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The purpose of this report is to fulfill regulatory requirements on environmental protection in accordance with Licence Condition 3.3 of the Bruce A and Bruce B Power Reactor Operating Licence (PROL) Bruce Nuclear Generating Stations A and B 18:00/2020, and the CNSC Regulatory Document REGDOC‑3.1.1 Reporting Requirements for Nuclear Power Plants, Section 3.5. Environmental protection at Bruce Power is managed under the environmental management system which encompasses; effluent and emissions control (releases) and monitoring, routine environment assessment and monitoring, and environmental risk assessment to ensure the protection of the public and the environment. Monitoring and assessment includes radiological, non‑radiological and hazardous substances as well as evaluates the effect on human and non‑human biota. Environmental Monitoring is an important part of environmental protection at a nuclear facility. It ensures, through measurement, sampling and analysis, that the health of the environment and people are protected. Years of study have unequivocally determined that the Bruce site does not pose radiological risk to plants, animals and people near the site. To support Bruce Power’s licence renewal application, an Environmental Assessment (EA) under the Nuclear Safety and Control Act (NSCA) was conducted to determine if the applicant (Bruce Power) has provided adequate protection of the environment and the health of people. Based on the EA under the NSCA conducted, CNSC staff concluded that Bruce Power has and will continue to make adequate provision for the protection of the environment and the health of persons.
This report describes the effluent and environmental monitoring programs related to Bruce Power’s operations; these programs, which are within Bruce Power’s environmental management framework, are developed, implemented, periodically reviewed, and where possible enhanced to ensure Environmental Protection. This report meets the content and timing requirement of REGDOC‑3.1.1.
Bruce Power complies with relevant Federal and Provincial environmental legislation, regulations, and other requirements; specifically with regulations and programs which protect human health and the environment under the Canadian Environmental Protection Act, Nuclear Safety and Control Act. As well, Bruce Power complies with the Environmental Compliance Approvals and Permits issued by the Ontario Ministry of Environment and Climate Change.
REG DOC 2.9.1
The CNSC Regulatory Document, REGDOC‑2.9.1 Environmental Protection Environmental Principles, Assessments and Protection Measures describe CNSC’s principles for environmental protection for new and existing nuclear facilities. The CNSC has accepted the request from Bruce Power to move to the most recent version of this standard, REGDOC‑2.9.1, version 1.1 (2017).
Registration to ISO 14001 Environment Management System is a requirement of REGDOC‑2.9.1, version 1.1 (2017). Bruce Power’s implements ISO 14001:2015 as our environmental framework, and incorporates industry best standards (CSA N288 Series) to conduct our effluent/environmental monitoring programs, achieve performance targets and drive continual improvement, to ensure environmental protection.
ISO 14001:2015 was released by the International Organization for Standardization on September 15, 2015. ISO 14001:2015 focuses on the Environment Management System (EMS) being integrated throughout business processes to aid in the organization’s knowledge and understanding of external and internal issues, identification of stakeholders needs and expectations, and identification of risks and opportunities impacting the organization and interested parties. The standard also focuses on leadership’s commitment to environmental performance, protection of the environment beyond prevention of pollution, and adoption of a lifecycle approach when considering and evaluating its environmental aspects.
Bruce Power’s ISO 14001:2015 re‑registration Audit was conducted by the external registrar, SAI Global, in the fall of 2017; resulting in our successful re‑registration to this revised and enhanced version of the standard. There were no non‑conformances, eight identified strengths and six opportunities for improvement (OFIs). Some of the strengths identified include: environmental integration within the company, Bruce Power’s contractor management approach, the continuous improvement of the internal audit and corrective action process, progress within Bruce Power’s integrated management system, internal awareness and external communications, and emergency preparedness. Recommended opportunities for improvement included: the internal audit process to reference conformity to the standard and identify administrative process weaknesses related to any findings; identification of needs/expectations of interested parties to be more specific, environmental aspect/impact analysis to include resource use based aspects/activities; performance measures discussed at management review to include a middle tier performance metrics.
