General Description of Regulatory Framework for Nuclear Power Generating Sites

1. Introduction

This document provides general information that serves as background for CNSC assessments of compliance and performance of nuclear power plants (NPPs) and the waste management facilities (WMFs) that are located at the same sites (e.g., as documented in the Regulatory Oversight Report for Canadian Nuclear Power Generating Sites).

The CNSC regulates the nuclear sector in Canada, including NPPs and WMFs, through

• licensing
• reporting
• compliance verification
• enforcement
• regular assessment of compliance and performance

The CNSC uses a risk-informed regulatory approach to these activities, applying resources and regulatory oversight commensurate with the risk associated with the regulated facility and activity.

CNSC has established a set of safety and control area (SCAs; see http://www.nuclearsafety.gc.ca/eng/resources/news-room/feature-articles/safety-and-control-areas) that provide a framework for the activities noted above. For the purposes of detailed compliance verifications and regular assessments of compliance and performance, each SCA is broken down into specific areas, which are discussed in sections 1 to 14 of this document.

Licensing

The CNSC licensing process for NPPs and WMFs is comprehensive and covers all the SCAs. Per the definitions in the Class I Nuclear Facilities Regulations, which are made under the Nuclear Safety and Control Act (NSCA), NPPs and WMFs are identified as Class I facilities. Specifically, NPPs are considered Class IA nuclear facilities and the WMFs are considered Class IB nuclear facilities.

Each licence for an NPP or WMF has a requirement for the licensee to operate in accordance with the licensing basis. The licensing basis is defined in CNSC REGDOC-3.5.3, Regulatory Fundamentals. It comprises:

• the regulatory requirements set out in the applicable laws and regulations
• the conditions and safety and control measures described in the facility’s or activity’s licence and the documents directly referenced in that licence
• the safety and control measures described in the licence application and the documents needed to support that licence application

The requirements in parts (ii) and (iii) of the licensing basis are unique to each licensed facility – they depend on the content of a given licence, the associated licence application and the applicant’s supporting documentation. Regulations under the NSCA, including the Class I Nuclear Facilities Regulations, provide requirements on the content of licence applications for NPPs and WMFs. CNSC REGDOC‑1.1.3, Licence Application Guide: Licence to Operate a Nuclear Power Plant, provides additional guidance for applications for a licence to operate an NPP. CNSC staff also provide additional, tailored guidance for individual licensees intending to renew their licences for NPPs and WMFs.

Licence applications for NPPs and WMFs cite CNSC regulatory documents, CSA Group standards, and other publications, as well as the applicant’s own documentation. CNSC staff assess licence applications to ensure that the proposed safety measures are technically and scientifically sound, that all application requirements are met and that the appropriate safety systems will be in place to protect people and the environment. CNSC staff assess the adequacy of the proposed measures against the requirements in the regulations and any guidance that has been provided to the applicant.

The licensing process offers significant opportunities for participation of the public and Indigenous peoples, including in Commission hearings (which are often held in the affected community) and Commission meetings. Most Commission proceedings are open to the public and webcast live.

The NPP and WMF licences are relatively similar and contain standardized licence conditions that are organized according to the SCAs. Examples of requirements in standard licence conditions related to the implementation of various programs under the SCAs are included in this document. The detailed compliance verification criteria for all licence conditions are found in the associated licence conditions handbook (LCH) for the facility, which is written by CNSC staff by consulting the licence application and following direction from the Commission stemming from the licensing decision. The LCHs are consistent with the licensing basis for the facility and establish the basis for the compliance verification program (CVP) during the licence period.

Licensee Reporting

Licensees are required to provide various reports and notices to the CNSC in accordance with regulations made under the NSCA. LCHs clarify CNSC expectations for these requirements, if needed.

In addition to, and in conjunction with, the reporting requirements in the regulations, licence conditions require licensees to report to the CNSC in accordance with the following CNSC regulatory documents.

• For NPPs, REGDOC‑3.1.1, Reporting Requirements for Nuclear Power Plants
• For WMFs, REGDOC‑3.1.2, Reporting Requirements for Non-Power Reactor Class I Facilities and Uranium Mines and Mills

REGDOC-3.1.1 requires NPP licensees to submit quarterly and annual reports on various subjects; for example, quarterly reports on the safety performance indicators that are illustrated in various parts of this report. They provide detailed requirements related to the submission of other important reports (such as updates to the final safety analysis report, proposed decommissioning plan and annual environmental protection report). They also require licensees to report any unplanned situations and events to the CNSC (the licensees also post those reports on their respective websites).

Similar to the NPPs, REGDOC-3.1.2 requires WMF licensees to submit annual reports on various subjects; specifically, they are required to provide an update on all fourteen SCAs. Additionally, the LCHs for WMFs require the licensee to submit quarterly operational reports that include information such as the number of dry storage containers (DSCs) transferred/processed, environmental monitoring results and summaries of event reports.

CNSC Compliance Verification Program

The CVP confirms compliance with the licensing basis for the NPPs and WMFs. It includes inspections led by inspectors and supported by subject matter experts, including:

• Type I inspections, which evaluate licensee programs and typically involve documentation review and onsite activities
• Type II inspections, which evaluate the outputs and outcomes of licensee programs and typically involve documentation review and onsite activities
• field inspections, which are limited in scope (for example, a particular area of the facility) and involve onsite activities to collect data on the outputs and outcomes of licensee programs
• desktop inspections, which are similar to Type II inspections but do not involve onsite activities

Onsite activities during inspections include workplace observations, measurements and worker interviews.

The CVP also includes compliance assessments, which are led by a wide range of subject matter experts and typically involve documentation review. Finally, the CVP includes surveillance and monitoring activities, which are conducted by CNSC inspectors onsite (e.g., observation of licensee meetings or review of station condition records).

The activities in the CVP cover the SCAs and are conducted with varying frequency over a predetermined period – five years for NPPs and ten years for WMFs. This baseline is the minimum set of activities needed to systematically and comprehensively verify whether licensees are complying with the safety and control measures in their licensing bases. Inspections typically verify compliance with requirements across multiple specific areas and SCAs.

For example, for each NPP, between 80 and 100 applicable compliance verification activities are selected from the five-year baseline for the year’s compliance plan. This document indicates the compliance verification activities in the five-year baseline cycle for NPPs that are relevant to each specific area.

For the WMFs, the ten-year baseline compliance plan includes one Type II inspection per SCA over the ten-year period. In addition, general inspections are typically held yearly at each WMF, with a broader focus encompassing several SCAs.

Additional reactive compliance verification activities for NPPs and WMFs are added as needed. These focus on site-specific matters and known or potential licensee challenges. CNSC technical specialists and licensing staff then validate the annual plans by using a risk-informed approach that considers the status, performance history, and conditions and challenges of each facility to ensure appropriate regulatory oversight and safety performance evaluation. Additional compliance verification activities for NPPs and WMFs may also be added as necessary during the year in response to new or emerging licensee challenges. The goal is to ensure that the CVP for NPPs and WMFs is timely, risk-informed, performance-based and responsive to developments.

The compliance assessments for NPPs include reviews of safety performance indicators submitted quarterly to the CNSC in accordance with REGDOC-3.1.1. No regulatory limits or thresholds are associated with this data, but CNSC staff monitor them, watching for trends over time and deviations from the data typically provided by other licensees with similar operations or facilities. Trends over time are relatively slow to develop, and the differences between licensees are relatively small, since NPP licensees tend to have mature programs for the SCAs that are based on similar or identical requirements. Any unfavourable trend or comparison is followed by increased regulatory scrutiny, which can range from increased surveillance and monitoring, to increased focus during field inspections, adjustment of the timing or scope of a baseline inspection, focused desktop review or a reactive inspection, depending on the safety significance of the trend or deviation.

Enforcement

The CNSC uses a graduated approach to enforcement to encourage and compel compliance, and deter future non-compliances. When a non-compliance is identified, CNSC staff determine the appropriate enforcement action based on the safety significance and other factors, such as whether the non-compliance is systemic or repeated. Each enforcement action is a discrete and independent response to a non-compliance.

