CNSC Response to the Findings of the Fall 2016 Report of the Commissioner of the Environment and Sustainable Development on the inspection of nuclear power plants

Frequently asked questions

1. What did the audit review?
2. What does the CNSC do when they find instances of non-compliance during site inspections?
3. What were the CESD's recommendations and what has the CNSC done about them?
4. How does the CNSC verify compliance at nuclear power plants?
5. How far in advance are inspections planned?
6. What would cause an inspection to be rescheduled or cancelled?
7. What are Type I and Type II inspections?
8. How does the CNSC decide when to do a Type I or Type II inspection?
9. What kind of training do inspectors receive?
10. How many inspectors does the CNSC have at each nuclear power plant?
11. How many nuclear power plant site inspections does the CNSC do annually?
12. How does the CNSC inform the public about Canada’s nuclear power plants?

1. What did the audit review?

The Commissioner of the Environment and Sustainable Development (CESD) of the Office of the Auditor General (OAG) conducted an audit that focused on the CNSC’s processes for planning and completing compliance site inspections at nuclear power plants; allocation of resources to support the inspection program; and application of enforcement measures to correct and deter non-compliance. The audit covered the period during the 2013-14 and 2014-15 fiscal years. The scope of the audit did not include the safety of Canadian nuclear power plants.

2. What does the CNSC do when they find instances of non-compliance during site inspections?

Immediately following nuclear power plant (NPP) site inspections, CNSC inspectors meet with the licensee and inform them of the preliminary findings, including any compliance issues. The audit found that when CNSC inspectors identified issues during a site inspection, they followed up with the licensee 100% of the time to ensure compliance.

3. What were the CESD's recommendations and what has the CNSC done about them?

The Fall 2016 Report of the Commissioner of the Environment and Sustainable Development on the inspection of nuclear power plants made recommendations for improvement to the documentation of the nuclear power plant site inspection program. As of March 31, 2017, the CNSC has completed its corrective action plan as committed, and all five recommendations have been addressed.  Read the CNSC's corrective action plan.

4. How does the CNSC verify compliance at nuclear power plants?

The CNSC verifies licensee compliance and the safety of nuclear power plants (NPPs) using a number of activities, including:

• onsite inspections: a combination of inspections of various scope conducted at the NPP to verify that licensee programs, performance, work activities, facilities and equipment comply with regulations and conditions of their NPP licence (total of 200-400 per year)
• onsite surveillance and monitoring: daily inspector observations conducted at the NPP of licensee management and operations which is used to inform and direct future compliance actions
• expert reviews: specialist evaluations of program documents and operational reports submitted by the licensee to comply with conditions of their NPP licence (total of 400-600 per year); mandatory annual and quarterly reports include more than 150 data sets against 25 safety performance indicators.
• unplanned event examinations: specialist examinations of abnormal or unplanned situations or events reported by the licensee to comply with conditions of their NPP licence (total of 200-400 per year); the status of Canadian power reactor facilities, including activities and events, is discussed at every publicly webcast Commission meeting.
• annual regulatory oversight report: the publication of an annual regulatory oversight report for Canadian nuclear power plants on which the public has an opportunity to comment and which is discussed at a public Commission meeting that is webcast live; the report assesses and assigns a rating on how well plant operators are meeting regulatory requirements and program expectations in each of 14 safety and control areas.

The effectiveness of the CNSC’s comprehensive compliance oversight program is demonstrated by industry’s annual safety performance ratings and affirmed through international benchmarking and independent peer reviews.

5. How far in advance are inspections planned?

The CNSC has a five-year inspection plan, which is broken down into annuals plans. These annual plans are then reviewed and updated on a quarterly basis. The plan includes the required staff allocation, and the frequency and type of inspections based on risk-informed decision making. Before a planned inspection is changed, rescheduled or cancelled, it is assessed by CNSC experts and management to ensure that verification of compliance will not be impacted.

In addition to planned inspections, CNSC staff also carry out responsive inspections as a result of unforeseen events.

6. What would cause an inspection to be rescheduled or cancelled?

Inspection planning must be flexible to respond to emerging situations. All decisions about which site inspections could be rescheduled or removed from the plan are made by knowledgeable, senior technical experts with the involvement and support of CNSC management. However, the audit found that the CNSC needs to do a better job at documenting the reasons for rescheduling or cancelling an inspection.

Inspections are primarily rescheduled due to two factors: changes in the licensee plans and changes in priority. Some inspections can only be done when the nuclear reactor has been shut down; if the licensee changes their shutdown plan, the inspection plan must be changed as well. If resources are constrained, CNSC staff defer lower risk area inspections to concentrate on areas of higher risk. During the period under audit, the changes to inspection plans were due to the Fukushima accident, licensee refurbishment plans and unplanned events.