Based on the updates to the 2015 version of the ISO 14001 standard, Bruce Power has evaluated its environmental aspects from both a risk‑based and an opportunity‑based perspective. In this exercise, Bruce Power has identified several opportunities related to its environmental aspects, one of which met the threshold to be classified as a Significant Environmental Aspect (SEA); this SEA is titled “Energy Production and Climate Change”. Bruce Power’s operation (clean energy production) produces over 6,300 MW of electricity and emits low CO2. Numerous studies have shown that life cycle emissions from nuclear energy are comparable to other low‑carbon emitting sources of electricity such as wind, solar and hydro power. Bruce Power increased its power generation outputs since returning Bruce A units to service, providing an additional 3,000 megawatts (MW) of carbon‑free electricity to Ontario’s grid since 2012, replacing 70% of the electricity that was lost by the phase‑out of coal plants. As a result, 2015 was the first year with no coal‑fired electricity in Ontario. The phase‑out of coal resulted in 93% reduction in Ontario’s sulphur emissions and the number of smog days in the Greater Toronto dropped from forty‑eight days in 2014 to zero in 2015.
CSA N288 Series Implementation
Bruce Power continues to progress through its implementation plans of industry best standards and guidelines on environmental management of nuclear facilities (CSA N288 Series); specifically for Canadian Standards Association (CSA) standards on Environmental Monitoring Programs (N288.4‑10), Effluent Monitoring Programs (N288.5‑11) Environmental Risk Assessments (N288.6‑12). The current programs and activities on site already demonstrate general compliance to these standards, however gaps analyses and audits have been conducted to identify any gaps, and continuous improvements are being made to ensure that the standards are incorporated appropriately on a clause by clause basis. Bruce Power is working towards full implementation of N288.4‑10 and N288.5‑11 by the end of 2018.
Recently included in Bruce Power’s voluntary CSA N288 series implementation plan is the standard on Groundwater Protection (N288.7‑15). A groundwater monitoring program already exists as part of the routine program, and this is being reviewed and enhanced to meet the specific clauses in this new standard. Monitoring shows that there are no adverse impacts on groundwater as a result of facility operations. Bruce Power is working towards implementation of N288.7 by end of 2020.
Bruce Power is working towards a voluntary implementation plan of N288.8‑17 Establishing and implementing action levels for releases to the environment from nuclear facilities as discussed further below in the discussion of release limits and environmental actions levels.
Bruce Power has met the compliance requirements of N288.6‑12. An Environmental Risk Assessment (ERA) Report was completed and submitted to the CNSC in December 2017. The CNSC staff are satisfied that risks to the environment or human health for the continued operation of Bruce Power, including Major Component Replacement (MCR) are low to negligible. CNSC concluded that the ERA Bruce Power conducted under the Nuclear Safety Control Act has, and will continue to, make adequate provision for the protection of the environment and the health of persons. Updates from routine environmental monitoring will be incorporated into the 5‑year ERA cycle and into the annual environmental protection report. The ERA continues to demonstrate that the operation of the Bruce Power Facility and associated life extension activities, has not, and will not, result in significant adverse environmental effects as a result of exposure to radiological or non‑radiological substances, for both human health (nearby residents and visitors) and for ecological receptors.
This is consistent with similar assessments that have been conducted since 2001. The conclusions of the ERA include: 1) for human health there are no radiological or non‑radiological risks to members of the public near Site or visitors to the on‑site Indigenous burial ground, 2) for ecological heath, there are no radiological or non‑radiological risks to wildlife or the environment, all activities are within bounds and do not require further Tier 3 assessment. No interactions were identified that pose a risk to humans or the environment, and potential impact of future activities are anticipated to be similar to those of existing and predicted operations and as a result would not cause any significant adverse environmental impact. The current environmental monitoring is sufficient and will be maintained.