The CNSC’s strategy to address non-compliances may involve the following regulatory responses and enforcement measures:

• informing licensees
• issuing written notices of non-compliance
• issuing warning letters
• increasing regulatory scrutiny
• making requests under subsection 12(2) of the General Nuclear Safety and Control Regulations
• issuing administrative monetary penalties
• issuing orders
• taking licensing actions
• decertifying persons or equipment
• undertaking prosecution

Regulatory responses and enforcement actions may be applied independently or in combination with other actions.

Regulatory judgment is applied, and multiple factors are taken into account, to determine the most appropriate enforcement strategy for any given situation. If the initial response or enforcement action does not result in timely compliance, other enforcement actions are used.

Regular Assessment of Compliance and Performance

CNSC staff regularly assess the overall state of compliance and safety performance of individual licensees or groups of licensees and summarize the results in reports to the public and Commission. For example, the Regulatory Oversight Report for Canadian Nuclear Power Generating Sites) provides staff’s annual assessment of compliance and performance for NPPs and the WMFs that are located at the same sites. The remainder of this document provides general information that serves as background for the assessments of NPPs and WMFs. It is broken down according to the SCAs, which are subdivided further into specific areas. The specific areas are applicable to both NPPs and WMFs, unless noted otherwise.

In the following, the phrase “operating NPPs” refer to NPPs having at least one reactor that is in operation or is being refurbished with the intent of returning to service. References to quarterly or annual reports are those that are required by the regulations or CNSC regulatory documents REGDOC-3.1.1 for NPPs and REGDOC-3.1.2 for the WMFs.

2. Safety and Control Areas

2.1 Management system

This SCA covers the framework that establishes the processes and programs required to ensure that an organization achieves its safety objectives, continuously monitors its performance against those objectives and fosters a healthy safety culture.

The performance objective of this SCA is to ensure an effective management system that addresses all requirements and related objectives, enables the licensee to continuously monitor and manage performance against those objectives, and maintains a healthy safety culture.

Management system encompasses the following specific areas:

• management system
• organization
• performance assessment, improvement and management review
• operating experience (OPEX)
• change management
• safety culture
• configuration management
• records management
• management of contractors
• business continuity

Management system

Licences for NPPs and WMFs contain a condition requiring the licensee to document and maintain a management system. Licensee management systems encompass policies, descriptions of interfaces, and supporting documentation that control and maintain the programs, procedures, processes and practices applicable for all licensed activities. All licensees review their management system programs periodically to assess their effective implementation and improve the documentation as necessary. CNSC compliance verification activities for NPPs and WMFs may include various Type II inspections and field inspections that confirm certain elements of the management system.

Organization

NPP and WMF licensees define their organizational structure, authorities, accountability, and responsibilities of positions, including internal and external interfaces, and how and by whom decisions are made. CNSC compliance verification activities for NPPs and WMFs may include various Type II inspections and field inspections that confirm certain elements of the licensee’s organization. For example, field inspections at NPPs verify that the organizational structures, accountabilities, roles and responsibilities are documented and current in the licensee’s documentation.

Performance assessment, improvement and management review

NPP and WMF licensees continually assess and improve their management systems. The organization’s management confirms the effectiveness of the management systems in controlling safe operation through periodic, critical assessments. The inputs to these assessments include independent assessments (audits) and self-assessment results, status of corrective actions including corrective actions from CNSC staff’s compliance verification activities and key safety performance indicators used to maintain the control of their processes to operate safely. Licensees take action from these assessments to resolve identified weaknesses in the management system. CNSC compliance verification activities may include Type II inspections for NPPs that focus on licensee self-assessment and independent assessment, field inspections on self-assessments, and field inspections that focus on effectiveness assessment of the management system.

Operating experience (OPEX)

Licensees have problem identification and corrective action programs to identify and resolve problems, as well as operating experience (OPEX) programs to obtain and disseminate lessons learned internally and externally.

When problems arise, licensees take action to limit the impact on their facilities. Problems are documented and reported to the appropriate levels of management to initiate a corrective action process and prevent the recurrence of events. The licensees establish time frames for controlling problems and completing corrective actions. The licensees’ responses may involve the determination of underlying causes, depending on the significance of the problem. Licensees also perform analyses to identify systemic events (i.e, trends).

The licensees also have an information-gathering and review process to identify and evaluate relevant OPEX to improve and implement actions that prevent the occurrence of potential problems.

CNSC compliance verification activities for NPPs may include various inspections that assess the output of problem identification and resolution programs as well as assessing OPEX as a standard verification activity.

Change management

Licensees control changes to their organizations, documentation, processes, programs, designs, drawings, structures, systems and components (SSCs), equipment, materials and software. The controls ensure that changes are documented, justified and reviewed by stakeholders to assess the potential impact on safety. The level of review and approval is commensurate with the impact, risk and complexity of the change. CNSC compliance verification activities for NPPs may include Type II inspections for engineering changes, field inspections and reviews of changes to licensee documents that are listed in their LCHs.

Safety culture

Licensees periodically conduct safety culture self-assessments, gathering data through multiple methods, including surveys, interviews and focus groups. NPP licensees have implemented safety-culture monitoring panels following the guidance provided by the Nuclear Energy Institute. CNSC staff review licensee safety culture self-assessments, their results and the adequacy of the licensees’ follow-up actions.

Configuration management

Licensees maintain the alignment of the physical and operational configurations of SSCs and their associated documentation, including their design and licensing basis requirements. The configuration management processes include the review of completion assurance prior to turnover of any modified SSCs to operation. CNSC compliance verification activities for NPPs may include field inspections of the physical and operational configurations.

Records management

The General Nuclear Safety and Control Regulations and the Class I Nuclear Facilities Regulations include requirements related to record retention and disposal. Licensees’ records management systems, including document control, ensure that only approved and current documents are issued and used. These systems ensure that:

• obsolete documents are withdrawn
• records are produced and reviewed for acceptance
• documents and records are available when needed
• records are protected and retained in accordance with the applicable regulatory requirements

CNSC staff base their assessment of the licensees’ implementation of the documents and records control processes through many regulatory activities involving a variety of SCAs.

Management of contractors

Licences for WMFs contain a condition requiring the licensee to ensure that contractors at the WMFs comply with the licence.

NPP and WMF licensees implement supply chain programs that qualify suppliers and manage contractual requirements and suppliers’ work, including purchased items. Licensees’ management defines, plans and controls the business by establishing safety objectives that meet regulatory and licensee requirements. Achievement of those objectives is measured and monitored; this activity includes aspects that are assigned to suppliers. CNSC compliance verification activities for NPPs may include Type II inspections on supply and contractor management and field inspections.

Business continuity

Licensees’ measures for business continuity include contingency plans to maintain or restore critical safety and business functions in the event of disabling circumstances, such as a pandemic, severe weather, or labour actions. For NPPs, those measures support minimum shift complement staffing.

2.2 Human performance management

This SCA covers the activities that enable effective human performance through the development and implementation of processes that ensure licensees have sufficient personnel in all relevant job areas – and that these personnel have the necessary knowledge, skills, procedures and tools to safely carry out their duties.

The performance objective of this SCA is to ensure that workers are sufficient in number, and human performance is managed, so that all workers are capable, competent, qualified and supported to carry out their work tasks safely.

Human performance management encompasses the following specific areas:

• human performance program
• personnel training
• personnel certification
• initial certification examinations and requalification tests
• work organization and job design
• fitness for duty

Human performance program

In accordance with the Class I Nuclear Facilities Regulations, and as a condition of the NPP and WMF licences, licensees are required to maintain human performance programs. The aim of these programs is to ensure that licensees consider human and organizational factors to safely carry out licensed activities.

Human and organizational factors are those factors that influence human performance. These factors include, but are not limited to, having a sufficient number of qualified staff who are adequately trained, fit for duty and provided with adequate processes and tools, and well-designed and well-maintained equipment. Human performance tools are applied to reduce events triggered by human error and support workers in completing their tasks effectively and safely. While each of these factors is considered individually, the human performance program brings these aspects together to provide a more integrated human-centric view of safety. Licensees apply the human performance program at a corporate level across their organizations and locally within the various departments. CNSC compliance verification activities for NPPs may include Type II inspections and field inspections.