7. What are Type I and Type II inspections?

CNSC inspections are divided into two categories: Type I and Type II.

Type I inspections are in-depth examinations of a licensee’s processes and operations, and typically occur at the licensee’s operational site(s). Inspectors check licensee compliance by directly observing operations, reviewing records and interviewing licensee staff. These inspections usually last several days and in most cases allow inspectors to gain an appreciation of the licensee’s safety culture (i.e., its view on safety in general). Licensees receive daily updates during inspections on inspectors’ findings up to that point. At the end of an inspection, a licensee must provide timelines for addressing the findings that have been made and a preliminary report is issued by the inspector(s). Should something be found during the inspection that is an imminent threat to health, safety or the environment, the Nuclear Safety and Control Act (NSCA) provides inspectors the legal power to immediately order these activities to stop.

Type II inspections typically examine the outcomes of those processes. Type II inspections are usually shorter since extensive interviews are not performed, and data is collected mainly through direct observations, measurements and reviews of onsite records. Should inspectors find issues that cannot be resolved through a Type II inspection, it may be followed up with a more in-depth Type I inspection. Type II inspections are usually scheduled, but can be performed unannounced if necessary. At the end of the inspection, licensees must provide timelines for addressing findings and a preliminary report is issued by the inspector(s). Should something be found during the inspection that is an imminent threat to health, safety or the environment, the NSCA provides inspectors the legal power to immediately order these activities to stop.

8. How does the CNSC decide when to do a Type I or Type II inspection?

The CNSC does Type II inspections on a regular basis to assess licensee performance. The more in-depth Type I inspections are used when there is a serious performance problem or when there is a new or major change to a licensee program.

During the period under audit, several major relicensing or refurbishment activities for nuclear power plants entailed comprehensive compliance reviews (including expert reviews, site inspections and reviews of unplanned events.) These reviews provided the required information needed to ensure regulatory compliance, and as a result Type 1 inspections were not required during that period.

9. What kind of training do inspectors receive?

CNSC inspector candidates typically have a science or engineering university degree. They undergo a documented inspector training and qualification program which typically takes two years before being designated as a CNSC inspector. Following designation, an inspector typically requires another two to four years of supervised inspection experience before they are able to be assigned to the full range of inspections conducted at NPPs.

10. How many inspectors does the CNSC have at each nuclear power plant?

The CNSC currently has 30 permanent onsite inspectors across Canadian operating nuclear power plants. All inspectors have multiple scientific and technical experts at their disposal within the CNSC, and the lead inspector calls expert teams together as appropriate to address the scope of each individual inspection. From a resourcing point of view, over 200 staff are allocated to NPP licensing and compliance oversight.

11. How many nuclear power plant site inspections does the CNSC do annually?

Depending on the scope, frequency and complexity of inspections, some are conducted by a single inspector verifying a single requirement and others are conducted by a team of inspectors and technical specialists over a longer period to verify entire programs and systems. The number of inspections varies from year to year based on the conditions and needs at each NPP, such as historical performance, outages or refurbishment.

In fact, the amount of compliance effort expended is more important than the actual number of site inspections. For example, in 2015, there were more than 17,000 person-days of effort by CNSC staff in conducting inspections, event reviews and other compliance activities. In the audit, the CESD observed that the CNSC planned to conduct 255 site inspections during 2013–14 and 2014–15 and completed 226 or 89%. Those inspections not completed were covered by other types of compliance activities.

12. How does the CNSC inform the public about Canada’s nuclear power plants?

With a mandate to disseminate objective scientific, technical and regulatory information to the public, the CNSC goes to great lengths to ensure that it is being open and transparent in its regulation of the nuclear industry.

The Commission – the CNSC’s decision-making body for major nuclear facilities – promotes openness and transparency by conducting public hearings and meetings that are webcast live. When possible, these proceedings are held where nuclear facilities are located. This ensures that the public most directly implicated by the matter at hand will have a voice in the decision-making process. Status reports on the NPPs, including updates on unplanned events, are publicly discussed and webcast live at every Commission meeting.

The CNSC also publishes an annual regulatory oversight report for Canadian nuclear power plants on which the public has an opportunity to comment. The report assesses and assigns a rating on how well plant operators are meeting regulatory requirements and program expectations on each of the 14 safety and control areas: management system, human performance management, operating performance, safety analysis, physical design, fitness for service, radiation protection, conventional health and safety, environmental protection, emergency management and fire protection, waste management, security, safeguards and non-proliferation and packaging and transport. The report is then discussed at a public Commission meeting that is webcast live.

The CNSC also expects licensees to build public awareness and understanding of their nuclear activities. Developing and maintaining open communications channels, and sharing information regularly, informs the public both during regular operating circumstances and during an emergency. Currently, all licensees of major facilities are required to maintain a public information program.