DFO Fisheries Authorization
Since 2012, Bruce Power has been in discussions with the Canadian Nuclear Safety Commission (CNSC) and Fisheries and Oceans Canada (DFO) with respect to the authorization requirements under the amended Fisheries Act. Bruce Power has also taken steps to engage with the local Indigenous communities to seek input on issues related to fisheries. The existing design of the facility meets industry standards for mitigation and protection of fish. However, the Fisheries Act requires any residual impact to be offset. Two consecutive years of monitoring for impingement and entrainment in 2013 and 2014 resulted in a quantification of annual loss of fish, in terms of age‑1 equivalents, to be 2,393 kg. Further consideration of potential uncertainties resulted in an increase to 2,414kg. In comparison, the biomass of the annual loss of fish represents 0.5‑1.0% of the commercial harvest in 2013 and 2014. Bruce Power will resubmit the Fisheries Act Application to include these updates as well as an offsetting plan in May 2018. Pre‑monitoring for offset projects continues in 2018, offset project implementation is anticipated to begin in 2019, and the monitoring of the project to confirm productivity will continue into subsequent years.
Bruce Power has been in active dialogue with the Canadian Nuclear Safety Commission (CNSC) and Environment and Climate Change Canada (ECCC) to ensure that fish are being protected from the effects of thermal discharge of water. Quantitative analysis was conducted in the 2017 ERA. Sixteen fish species representing cold, cool and warm water guilds were assessed against measured temperature values over 3 years. Results using conservative thermal benchmarks and time windows concluded that thermal effluent causes minimal to negligible risk to fish. Further detailed quantitative analysis was completed for whitefish embryos over winter in the nearshore and concluded minimal to negligible risk as a result of thermal effluent. In addition, with respect to the Provincial Environmental Compliance Approval with the Ministry of Environment and Climate Change, Bruce Power will be submitting an application in February 2018 for a temporary amendment to the ECA to continue with the Operational Flexibility granted in previous years for an additional 10 year period. The ECA operational flexibility requested and granted in previous years has been evaluated in terms of fish thermal benchmarks, which also resulted in minimal to negligible risk to fish. This information has been shared and discussed with local Indigenous communities. Comments on this assessment have been received from CNSC/ECCC. Discussions on this topic with regulators and Indigenous communities are ongoing.
Results of the Effluent Monitoring program demonstrate that all conventional and radiological effluents (waterborne and airborne) are and continue to be well below regulatory limits.
Radiological Effluent Monitoring
With respect to non‑radiological emissions, Bruce Power is in compliance with applicable Provincial regulations, approvals, and permits. With respect to radiological airborne emissions and liquid releases, derived release limits (DRLs) are in place to ensure release limits to the environment will not exceed the annual regulatory public dose limit of 1 mSv. Furthermore, to ensure that DRLs are never reached, Bruce Power has developed and implemented additional administrative limits well below DRLs, to ensure action is taken well before there is any emission that would significantly contribute to public dose. These lower levels are called Environmental Action Levels (EALs) and Internal Investigation Levels (IILs). Environmental Action Levels are set at approximately 10 percent of the DRLs for each radionuclide/radionuclide group. Action levels, if reached, are reportable to the CNSC and require specific actions to be taken to promptly mitigate the release. An Internal Investigation Level is an administrative level set much lower than Environmental Action Levels. It is set at the upper range of normal releases (both airborne and waterborne) for each radionuclide/radionuclide group. If an IIL is exceeded, Bruce Power immediately begins an investigation to determine why it happened and put corrective actions in place to ensure potential future releases remain within the normal range.
In 2017, all releases were well below the derived release limits and action levels. Bruce Power is required to review, and if necessary, revise and reissue DRLs and EALs at least once per licence period. Currently, the CNSC is looking at ways to revise these limits to assist Bruce Power in further protecting people and the environment to the best of its ability. Bruce Power is always striving to represent industry best practice and frequently requests to adopt new standards. Currently Bruce Power is working towards the implementation of N288.8 which would include the development of more stringent Environmental Actions Levels (approximately 1,000 times lower than current EALs) that are more closely aligned with operational performance.