Personnel training

In accordance with the General Nuclear Safety and Control Regulations, licensees are required to ensure that their workers are trained to carry on the licensed activities safely. Furthermore, NPP and WMF licences have a condition requiring the licensee to maintain a training program for workers. A training system provides the basis for the analysis, design, development, implementation, evaluation, documentation and management of the training programs for workers. NPP and WMF licensees have training systems that are based on the systematic approach to training methodology to comply with licence requirements. They support responsibilities, qualifications and requalification training of persons at the facilities and support initial certification training and renewal of certification training of persons in, and candidates for, certified positions. CNSC compliance verification activities for NPPs may include Type II inspections, as well as desktop inspections and field inspections.

Personnel certification

The Class I Nuclear Facilities Regulations establish conditions and requirements governing the certification of certain licensee staff by CNSC.

This specific area applies to NPPs but does not apply to their WMFs due to the absence of certified personnel. NPP licences have conditions requiring the licensee to maintain certification programs for the designated certified positions.

To become a certified worker, an NPP licensee must demonstrate that the candidate it puts forward for certification meets the requirements and that this candidate possesses the knowledge and skills to safely perform the duties of the position. Following the successful completion of a training program and several certification examinations, the NPP licensee demonstrates that its candidate meets the above requirements by submitting an application that provides sufficient proof of competency, a training history and examination results. Once certified by the CNSC, certified workers undergo continual training and requalification testing to ensure that they maintain the knowledge and skills necessary to safely perform their duties. CNSC staff administer the initial certification examinations and requalification tests for health physicists, while the licensees are responsible for the administration of the certification examinations and requalification tests for all other certified personnel.

CNSC staff conduct Type II and desktop inspections on knowledge-based and simulator examinations and testing for NPPs. CNSC compliance verification activities for NPPs also include field inspections that cover different topics such as verification of working under supervision or verification of the retention of records to support initial and renewal of certification applications. CNSC staff also conduct technical assessment of the licensees’ quarterly reports and event notifications on certified personnel.

Work organization and job design

This specific area applies to NPPs but does not apply to their WMFs.

In accordance with the General Nuclear Safety and Control Regulations, licensees are required to ensure the presence of a sufficient number of qualified workers to safely carry out all licensed activities. Furthermore, the NPP licences have a condition requiring the licensee to maintain a minimum shift complement and control room staffing. The minimum shift complement specifies the number of qualified staff who must be present onsite at all times for the safe operation of the NPP and to ensure adequate emergency response capability. The minimum shift complement is specific to each NPP and is determined through a systematic analysis of the most resource-intensive operating state, including design-basis accidents and emergencies. The results of the analysis are validated through integrated validation exercises. CNSC compliance verification activities may include field inspections that cover the monitoring and verification of the minimum shift complement, as well as main control room staffing. CNSC staff may also review non-compliances of, and updates to, the minimum shift complement.

Fitness for duty

Fitness for duty is defined as a condition in which workers are physically, physiologically, and psychologically capable of competently and safely performing their tasks. CNSC oversight of fitness for duty includes assessing licensee measures related to managing worker fatigue, managing alcohol and drug use, and minimum requirements for nuclear security officer medical, physical and psychological certificates.

In accordance with the Class I Nuclear Facilities Regulations, licensees are required to ensure workers’ fitness for duty.

Fatigue is widely recognized to affect fitness for duty because of its potential to degrade several aspects of human performance. All NPP licensees have procedures to manage worker fatigue that include limits on hours of work. CNSC compliance verification activities for NPPs may include field inspections that cover worker fatigue. CNSC staff also review quarterly reports of hours-of-work violations by personnel at NPPs.

2.3 Operating performance

This SCA includes an overall review of the conduct of licensed activities and the activities that enable effective operating performance.

The performance objective of this SCA is to ensure that facility operation is safe and secure, with adequate regard for health, safety, security, radiation and environmental protection, and international obligations.

Operating performance encompasses the following specific areas:

• conduct of licensed activity
• procedures
• reporting and trending
• outage management performance
• safe operating envelope
• severe accident management and recovery
• accident management and recovery

NPP and WMF licences have a condition requiring the licensee to maintain an operations program that includes a set of operating limits.

Conduct of licensed activity

CNSC staff monitor the licensees’ conduct of licensed activities through various compliance verification activities, including: baseline and focused inspections; desktop inspections and compliance assessments of licensees’ programs; reviews of quarterly and annual scheduled reports, event reports and follow-up actions associated with reportable events; and follow-up on licensees’ responses to inspection findings. Besides the numerous compliance verification activities related to the licensed activities of NPPs and WMFs, CNSC staff also assess various safety performance indicators (submitted per REGDOC-3.1.1), including:

• “mispositioning index”
• “number of unplanned transients”
• “unit capability factor”
• “unplanned capability loss factor”
• “forced loss rate”
• “reactor trip rate”

Procedures

Licensees have processes to ensure that procedures are developed and changes are managed in a consistent manner to support the safe operation and maintenance of NPPs and WMFs. CNSC staff’s oversight of procedures focuses on ensuring that there is an adequate process for the development, modification, and use of procedures that takes into account human performance considerations.. CNSC staff confirm the adequacy and management of the process to develop new procedures, and review and approve existing procedures. CNSC compliance verification activities for NPPs may include field inspections. Many Type II inspections also assess the adequacy of the procedures for the topic of the inspection (e.g., for instrument calibration or SSC monitoring).

Reporting and trending

The General Nuclear Safety and Control Regulations outline specific scenarios under which a licensee must file a report to the CNSC. For every reportable event, the licensee must file a full report that provides details about the event, including any effects on the environment, the health and safety of persons and the maintenance of security that have resulted or may result from the situation. The licensee must also describe the actions it has taken or proposes to take with respect to the event.

Licences for NPPs and WMFs also contain a condition with programmatic requirements for reporting. NPP licensees are required to submit quarterly reports on operations and safety performance indicators, as described in REGDOC-3.1.1. This regulatory document also expands on event reporting requirements in the regulations and specifies requirements for other quarterly and annual reports to the CNSC.

WMF licensees are subject to REGDOC‑3.1.2, which expands on event reporting requirements and requires them to submit annual reports on operations. In addition, they are required to provide quarterly operations reports for their WMFs, as detailed in their LCHs.

CNSC staff review event and other reports to confirm the licensee meets 1) the submission requirements and 2) CNSC staff’s expectations for the technical content and results contained therein.

Outage management performance

This specific area applies only to operating NPPs.

CNSC staff monitor the level of performance and achievement of objectives during planned maintenance outages. CNSC compliance verification activities may include Type II outage inspections.

Safe operating envelope

This specific area applies only to operating NPPs. The adherence of an operating NPP to its safe operating envelope (SOE) ensures that each reactor operates in an analyzed state, thereby ensuring adequate safety at all times. CNSC compliance verification activities for SOE may include Type II inspections and field inspections. CNSC staff may also review licensee updates of the limits and conditions in the SOE.

Severe accident management and recovery

This specific area applies only to NPPs. NPP licensees have severe accident management guidelines (SAMGs), which include measures to prevent severe damage to the reactor core in the event of an accident, mitigate the consequences of an accident involving damage to the reactor core and achieve stable conditions in the long term. Licensees demonstrate the effectiveness of SAMGs on an ongoing basis through exercises and drills.

To establish the instructions for use and deployment of emergency mitigating equipment (EME), licensees have EME guidelines. The purpose of EME is to provide additional water makeup and power-supply capabilities to cool the fuel, arrest accident progression and mitigate accident consequences for beyond-design-basis accidents, including severe accidents. CNSC compliance verification activities may include reviews of integrated SAMGs and integrated EMEGs.

