secondary pressure control malfunctions
leading to an increase in steam flow rate;
feedwater system malfunctions leading to
an increase in the heat removal rate.
-Decrease in reactor heat removal:
feedwater pump trips; reduction in the
steam flow rate for various reasons (control
malfunctions, main steam valve closure,
turbine trip, loss of external load, loss of
power, loss of condenser vacuum).
-Decrease in reactor coolant system flow
rate: trip of one main coolant pump;
inadvertent isolation of one main coolant
system loop (if applicable).
-Reactivity and power distribution
anomalies: inadvertent control rod
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0235 ISR ADEQUA 0001 01

Significance
withdrawal; boron dilution due to a
malfunction in the volume control system
(for a PWR); wrong positioning of a fuel
assembly.
-Increase in reactor coolant inventory:
malfunctions of the chemical and volume
control system.
-Decrease in reactor coolant inventory: very
small loss of coolant accident (LOCA) due
to the failure of an instrument line.
-Release of radioactive material from a
subsystem or component: minor leakage
from a radioactive waste system.

that have the potential to adversely affect
the fundamental safety functions of control
of reactivity, removal of heat from the fuel,
and containment of radioactive releases
and that can potentially challenge the safety
or control functions of the NPP including:
1. Component and system failures or
malfunctions;
2. Operator errors; and
3. Common-cause internally and
externally initiated events

DBAs should demonstrate that the safety
systems are able to fulfil the safety
rd
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Significance
requirements in that they can:
-Shut down the reactor and maintain it in
the safe shutdown condition during and
after DBA conditions.
-Remove residual heat from the core after
reactor shutdown from all operational states
and all DBA conditions.
-Reduce the potential for the release of
radioactive material and ensure that any
releases are below prescribed limits during
operational states and below acceptable
limits during DBA conditions.

requirement to analyse the effectiveness of
safety systems for AOO events to control
reactivity, remove heat from the fuel, and
contain radioactive releases is addressed in
the COG Principles and Guidelines (P&G)
requirements in the P&G. This is in addition
to analysing the effectiveness of the control
systems for AOO events.

carried out for anticipated operational
occurrences is essentially the same as for
accidents. However, for the former, the
analysis need not have all the conservatism
of the analysis for DBAs. For example, the
analysis of anticipated operational
occurrences would not necessarily assume
the unavailability of all non-safety systems
and equipment.
rd
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0235 ISR ADEQUA 0001 01

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requirement that analysis of AOO credit
control systems and use realistic
assumptions is addressed in the COG
Clause 4.85 requires: In addition, the

anticipated operational occurrences should
not lead to any unnecessary challenges to
safety equipment primarily designed for
protection in the event of DBAs.

requirement that AOO not lead to
unnecessary challenges to safety systems

DBAs should use suitable neutron physics,
thermal-hydraulic, structural and
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radiological computer codes to determine
the response of the reactor to the
operational occurrences and accidents
considered.

requirement that AOO analysis use qualified
computer codes that have been
demonstrated to be applicable for use with
validation of key phenomena is addressed
in the COG Principles and Guidelines (P&G)

of the anticipated operational occurrences
should also include many of the
conservative assumptions of the
deterministic DBA analysis, especially those
which relate to the systems for maintaining
critical safety functions during these
transients. However, it is not necessary to
assume that all non-safety systems and
equipment are unavailable and that credit
cannot be taken for the control systems in
mitigating the effects of the initiating event
unless the PIE makes these systems
unavailable.

rd
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Significance
requirement that analysis of AOO use
conservative DBA assumptions for safety
systems but make realistic credit for control
systems unless the event includes loss of
control is addressed in the COG Principles
and Guidelines (P&G) for Deterministic
Safety Analysis***. This P&G is referenced
in the Darlington Design Guide for Safety
Clause 4.97 requires: The results of the

assessment should be structured and
presented in an appropriate format to
provide a good understanding of the course
of the event and to allow easy checking of
the individual acceptance criteria.

requirement that AOO analysis be
documented in a manner that is retrievable
for the lifetime of the station, facilitates
independent review by qualified experts,
provides traceability, and is reproducible
including a set of the important parameters
in the course of a transient as a function of
time to evaluate the status of the safety
functions and the fulfillment of the
acceptance criteria starting from the initial
steady state up to the long term safe stable
condition is addressed in the COG
rd
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Significance
Clause 4.101 requires: The radiological

acceptance criteria for anticipated
operational occurrences are typically more
restrictive since their frequencies are
higher. In general, there should be no
failures of any of the physical barriers (fuel
matrix, fuel cladding, reactor coolant
pressure boundary or containment) and no
fuel damage (or no additional fuel damage if
minor fuel leakage, within operational limits,
already exists).

requirement that AOOs meet the lower dose
target and fitness for service criteria is

7.3.2 of CNSC RD-337 which requires: The
design includes provisions such that
releases to the public following an AOO do
not exceed the dose acceptance criteria.
The design also provides that, to the extent

practicable, SSCs not involved in the
initiation of an AOO will remain operable
following the AOO.
The response of the plant to a wide range of

AOOs allows safe operation or shutdown, if
necessary, without the need to invoke
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0235 ISR ADEQUA 0001 01

Significance
provisions beyond defence-in-depth Level 1
or, at most, Level 2.
The facility layout is such that equipment is

placed at the most suitable location to
ensure its immediate availability when
operator intervention is required, allowing
for safe and timely access during an AOO.