For airborne radiological releases, tritium increases were observed in 2017 at Bruce A and Bruce B compared to 2016 primarily due to extensive maintenance outages and equipment deficiencies that have since been resolved. Airborne 14C emissions at Bruce B have significantly declined since 2010 and have remained relatively stable since, and Bruce A experienced a reduction in 14C emissions since 2015. Iodine emissions at Bruce B have been very low and stable over the long term; however, Bruce A experienced elevated emissions in 2012 and 2014 which are discussed in Section 188.8.131.52. Improvements realized in 14C emissions can be attributed to an increased focus on resin management and a decrease in moderator cover gas purges whilst an increased focus on the equipment monitoring and reliability of the exhaust stack filters has ensured the minimization of iodine emissions. For waterborne emissions, tritium releases from Bruce B increased since 2016 due to extensive maintenance outage activities in concurrence with a minor on‑going boiler tube leak, whilst Bruce A waterborne tritium emissions show a long term stable trend. Waterborne 14C emissions have decreased at Bruce A and Bruce B since 2015 due to an increased focus on resin management on reactor purification systems, and waterborne gamma emissions have remained stable over the long term. All emissions remain well below Environmental Action Levels and Derived Release Limits (regulatory limits) and the dose to public remains de minimus.
Conventional Effluent Monitoring
Bruce Power continues to comply with its Environmental Compliance Approvals and regulations under, but not limited to, the Environmental Protection Act and the Ontario Water Resources Act. For conventional waterborne emissions, there were two moderate infractions in 2017, as discussed in Sections 184.108.40.206 and 220.127.116.11. This represents an improving trend in conventional water moderate infractions at Bruce Power, with the number decreasing over the last five years. In accordance with the ECA (Air), noise complaints received from Inverhuron residents between July 3, 2017 and September 27, 2017 were reported to the Ministry of the Environment and Climate Change District Office, as discussed in Section 18.104.22.168. Bruce Power continues to investigate opportunities to mitigate this nuisance impact via short term and long term strategies. Noise monitoring and assessments conducted between 2015 and 2017 demonstrate that Bruce Power’s noise emissions remain in compliance with MOECC limits. Greenhouse gas emissions have trended downwards due to the shutdown of the Bruce Steam Plant in 2015 and remain below the Federal and Provincial greenhouse gas emission thresholds for reporting, as discussed in Section 22.214.171.124.
Bruce Power manages many different forms of waste, including: Radioactive, Hazardous (oils and chemicals), Recyclables (glass, cardboard, plastic, paper, metal), Organic (compost), Landfill (for those items that are not radioactive, non‑hazardous, cannot be recycled or composted). Beyond complying with relevant waste regulations and requirements, reducing all forms of waste is in the best interest of the company from an environmental and financial standpoint, and has been a focus for many years. The philosophy is a life cycle consideration; to reduce at the consumer level, to generate less waste, reuse when opportunities are presented and explore all opportunities to sort and recycle. There are a number of initiatives that focus on these areas. Waste volumes are minimized by applying the principles of reduce; reuse, recycle, recover; and wastes are processed in a safe, environmentally responsible manner. Potential pollutants are controlled to meet regulatory requirements and to minimize environmental impacts associated with their use. Bruce Power continues to effectively implement programs for the minimization, segregation, handling, monitoring and processing of waste in accordance with regulations and industry best practice.
Every year, Bruce Power monitors all aspects of the environment surrounding our facility, including the level of radioactivity. Environmental Monitoring (EM) is an important part of environmental protection at a nuclear facility. It ensures, through measurement, sampling and analysis, that the health of the environment and people are protected. Sampling and analysis of the local area gives Bruce Power a baseline to compare against in the unlikely event that site operations ever had a measurable impact. Bruce Power uses various methods to gather the data that is used to determine the risk to the surrounding environment.