Accident management and recovery

Licensees have procedures to manage potential incidents and accidents. For NPPs, these include abnormal incident manuals and emergency operating procedures. These procedures ensure that incidents are mitigated and the facility is returned to a safe and controlled state; they also prevent the further escalation of the abnormal incident into a serious accident. CNSC compliance verification activities for NPPs, which are typically limited to on-site monitoring and surveillance, ensure that up-to-date procedures are available to the operators and that those operators are adequately trained in their use.

2.4 Safety analysis

This SCA pertains to maintaining the safety analysis that supports the overall safety case for each facility. Safety analysis is a systematic evaluation of the potential hazards associated with the conduct of a proposed activity or facility, and considers the effectiveness of preventive measures and strategies in reducing the effects of such hazards.

The performance objective of this SCA is to ensure that updates to safety analysis effectively incorporate feedback from various sources to continually demonstrate safety.

For NPPs, safety analysis is primarily deterministic in demonstrating the effectiveness of the fundamental safety functions of controlling power, cooling the fuel and containing or limiting any releases from the plant. Risk contributors are considered through probabilistic safety assessments (PSAs). Appropriate safety margins should be demonstrated to address uncertainties and limitations of safety analysis approaches.

Safety analysis encompasses the following specific areas:

• deterministic safety analysis
• hazard analysis
• probabilistic safety assessment
• criticality safety
• severe accident analysis
• management of safety issues (including R&D programs)

NPP and WMF licences have a condition requiring the licensee to maintain a safety analysis program.

Deterministic safety analysis

The safety analysis report describes the SSCs of the facility including their design and operating conditions. The final safety analysis report demonstrates the adequacy of the facility’s design by identifying facility hazards and using deterministic safety analysis and other techniques to confirm the ability of safety mechanisms to control or mitigate those hazards.

Licensees are required to submit an updated facility description and safety analysis report for their facilities every five years – for NPP licensees this is stipulated in REGDOC-3.1.1 and for WMFs this is stipulated in their LCHs. CNSC staff review the safety analysis reports to verify compliance with the applicable regulatory requirements, which include requirements set out in the regulations and regulatory documents, as well as the licensees’ design and analysis specifications. CNSC staff also review specific deterministic safety analyses that are developed or updated to address specific safety issues.

Impact of aging on the safety analysis for NPPs

NPP aging management programs include activities to systematically monitor and manage aging-related factors that could affect, to different degrees, the conditions of SSCs important to safety. Licensees implement compensatory measures to mitigate the impact of aging when needed. As such, the overall safety case of an NPP needs to be periodically assessed and the existing safety margins quantified.

Aging can affect certain characteristics of the heat transport system, resulting in a gradual reduction of safety margins. NPP licensees monitor, assess and mitigate the impact of heat transport system aging on safety analysis to demonstrate safe operation of the NPP.

Hazard analysis

NPP and WMF licensees periodically update their hazard assessments (e.g., related to fire or seismicity) to reflect changes and facility modifications. In addition, licensees implement measures to identify, minimize, monitor and control those hazards. CNSC compliance verification activities may include reviews of the licensee’s assessments.

Probabilistic safety assessment

Probabilistic safety assessment (PSA) applies to operating NPPs. CNSC compliance verification activities for PSA may include compliance assessments of licensee submissions of proposed PSA methodologies as well as compliance assessments of the PSAs themselves.

Criticality safety

NPP and WMF licensees handle and store fuel bundles containing fresh and/or irradiated natural or depleted uranium, neither of which can become critical in air or in light water. NPPs and WMFs that only possess those substances are not required to maintain nuclear criticality safety programs. Analyses of nuclear criticality safety of those types of bundles have been performed and included in the safety analysis reports of the WMFs. However, due to the storage of booster fuel assemblies at the Bruce A NPP and the storage of irradiated low void reactivity fuel at the Bruce B NPP, the licensee is required to have a criticality safety program. CNSC compliance verification activities at Bruce A and B may include compliance assessments of the licensee’s nuclear criticality safety programs.

Severe accident analysis

This specific area applies to operating NPPs. NPP licensees perform severe accident analyses to assess, in conjunction with PSA, the achievement of plant safety goals, to demonstrate effectiveness of severe accident management, and to support severe accident exercises for emergency preparedness and response. CNSC compliance verification activities may include compliance assessments of licensees’ submissions of specific analyses of severe accidents.

Management of safety issues (including R&D programs)

This specific area applies to operating NPPs.

CNSC staff evaluate the licensees’ R&D program activities, as submitted to CNSC staff through annual reporting in accordance with REGDOC-3.1.1. The annual reports describe R&D activities to resolve safety issues that were completed, underway or planned during the year or are planned for future years, the nature of the safety issues being resolved and progress during the year to resolve the safety issues.

CANDU safety issues

In 2007, CNSC staff identified generic safety issues associated with CANDU reactors. This activity was in response to initiatives started by the International Atomic Energy Agency (IAEA) to reassess the safety of operating NPPs. CANDU safety issues (CSIs) were classified into three broad categories according to the adequacy and effectiveness of the control measures implemented by the NPP licensees, namely:

• Category 1: Not an issue in Canada – has been satisfactorily addressed.
• Category 2: Issue is a safety concern in Canada but appropriate measures are in place to maintain safety margin.
• Category 3: Issue is a concern in Canada. However, measures are in place to maintain safety margins but the adequacy of these measures needs to be confirmed.

The CNSC monitors the management of CSIs by licensees of operating NPPs to ensure timely and effective implementation of plant-specific safety improvement initiatives and risk-control measures.

2.5 Physical design

This SCA relates to activities that affect the ability of SSCs to meet and maintain their design basis as new information arises over time and changes take place in the external environment.

The performance objective of this SCA is to ensure that SSCs that are important to safety and security continue to meet their design basis.

Physical design encompasses the following specific areas:

• design governance
• site characterization
• facility design
• structure design
• system design
• component design

NPP and WMF licences have a condition requiring the licensee to maintain a design program.

Design governance

NPP licences have a condition requiring the licensee to maintain an equipment and structure qualification program.

NPP and WMF licensees have policies, processes and procedures that provide direction and support for physical design. Licensees’ design management is supported by programs that govern the conduct of engineering, pressure boundaries, seismic qualification, environmental qualification, human factors in design, robustness and fire protection, as well as change control mechanisms within their management systems.

Seismic qualification

Seismic qualification is the verification of the ability of an SSC to perform its intended function during and/or following the designated earthquake, through testing, analysis or other methods.

Environmental qualification

An environmental qualification program ensures that all required SSCs are capable of performing their designated safety functions in a postulated harsh environment resulting from design-basis accidents. CNSC staff monitor this area (including NPP licensees’ bi-annual or annual environmental qualification health reports) to confirm that the NPP licensees continue to maintain environmental qualification in the context of aging reactors and limited resources.

Pressure boundary design

NPP and WMF licences have a condition requiring the licensee to maintain a pressure boundary program. The licensees maintain formal service agreements with an authorized inspection agency for pressure boundaries.

Human factors in design

Human factors in design applies knowledge of human capabilities and limitations in the design of SSCs to improve the interaction between humans and technical systems and to optimize human and system performance.

Robustness design

Robustness design and assessment cover the physical design of nuclear facilities for sufficient robustness against anticipated threats. The CNSC’s assessment of this specific area is based on licensee performance in meeting regulatory commitments for mitigating the potential consequences of these accidents.

Fire protection – Governance

NPP and WMF licensees have fire protection programs to minimize the risk to health, safety and the environment due to fire. Implementation of the fire protection program ensures that each licensee is able to efficiently and effectively control and respond to fires. The fire protection provisions are applicable to all work related to the design, construction, operation and maintenance of nuclear facilities, including the SSCs that directly support the facility and the protected area.

CSA Group standards require licensees to submit their periodic reviews and updates of the fire protection programs and fire protection assessments to the CNSC. In addition, licensees are required to submit third-party reviews of proposed modifications with the potential to impact the fire protection objectives. CNSC compliance verification activities may include compliance assessments of licensees’ fire hazard assessments, fire safe shutdown analyses, and code compliance reviews, as well as compliance assessments of third party audits of fire protection programs and annual assessments of plant condition. For NPPs, the five-year baseline compliance cycle includes a Type II inspection and four field inspections that cover fire protection.