03680-10109, found that the governance*
included the main control room and field
operation requirement but AOOs have not
been analysed for process system
effectiveness to maintain operability of
SCCs without requiring safety system
action.

requirement that the design be analysed for
AOO against AOO dose targets, for fitness
for service, without challenging safety
systems and to determine whether there is
sufficient time for operator actions to be
performed safely is addressed in the COG
* Governance refers to OPG and Darlington

programs, standards, procedures, and
design guides. In this specific usage,
governance refers to the Darlington Design
Guide for Safety Assessment, DG-9.
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** In October 2009, the CNSC requested a

plan for implementation of RD-310 at
Darlington (DNGS), with the aim of eventual
incorporation in the Stations operating
license [CNSC Letter, P.A. Webster to S.A.
Seedhouse Implementation of RD-310
Safety Analysis for Nuclear Power Plants,
New Action Item 20091316 October 7,
2009. CD# N-CORR-00531-14827]. A
detailed plan for OPG implementation of
RD-310 was submitted in December, 2012
[OPG Letter W.M. Elliot to M. Santini and
P.A. Webster OPG RD-310 Implementation
Plans - Action Item 2010OPG-05
December 10, 2012 CD# N-CORR-00531-
05970]. It includes a timeline for OPG
implementation of RD-310 in safety analysis
and its incorporation into the upgrade of the
Darlington Safety Report. The timeline
makes a commitment to have the Safety
Report comprehensively comply with RD-
310 by Q4 2021. The accident specific
schedule is shown below:
-Common mode failures will be upgraded by
2016 Q4.
- Control failures and electrical failures will
be upgraded by 2017 Q2.
- Shutdown cooling failures will be upgraded
by 2018 Q2.
- Out-of-core small LOCA will be upgraded
by 2018 Q4.
- HTS breaks outside containment and
shield cooling failures will be upgraded by
2019 Q2.
- Moderator system failures will be
upgraded by 2019 Q4.
- In-core LOCA and secondary side failures
- Fuel handling and support system failures
- The summaries in the main sections of the
Safety Report will be upgraded by 2021 Q4.
The existing Appendices 12, 13, 14, and 15
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0235 ISR ADEQUA 0001 01

Significance
on event classification, computer codes,
LOCA methodology and HTS aging
respectively will be amalgamated within the
accident Appendices 1 to 11.
*** Compliance with CNSC RD-310 [CNSC

RD-310, Safety Analysis for Nuclear Power
Plants] is being pursued on an industry
basis via the CANDU Owners Group
(COG). This industry effort has led to the
issuance by COG of a "Principles and
Guidelines" (P&G) document, COG-09-
9030 [COG-09-9030 R01, Principles &
Guidelines for Deterministic Safety Analysis
Used in Licensing of Current CANDU
Nuclear Power Plants Operating in
Canada], which presents the utilities
proposed common approach for
deterministic safety analysis and the
movement towards RD-310 type analysis
for existing stations.
The principles and guidelines document

was developed in consultation with the
CNSC. As stated in a letter to OPG from the
CNSC [N-CORR-00531-05255, "OPG
Safety Analysis Improvement Activities, Part
3: Accident Analysis Closure of Action Item
2010OPG-01"]: "CNSC staff further
confirmed its views that this P&G document
for implementing RD-310". Formal
submission of Revision 2 of the P&G to the
CNSC is planned for 2013.
This P&G is referenced in the Darlington

Design Guide for Safety Assessment NK38-
DG-03650.9-R002 to close gaps in the
governance* related to deterministic safety
analysis.
D028 Systematic Overview: 3 1210 Definition of This ISR Issue deals with the analysis of Gap 00766 was declared against Clause [R-1] NK38-REP-03680-
Analysis of AOOs Anticipated Operational Occurrences 5.24 of IAEA NS-R-1 which requires: The 10024,"Review Of IAEA NS-R-1
Anticipated This ISR issue consists of a total of 17 ISR (AOOs). The ISR Gaps arise from a plant shall be designed to operate safely (October 2000) Safety Of
Operational Gaps from four (4) Code Review Reports. combination of Canadian and international within a defined range of parameters (for Nuclear Power Plants: Design
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Significance
Occurrences codes. In general, the Canadian treatment example, of pressure, temperature, power), For Darlington Integrated
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per CNSC RD-310.