Bruce Power radiological environmental monitoring carries out sampling and analysis of the following media and relevant analytes:
- Media: Air, Water, Precipitation, Aquatic Samples (including fish, sediment, and sand), Terrestrial Samples (including animal feed, eggs, fish, beef, pork, poultry, deer, fruit and berries, milk, root vegetables, non‑root vegetables, honey, grain, soil)
- Analytes: Tritium, Carbon‑14, Iodine‑131, Beta, Gamma
The limit for tritium in drinking water is an annual average of 7,000 Bq/L. Bruce Power has made a commitment to maintain tritium concentrations much lower and has self‑imposed a limit of 100 Bq/L at all local municipal water supply plants. The 2017 annual average in Kincardine was 5 Bq/L and in Southampton it was 10 Bq/L.
The radiological environmental monitoring (REM) data implicitly reflects the influence of releases from all Bruce Power facilities as well as facilities within the Bruce Power site that are owned by other parties. This includes the Western Waste Management Facility (WWMF), owned and operated by Ontario Power Generation (OPG), and Douglas Point Waste Management Facility (DPWMF) which is owned by Canadian Nuclear Laboratories (CNL). In this approach, the resulting levels of exposure and dose are representative of Bruce Power site releases.
CNSC staff conducted a type II compliance inspection of Bruce Power’s Radiological Environmental Monitoring (REM) program. The inspection assessed Bruce Power’s compliance with regulatory requirements associated with environmental monitoring as well as other areas as they related to the environmental monitoring. Based on the scope of the inspection, CNSC staff concluded that Bruce Power met all regulatory requirements. CNSC staff did not find evidence of unsafe operations that would result in undue risk to the health and safety of persons, the environment, or that would compromise respect for Canada’s international obligations
Dose to public
A site specific survey is conducted routinely; at least every 5 years, the most recent survey was conducted in 2016 and included over 260 respondents. This survey provides important information about the human, social, economic and natural environment surrounding the site. Bruce Power gathers information on meteorology and severe weather, land use, population, water usage, agriculture, recreation, food sources (how much of a person’s diet is locally produced), daycares, before/after school programs, long‑term care homes, school boards and parks within the vicinity of the Bruce site. Bruce Power uses the data to calculate an annual radiation dose to the public, perform periodic Environmental Risk Assessments and calculate Derived Release Limits. This data is also used to inform the environmental monitoring program design, and it is also important for emergency preparedness.
In the calculation of public doses for the Bruce Power site, statistically reliable data generated through the site specific radiological effluent monitoring programs (REMP) have been preferentially used as the basis for determining the concentrations of radionuclides in the various exposure media. For some radionuclide/media combinations, technological limitations may inhibit the capacity to collect the desired radionuclide measurements. In cases where monitoring data were not available for a particular exposure media, transport modelling and emissions data have been used – this results in very conservative estimations. The environmental transport models in IMPACT may calculate radionuclide concentrations in exposure media (based on defined concentrations in other contributing media), or they may calculate concentrations in each medium along the entire pathway on the basis of defined rates of emission from the source. The transport models in the current version of IMPACT (Version 5.5.1) are taken from CSA DRL Guidance. The data is then processed (e.g., adjusted for background, converted to required units of input for IMPACT) for the specific purpose of dose calculations.
For the 26th consecutive year Bruce Power’s calculated dose to a member of the public is less than the 10 µSv/year value that is regarded as the lower threshold for significance (de minimus). Dose to potential representative persons are calculated using IMPACT 5.5.1. The most recent site specific survey results (2016 Site Specific Survey), 2017 meteorological data, effluent and environmental monitoring data for Bruce site for year 2017 are all taken into account for the calculation. The highest dose estimated for year 2017 is 2.12 µSv, representing 0.2% of the regulatory dose limit of 1000 µSv/y. The representative person estimated for year 2017 is a 10‑year old child at the Bruce Subsistent Farmer 3 location.
2017 Maximum Representative Person’s Dose
|Representative Person||Committed Effective Dose||Percentage of Legal Limit|
|BSF3 10‑year old||2.12 µSv/y||0.2%|