Site characterization

Site characterization encompasses processes for describing the distinguishing characteristics, qualities, physical features and environment of the land on which the nuclear facility is located.

Facility design

Facility design (and structure design) pertain to the overall adequacy of the design of the facility and structures, which are governed by licensee design programs and a number of codes and standards. There are no specific CNSC activities to verify compliance in this specific area.

Structure design

The design of structures in NPPs and WMFs is governed by licensee design programs and a number of codes and standards. CNSC compliance verification activities may include Type II inspections on the preservation of the seismic design basis and field inspections on seismic verification.

System design

This specific area is applicable to NPPs.

Electrical power systems

The electrical power system (EPS) provides support for the safety of an NPP and is important for defence in depth. It is essential that NPPs have a reliable EPS to control anticipated deviations from normal operation as well as to power, control and monitor the plant during events of all types. CNSC compliance verification activities for EPS design may include Type II inspections.

Instrumentation and control

I&C provides functions of protection, control, and monitoring for the safety of an NPP. I&C consists of measuring devices, controllers and actuating devices. The devices and controllers must meet the safety and reliability requirements, which are related to defence in depth, operational limits and conditions, common-cause failures, separation, diversity, independence, single-failure criterion and fail-safe design. In addition, I&C monitors plant variables and systems over the respective ranges for operational states, design-basis accidents and design extension conditions in order to ensure that adequate information can be obtained on plant status. CNSC compliance verification activities for I&C design may include Type II inspections and field inspections.

Component design

This specific area is applicable to NPPs.

Fuel design

Fuel bundles and fuel assemblies are important examples of designs that are considered safety and control measures. The fuel pellet and fuel sheath act as the first and second physical barriers against radioactive release. Protection of the fuel through robust design, controlled operations and a monitoring program is essential to ensure the protection of workers and the public from the harmful effects of radiation. The licensees of operating NPPs establish fuel designs and operating procedures and limits, perform analyses and implement inspection programs. CNSC compliance verification activities for fuel may include compliance assessments and the review of new fuel design and verification programs.

Fuel Inspection Program

Performance of the fuel inspection and design programs are characterized by four key areas of fuel performance:

• operation within burnup and power limits
• prevention and mitigation of fuel defects
• prevention and detection of abnormal fuel conditions
• minimization of operational events that may challenge the fuel condition

CNSC staff monitor the efficacy of the licensees’ management of these program indicators.

Fuel programs with effective performance in these areas maintain their fuel within the design basis conditions and thereby ensure that adequate margins are maintained to the safe operating envelope (SOE) limits. They also prevent the release of radioactivity to the primary heat transport (PHT) system and auxiliary systems, including the irradiated fuel bays (IFBs) and irradiated fuel ports (IFPs). Activities to support these key areas limit the potential dose to workers in normal operation and would help to protect the integrity of the first two barriers to fission product release in accident scenarios.

Cables

Cables are critical to the safe and reliable operation of NPPs due to their widespread use as a connection medium for many systems important to safety. Canada’s operating reactors are aging and cables are affected by the aging process. The licensees of operating NPPs implement cable condition monitoring and surveillance programs, as well as cable aging management programs to assess the degradation of cable insulation over time. Although there may not be any regular CNSC compliance verification activities for cables in the five-year cycle, several inspections have line items that cover cables.

2.6 Fitness for service

This SCA covers activities affecting the physical condition of SSCs to ensure that they remain effective over time. This includes programs that ensure that all equipment is available to perform its intended design function when needed.

The performance objective of this SCA is to ensure that SSCs for which the performance may affect safety or security remain available, reliable, effective and consistent with design, analysis and quality control measures.

Fitness for service encompasses the following specific areas:

• equipment fitness for service / equipment performance
• maintenance
• structural integrity
• aging management
• chemistry control
• periodic inspection and testing

NPP and WMF licences have a condition requiring the licensee to maintain a fitness for service program.

Equipment fitness for service / equipment performance

This specific area applies to NPPs. An important consideration for NPPs under this specific area is the reliability of systems important to safety. CNSC compliance verification activities may include Type II inspections of the reliability program for systems important to safety.

The reliability programs for operating NPPs include trending of system performance by monitoring process parameters, station condition records, and test and inspection results, initiating investigations or maintenance activities as needed.

REGDOC-3.1.1 requires licensees of operating NPPs to report the results of its reliability program to the CNSC annually. CNSC staff review these reports to confirm compliance with the regulatory requirements. The reports include information on the reliability of the special safety systems (SSSs), including their availability. Availability is defined as the fraction of time that an SSS meets the minimum allowable performance standards. Unavailability targets are established as part of the design requirements of the SSSs, in addition to the other reliability-related design requirements, such as separation and independence, fail-safe, single failure criterion, redundancy and diversity. Unavailability targets of the SSSs are assigned in a way to be consistent with the NPP’s safety goals and to maintain a balance between the prevention and mitigation of events. Unavailability targets are established based on frequency of demand, consequence of failure and overall risk.

Licensees monitor the performance or condition of the SSSs against unavailability targets (no higher than 0.001) to ensure that these systems are capable of fulfilling their intended functions. However, activities may result in conditions where the SSS will be incapable of meeting its unavailability target. Examples of these activities include preventive maintenance, testing and corrective repairs to failed components (unscheduled activity), as well as the occurrence, during operation, of initiating events that cause challenges to plant systems and operations.

When the performance or condition of any SSC fails to meet established targets, appropriate corrective action should be taken, which may involve a detailed technical analysis. If the analysis demonstrates that the safety objectives and defence in depth are ensured, no immediate corrective action may be needed. However, the licensee should continue to monitor the SSC closely.

In addition, the licensees’ reliability programs require the availability of systems important to safety to be confirmed through surveillance activities such as tests and inspections. Missed tests are tracked by licensees and reported to the CNSC as required by REGDOC-3.1.1. The number of missed tests is a measure of a licensee’s ability to successfully complete routine tests on safety-related systems and is used in the calculation of the predicted availability of systems.

Maintenance

CNSC compliance verification activities for NPPs may include Type II inspections and field inspections that cover maintenance work planning, scheduling and execution as well as the monitoring of SSCs.

CNSC staff also routinely monitor several maintenance safety performance indicators for operating NPPs, including those that are required to be reported according to REGDOC-3.1.1, namely the “preventive maintenance completion ratio” (PMCR), maintenance backlogs and the number of preventive maintenance deferrals.

The number of deferrals and backlogs by themselves are not a measure of safety significance, since different risks are associated with the completion of different maintenance activities. Consequently, there are no predetermined limits for these indicators. CNSC staff track trends and compare the values of these indicators at individual NPPs with the industry average. Staff also monitor the licensee’s process for prioritizing activities based upon their risk significance, to help determine if closer regulatory scrutiny is warranted. Based on the assessment, CNSC staff might, for example, increase the focus on maintenance during regular field inspections, adjust the frequency of the baseline compliance program inspection on maintenance planning and scheduling, or conduct a reactive inspection to verify the causes and determine the actual safety significance of the values observed.

The PMCR quantifies the effectiveness of the preventive maintenance program in minimizing the need for corrective maintenance activities for safety-related systems.

The safety performance indicators corrective maintenance backlog, deficient maintenance backlog and deferrals of preventive maintenance are used to monitor the effectiveness of the maintenance program at NPPs.

• Corrective maintenance work is required when an SSC has failed and can no longer perform its design function. As defined by REGDOC-3.1.1, corrective maintenance backlogs consist of all corrective work generated through work order requests and appearing in the work management system as uncompleted work.
• Deficient maintenance is planned when SSCs of NPPs have been identified as degrading but remain capable of performing their design functions. The deficient maintenance backlog consists of all deficient work generated through work requests and appearing in the work management system as uncompleted work.
• Deferred preventive maintenance is preventive maintenance at NPPs that has received an approved technical justification for extension prior to its late date.