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4.86, 4.96, 4.97, and 4.101 of IAEA NS-G-

occurrence.


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Document I

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RETENTION: P

November 11, 2014

File No.: NK38-00531 P

Dear Mr. Rinfret:

Darlington NGS Global Assessment Update

Associated with OPG-STD-0031, Correspondence Standards

1. OPG Report, NK38-REP-03680-10203 R000, Darlington NGS Global

2. OPG Letter, D. Reiner and B. Duncan to F. Rinfret, Darlington NGS Request

3. OPG Letter, D. Reiner and B. Duncan to F. Rinfret, Darlington NGS Integrated

4. OPG Letter, D. Reiner to F. Rinfret, Request for CNSC Acceptance of the

5. OPG Letter, , D. Reiner to F. Rinfret, Darlington NGS Integrated Safety Review

6. OPG Report, NK38-REP-03680-10186 R000, Darlington NGS - Global

DARLINGTON NGS GLOBAL ASSESSMENT - TECHNICAL BASIS DOCUMENT

Darlington NGS Global Assessment -

0235 TBD DNGSGA 0002 00

Addendum to the Darlington NGS Global Assessment - Technical Basis

Addendum to the Darlington NGS

Prepared by: 2014 05 29

Reviewed by: 2014 05 29

Approved by: 2014 05 29

0235 TBD DNGSGA 0002 00

Addendum to the Darlington NGS Global Assessment - Technical Basis

0235 TBD DNGSGA 0002 00

Addendum to the Darlington NGS Global Assessment - Technical Basis

Revision Summary ...................................................................................................................... 2

1.0 INTRODUCTION .......................................................................................................... 4

2.0 ASSESSMENT ............................................................................................................. 5

3.0 SUMMARY ................................................................................................................... 6

0235 TBD DNGSGA 0002 00

Addendum to the Darlington NGS Global Assessment - Technical Basis

This addendum provides a summary of assessments performed on the seventy-seven (77)

0235 TBD DNGSGA 0002 00

Addendum to the Darlington NGS Global Assessment - Technical Basis

Adequacy of Actions to Address Open ISR Issues

The assessment is documented in Revision 01 of the ISR Adequacy Report [R-4].

Assessment of Acceptable Deviations

The detailed aggregate assessment of Acceptable Deviations is provided in the following

0235 TBD DNGSGA 0002 00

Addendum to the Darlington NGS Global Assessment - Technical Basis

- Evaluation of Seismic, Pressure Boundary and Accident Management ISR

- Evaluation of Human Performance ISR Acceptable Deviation Issues for Aggregate

- Evaluation of Special Safety Systems ISR Acceptable Deviation Issues for

- Acceptable Deviations Aggregate Review [R-14].

0235 TBD DNGSGA 0002 00

Addendum to the Darlington NGS Global Assessment - Technical Basis

[R-2] OPG Report, NK38-REP-03680-10185 R000, Darlington NGS Integrated

[R-3] OPG Procedure, N-PROC-LE-0005 R003, Nuclear Refurbishment Integrated Safety

[R-5] OPG Report, NK38-REP-03680-10200, Adequacy Review of ISR Condition Component

[R-6] OPG Instruction, N-INS-00770-10004 R001, Nuclear Refurbishment Gap Resolution

[R-7] OPG Report, NK38-REP-03680-10202 R000, Darlington NGS Defence In Depth

[R-8] OPG Report, NK38-REP-03680-10203 R000, Darlington Global NGS Assessment -

[R-9] OPG Report, NK38-REP-03680-10186 R00, Darlington NGS Global Assessment

[R-10] OPG Report, NK38-REP-03680-10197 R01, Evaluation of Seismic, Pressure Boundary

[R-11] OPG Report, NK38-REP-03680-10198 R00, Evaluation of Human Performance ISR

[R-13] OPG Report, NK38-REP-03680-10199 R01, Evaluation of Darlington NGS Fire

0235 TBD DNGSGA 0002 00

Addendum to the Darlington NGS Global Assessment - Technical Basis

[R-14] OPG Report, NK38-REP-03680-10195 R01, Acceptable Deviations Aggregate Review,

[R-15] OPG Correspondence, N-CORR-00531-16798, OPG Letter, B. Duncan to F. Rinfret,

0235 TBD DNGSGA 0002 00

Addendum to the Darlington NGS Global Assessment - Technical Basis

0235 TBD DNGSGA 0002 00

Addendum to the Darlington NGS Global Assessment - Technical Basis