A certain level of backlog is expected due to normal work management processes and equipment aging. Although usually not safety significant, maintenance backlogs can be a useful indicator of overall maintenance effectiveness and plant operation. CNSC staff focus their attention on the corrective and deficient maintenance backlogs for critical (i.e., safety-significant) components.

Structural integrity

Licensees have processes to monitor and assess structural integrity, such as inspections and tests of safety-significant structures and components. These processes draw on results from aging management and periodic inspection and testing activities, which are described in the following subsections.

The NPP licensees inspect pressure boundary components and containment. They also monitor and assess safety-significant balance-of-plant systems and structures. In general terms, balance-of-plant pressure boundary systems consist of the systems and components that comprise a complete NPP, excluding the nuclear systems.

WMF licensees inspect DSCs, dry storage modules (DSMs) and storage facility structures. For example, DSC seal welds are inspected after fuel loading and periodically for aging related degradation; welding bay walls are also inspected.

CNSC compliance verification activities related to structural integrity include desktop reviews of reports provided by the licensee (such as quarterly operations reports, pressure boundary reports, and event reports for NPPs, as well as inspection reports and annual aging management reports for DSCs).

Aging management

NPP and WMF licensees have implemented processes and programs to address aging-related factors that could affect the condition of SSCs important to safety. The licensees manage known and plausible aging-related degradation of SSCs to prevent the erosion of design and safety margins.

NPP licensees have component-specific aging management programs (typically referring to them as lifecycle management plans (LCMPs)) for the major primary heat transport components of their reactors (that is, feeders, pressure tubes and steam generators) as well as for reactor internals, concrete containment structures, and balance-of-plant safety-related civil structures.

The LCMPs include structured, forward-looking inspection and maintenance schedule requirements to monitor and trend aging effects and any preventive actions necessary to minimize and control aging degradation. The licensees update their LCMPs to incorporate operating experience and research findings and submit them to the CNSC for review.

WMF licensees have aging management plans for DSCs to address plausible aging mechanisms and inspection programs to support the aging management of civil structures.

Compliance monitoring activities conducted by CNSC staff include desktop reviews of licensee submissions related to integrated aging management programs and components and to structure-specific LCMPs.

Fuel channels

Aging management programs for pressure tubes are important to the ongoing safe operation of the NPPs as operating conditions in CANDU fuel channels have significant effects on the material properties. Pressure tube aging management activities include inspections to verify the condition of the tubes, surveillance activities to monitor material property changes, and the development of assessment methodologies and fitness-for-service guidelines.

In addition to pressure tube aging, LCMPs address the aging and behaviour of fuel channel spacers, which maintain the gaps between pressure tubes and their corresponding calandria tubes. If contact occurs between a pressure tube and the cooler calandria tube, pressure tube degradation may result. Licensees assess the possibility of spacer movement along the fuel channel over time (which could increase the likelihood of pressure tube to calandria tube contact) and correct the positioning if necessary.

Research in aging management

The licensees demonstrate the ability to safely operate pressure tubes through assessments of the current and expected conditions of the pressure tubes, basing the assessments on an understanding of relevant degradation mechanisms. Research activities as well as inspection and maintenance programs provide data to periodically validate the input parameters for these assessments. To assess mechanisms or parameters that are dependent on neutron flux (such as diametral creep of pressure tubes), EFPH is the best indicator. The Commission can approve new EFPH limits for pressure tubes in NPP units as new information has become available; they are identified as compliance verification criteria in the LCHs for the NPPs.

However, for in-service changes in pressure tube properties (such as fracture toughness), equivalent hydrogen (Heq) concentration is more important than EFPH. Fracture toughness is an important parameter that is modelled and used for assessments of leak-before-break and fracture protection of pressure tubes. For temperatures below 250 °C, Heq content in the pressure tube is a critical input to the fracture toughness model.

Chemistry control

CNSC compliance verification activities for NPPs may include Type II inspections of chemistry control and field inspections that cover chemical storage and on-line monitoring. CNSC compliance verification activities for WMFs may include reviews of licensees’ operations reports.

CNSC staff also monitor safety performance indicator data related to chemistry. REGDOC-3.1.1 requires the licensees of operating NPPs to report data for the safety performance indicators “chemistry index” and “chemistry compliance index”. The chemistry index reflects the control of important chemical parameters for plant operation. The chemistry compliance index reflects the control of safety-related chemical and radiological parameters in both non-guaranteed shutdown states and guaranteed shutdown states. Both indicators are calculated as the average percentage of time that the identified parameters are within the licensee’s specifications.

Periodic inspection and testing

This specific area applies to operating NPPs.

Licensees of operating NPPs have inspection and testing programs to provide ongoing monitoring of the fitness for service and structural integrity of safety-significant pressure boundary and containment SSCs. The licensees submit the results of these inspections and tests to CNSC staff, who verify the effective licensee implementation of the inspection and testing programs.

Licensees are also required to have inspection programs for balance-of-plant pressure boundary systems that are not covered under the scope of the CSA group standards that are in the licensing basis, but could have an impact on safe operation. The licensees carry out these programs in accordance with industry best practices. CNSC staff monitor the findings provided in the quarterly pressure boundary reports required by REGDOC- 3.1.1 and verify licensees’ compliance with their documented programs through field inspections.

2.7 Radiation protection

This SCA covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations. The program must ensure that contamination levels and radiation doses received by individuals are monitored, controlled and maintained as low as reasonably achievable (ALARA).

The performance objective of this SCA is to ensure that the health and safety of persons are protected through the implementation of a radiation protection program that ensures that radiation doses are kept below regulatory dose limits and are optimized and maintained ALARA.

Dose data are based on the radiation exposure records for every individual monitored at a Canadian NPP or WMF. CNSC staff analyse dose records in terms of annual collective dose ^{Footnote 1}, average effective dose ^{Footnote 2}, maximum individual effective dose, and the distribution of doses among the monitored individuals.

Radiation protection encompasses the following specific areas:

• application of ALARA
• worker dose control
• radiation protection program performance
• radiological hazard control

In accordance with the Radiation Protection Regulations, licensees are required to implement a radiation protection program. NPP and WMF licences have a condition requiring the licensee to maintain a radiation protection program that includes a set of action levels. A radiation protection action level is a specific dose or other parameter (e.g., contamination level) that, if reached, could indicate a loss of control of part of a licensee’s radiation protection program and the need for specific actions to be taken and reported to the CNSC.

Application of ALARA

NPP and WMF licensees implement radiation protection measures to keep the doses to persons ALARA, taking into account social and economic factors, as required by the Radiation Protection Regulations. Each licensee develops its own ALARA dose targets that are based on anticipated operational and maintenance activities and take past performance into consideration.

Each licensee also develops forward-looking dose projections and reduction plans for collective radiation exposure.

CNSC compliance verification activities for NPPs may include Type II inspections on the application of ALARA and field inspections. CNSC staff also review the licensees’ quarterly operations reports for NPPs and WMFs, which include data for the NPP safety performance indicator “collective radiation exposure” as well as dose data and dose trend information (submitted per REGDOC-3.1.1 and REGDOC-3.1.2).

Worker dose control

The Radiation Protection Regulations require all licensees to implement a radiation protection program to control and ascertain the occupational doses received by persons. In addition to maintaining doses to persons below the effective and equivalent dose limits in the Radiation Protection Regulations, NPP and WMF licensees have established action levels for worker exposures. CNSC staff monitor licensee actions for the affected workers following unplanned exposures or uptakes. CNSC compliance verification activities for NPPs may include Type II inspections and field inspections. CNSC staff also review data for the NPP safety performance indicator “unplanned dose/unplanned exposure” (submitted per REGDOC-3.1.1).

Radiation protection program performance

NPP and WMF licensees implement radiation protection programs and seek to improve program performance through assessment and benchmarking. The licensees maintain program documents and supporting procedures, taking into consideration operating experience and industry best practices. Licensee programs include safety performance indicators to monitor program performance.

Radiological hazard control

NPP and WMF licensees implement measures in their radiation protection programs to monitor, minimize and control radiological hazards and prevent the spread of radioactive contamination in their facilities. These measures include, but are not limited to, the use of radiological zoning systems, ventilation systems to control the direction of air flow, and the use of ambient air monitoring and radiation monitoring equipment at zone boundaries. The licensees set action levels for contamination control. The licensees also implement workplace monitoring programs to protect workers, identify changing radiological conditions and ensure that radioactive contamination is controlled within the site boundary.

CNSC compliance verification activities for NPPs may include Type II inspections and field inspections. CNSC staff also review data for the NPP safety performance indicators “personnel contamination events” and “loose contamination events” (submitted per REGDOC-3.1.1).

2.8 Conventional health and safety

This SCA covers the implementation of a program to manage workplace safety hazards and protect personnel and equipment.

The performance objective of this SCA is to ensure that conventional health and safety work practices and conditions achieve a high degree of personnel safety.

The conventional health and safety SCA encompasses the following specific areas:

• performance
• practices
• awareness

In accordance with the General Nuclear Safety and Control Regulations, licensees are required to take all reasonable precautions to protect the health and safety of persons. NPP and WMF licences have a condition requiring the licensee to maintain a conventional health and safety program. Specific regulatory requirements for conventional health and safety are found in the relevant provisions of provincial and/or federal laws (Ontario’s Occupational Health and Safety Act; Ontario’s Labour Relations Act; New Brunswick’s Occupational Health and Safety Act; Quebec’s Loi sur la Santé et la Sécurité au Travail; and the Canada Labour Code, Part II: Occupational Health and Safety). The CNSC has memoranda of understanding with the Provinces of Ontario and New Brunswick to facilitate cooperation in the regulation of conventional health and safety.

CNSC compliance verification activities for NPPs may include field inspections.

Performance

This specific area reflects the processes that monitor, track and report the level of occupational safety of workers. During inspections, CNSC staff record findings on safety practices and the controls being employed to address conventional hazards. CNSC staff also monitor data for the safety performance indicators “accident severity rate”, “accident frequency” and “industrial safety accident rate” at NPPs (submitted per REGDOC-3.1.1).

Practices

The practices specific area reflects licensee processes that ensure that managers and workers are actively involved in the support and enforcement of the safety actions.

The licensees establish practices through their conventional health and safety policies and programs to protect workers from physical, chemical and other hazards that may arise in their facilities. The licensees provide the CNSC with any report they send to other regulatory agencies (such as the provincial regulatory body for occupational health and safety).

For facilities in Ontario and New Brunswick, CNSC site staff maintain regular communication with the provincial Ministry of Labour regional offices and WorksafeNB, respectively, regarding any conventional health and safety issues.

Workers at NPPs and WMFs could be exposed to hazardous materials and industrial work hazards. Hazardous materials can include compressed gases such as gases used for welding activities or fire suppression and for emission monitors. Other materials include lubricants, adhesives, abrasives, solvents, paints, fuel for incinerators and other maintenance and cleaning supplies. In addition, the risks from conventional hazards include, for example, the hazards associated with the control and safe handling of large and heavy equipment, scaffolding, and conventional X-ray equipment for security-related purposes.

Awareness

Awareness reflects processes that ensure that managers and workers have the knowledge to identify workplace hazards and precautions.

Licensees deliver safety-related training courses to their employees and contractors. These courses encompass the safety areas of general health and safety knowledge, radiation protection, fire protection, regulatory requirements and job/task-specific safety training, and use of the Workplace Hazardous Materials Information System (WHMIS), which provides complete information on the safe use of hazardous and combustible materials.

2.9 Environmental protection

This SCA covers programs that identify, control and monitor all releases of radioactive and hazardous substances, and the effects on the environment from facilities or as a result of licensed activities.

The performance objective of this SCA is to ensure that the licensee takes all reasonable precautions to protect the environment and the health and safety of persons. This includes identifying, controlling and monitoring the release of nuclear and hazardous substances to the environment.

Environmental protection encompasses the following specific areas:

• effluent and emissions control (releases)
• environmental management system
• assessment and monitoring
• protection of people
• environmental risk assessment

NPP and WMF licences have a condition requiring the licensee to maintain an environmental protection program that includes a set of action levels.

Effluent and emissions control (releases)

As part of normal operations, NPPs and WMFs can release radioactive substances into the atmosphere (as gaseous emissions) and bodies of water (as liquid effluents). Licensees are required to control radioactive releases into the environment to ensure that they are protective of human health and the environment and do not exceed the regulatory release limits. These radioactive release limits are based on derived release limits (DRLs), which are quantities of radionuclides (released as an airborne emission or waterborne effluent) that are calculated based on the regulatory dose limit for the public of 1 mSv per year. NPPs and WMFs operated by the same licensee on the same site typically have a single set of DRLs for the effluents and emissions for the two facilities collectively (the exception is Bruce Power, which calculates separate DRLs for the Bruce A and Bruce B NPPs).

Licensees also establish and use environmental action levels. An action level is a specific quantity of radionuclide (released as an airborne emission or waterborne effluent) that, if reached, could indicate a loss of control of part of a licensee’s environmental protection program and the need for specific actions to be taken and reported to the CNSC.

CNSC compliance verification activities may include reviews of the NPP performance indicator “environmental releases - radiological” as well as the licensees’ annual reports that address environmental protection.

Environmental management system

Each licensee has an environmental management system (EMS) to assess environmental risks associated with its nuclear activities, and to ensure that these activities are conducted in a way that prevents or mitigates adverse environmental effects. The EMS includes activities such as the establishment of annual objectives and targets.

Assessment and monitoring

Under the NSCA, the licensee of each nuclear facility is required to develop, implement and maintain an environmental monitoring program to demonstrate that the public and the environment are protected from emissions related to the facility’s nuclear activities. The results of these monitoring programs are submitted to the CNSC to ensure compliance with the public dose limit of 1mSv/year for nuclear substances, as per the Radiation Protection Regulations, and compliance with the applicable limits for hazardous substances in accordance with environmental compliance approvals associated with municipal, provincial and federal legislation.

As mentioned above, NPP and WMF licensees are required to submit to the CNSC annual reports that address environmental protection. Licensees also monitor groundwater around all sites and regularly submit the results to the CNSC.

Independent Environmental Monitoring Program

To complement ongoing compliance activities, the CNSC has implemented its own Independent Environmental Monitoring Program (IEMP). The IEMP involves taking samples from publicly accessible areas around the facilities and measuring the amount of radiological and hazardous substances in those samples. Samples may be taken for air, water, soil, sediment, vegetation, and some food such as meat and produce.

Additionally, regional monitoring is carried out by other government organizations in the area around the NPPs, which the CNSC takes into account when assessing the protection of public health and the environment. These organizations include the Drinking Water Surveillance Program of Ontario’s Ministry of the Environment, Conservation and Parks, the Reactor Surveillance Program of Ontario’s Ministry of Labour, Training and Skills Development, and Health Canada’s Canadian Radiological Monitoring Network, along with the Fixed Point Surveillance Network. These programs provide further confirmation that the environment around the sites is protected and that health impacts are not expected.

Protection of people

This specific area is related to ensuring that members of the public are not exposed to unreasonable risk with respect to hazardous substances discharged from the facilities. CNSC staff regularly monitor licensee data for the performance indicator “spills” (submitted per REGDOC‑3.1.1). Dose to the public is discussed separately in section 7.

Environmental risk assessment

An environmental risk assessment (ERA) is a systematic process used by licensees to identify, quantify and characterize the risk posed by contaminants (nuclear and hazardous substances) and physical stressors in the environment to human and non-human (biological) receptors. The applicant’s or licensee’s ERA provides science-based information to inform monitoring programs and support regulatory decision making under the NSCA.

Licensees update the ERAs of the NPPs and WMFs on a five-year cycle or more frequently if major facility changes are proposed or if the science upon which the conclusions are based changes.

NPP licensees have developed and implemented programs to ensure the protection of fish populations from the effects of intake water withdrawal (fish impingement and entrainment) and cooling water thermal discharge and to verify that measures are in place to ensure that risks to fish and fish populations remain acceptable. This work is conducted at the request of CNSC staff, with advice and support from government ministries and agencies, including Fisheries and Oceans Canada and Environment and Climate Change Canada through memoranda of understanding.

Estimated dose to the public

The Radiation Protection Regulations require all licensees to maintain doses to non-nuclear energy workers below effective and equivalent dose limits. The estimated doses to the public are calculated based on measured airborne emissions and liquid releases.

2.10 Emergency management and fire protection

This SCA covers emergency response plans and emergency preparedness programs for managing radiological, nuclear and conventional emergencies and non-routine conditions. It also includes the results of participation in emergency response exercises.

The performance objective of this SCA is to ensure that emergency preparedness measures and fire protection response capabilities are in place to prevent and mitigate effects of nuclear and hazardous substances releases, both onsite and offsite, and fire hazards, in order to protect workers, the public and the environment.

The emergency management and fire protection SCA encompasses the following specific areas:

• conventional emergency preparedness and response
• nuclear emergency preparedness and response
• fire emergency preparedness and response

For the specific area of fire emergency preparedness and response, only the performance of the industrial fire brigade organization is addressed in this SCA; design issues are addressed in the SCA Physical design.

NPP and WMF licences have a condition requiring the licensee to maintain an emergency preparedness program.

Conventional emergency preparedness and response

NPP and WMF licensees maintain conventional emergency preparedness and response capabilities to manage potential emergency situations, such as physical injuries, chemical releases, uncontrolled energy releases (such as steam, electricity or compressed gas), equipment malfunctions, pandemic responses and extreme weather conditions. Licensees have safety and emergency response programs to minimize both the probability of occurrence and the consequences from emergencies involving conventional hazards. These programs identify training, barriers, procedures, processes, and emergency response to ensure a planned, coordinated and controlled approach to conventional safety and response.

CNSC compliance verification activities for NPPs may include Type II inspections of emergency preparedness and response and field inspections of emergency response facilities and equipment.

Nuclear emergency preparedness and response

NPP and WMF licensees have emergency preparedness programs that identify the concepts, structures, roles and resources to implement and maintain effective nuclear emergency response capabilities. The programs establish how nuclear facilities and other concerned organizations prepare for, and plan to, respond to emergencies (including nuclear or radiological emergencies, both onsite and offsite), in order to protect workers, the public and the environment. An effective emergency preparedness program ensures that arrangements are in place to ensure a timely, coordinated and effective response to any emergency.

Each licensee’s response capability is captured in its nuclear emergency plan, which encompasses both emergency preparedness and emergency response measures. It ensures that appropriate emergency response capabilities have been developed and are maintained for an effective response in the event of a nuclear emergency. The plan is based upon the licensee’s planning basis for both design-basis and beyond-design-basis events.

The licensees’ nuclear emergency plans include measures to address onsite emergencies, as well as measures that support planning, preparedness and response for offsite emergencies. Each licensee’s emergency plan is specific to its particular site and organization. However, all emergency plans typically cover:

• documentation of the emergency plan
• basis for emergency planning
• personnel selection and qualification
• emergency preparedness and response organizations
• staffing levels
• emergency training, drills and exercises
• emergency facilities and equipment
• emergency procedures
• assessment of emergency response capability
• assessment of accidents
• activation and termination of emergency responses
• protection of facility personnel and equipment
• interface arrangements with offsite organizations
• arrangements with other agencies or parties for assistance
• recovery program
• public information program
• public education program

The response to offsite emergencies takes a hierarchical approach that involves the licensee, the local municipal government, the provincial/territorial government and the federal government. Background information on the measures provided by each of these stakeholders is provided in appendix A.

As part of their emergency preparedness programs, the licensees annually conduct emergency preparedness training, drills and exercises to ensure that their sites have adequate and robust emergency notification and response capability from their own staff and/or nearby emergency services with which they have memoranda of understanding or agreements.

CNSC compliance verification activities for NPPs may include Type II inspections of emergency preparedness and response and Type II inspections of accident management drills and exercises. The baseline program may include:

• field inspections of emergency response facilities and equipment
• field inspections of emergency mitigating equipment deployment
• field inspections of offsite support equipment and services
• field inspections of emergency drills

For NPPs, CNSC staff also assess the safety performance indicators “radiological emergencies performance index”, “emergency response organization (ERO) drill participation index” and “emergency response resources completion index” (submitted per REGDOC-3.1.1).

Fire emergency preparedness and response

NPP and WMF licences have a condition requiring the licensee to maintain a fire protection program. The programs minimize both the probability of occurrence and the consequences of fire at the facilities. They identify the procedures and processes to demonstrate a planned, coordinated and controlled approach to fire protection. Fire response capability is maintained through a variety of arrangements. The licensees incorporate the results of the CNSC compliance findings and observations and the recommendations from third-party reviews into the drill and training program.

CNSC compliance verification activities for NPPs and WMFs may include compliance assessments of licensees’ fire hazard assessments, fire safe shutdown analyses, and code compliance reviews, as well as third party audits of fire protection programs and annual assessments of plant condition. CNSC compliance verification activities for NPPs may include Type II inspections of fire response, field inspections of fire brigade drills and field inspections of fire response facilities and equipment.

2.11 Waste management

This SCA covers internal waste-related programs that form part of the facility’s operations up to the point where the waste is removed from the facility. This SCA also covers any planning for eventual decommissioning of the facility.

The performance objective of this SCA is to ensure that:

• a facility- and waste stream-specific waste management program is fully developed, implemented and audited to control and minimize the volume of nuclear waste generated by the licensed activity
• waste management is included as a key component of the licensee’s corporate and safety culture
• a decommissioning plan is maintained

Waste management encompasses the following specific areas:

• waste characterization
• waste minimization
• waste management practices
• decommissioning plans

CNSC REGDOC-2.11, Framework for Radioactive Waste Management and Decommissioning in Canada, defines radioactive waste as any material (liquid, gaseous or solid) that contains a radioactive nuclear substance, as defined in section 2 of the NSCA, and which the owner has declared to be waste. In addition to containing nuclear substances, radioactive waste may also contain non-radioactive hazardous substances.

Under Canada’s national framework for radioactive waste management, waste owners are required to manage this waste safely and securely and to make arrangements for its long-term management.

NPP and WMF licences have a condition requiring the licensee to maintain a waste management program. The licensees’ waste management programs describe how all streams of wastes are managed throughout their entire lifecycle, from the point of their generation to their disposal. This includes waste generation, handling, processing, transporting, storage and disposal.

Waste characterization, waste minimization and waste management practices

NPPs and WMFs have “likely clean” programs that allow for the separation at the source of waste that is likely not radioactive, so as to minimize the generation of LLW at these facilities.

In comparison to the operations at NPPs, minimal radioactive waste is generated from the waste management activities conducted at the WMFs.

CNSC compliance verification activities for NPPs under this SCA may include field inspections. They also include the assessment of the safety performance indicator “low- and intermediate-level radioactive solid waste generated” (submitted per REGDOC-3.1.1).

Decommissioning plans

NPP and WMF licences have a condition requiring the licensee to maintain a decommissioning plan. The objective of decommissioning is to permanently retire a nuclear facility from service in a manner that ensures that the health, safety and security of workers, the public and the environment are protected. Decommissioning involves removing radioactive and other hazardous materials from the site, and restoring the site to an agreed-upon end-state.

Planning for decommissioning is an ongoing process, taking place throughout each stage of the facility’s lifecycle. In accordance with the Class I Nuclear Facilities Regulations, each licensee develops a preliminary decommissioning plan (PDP) for the facility lifecycle stages that precede decommissioning. The PDP provides the basis for the cost estimate and financial guarantee, which gives the assurance that funds will be available when the facility is ready to be decommissioned. A detailed decommissioning plan is developed prior to decommissioning in support of an application for a licence to do so.

The licensees are required to revise the PDPs and associated financial guarantees every five years or when requested by the Commission. For the NPPs, the proposed decommissioning strategies allow for an extended period of storage with surveillance after the end of normal operations. This period would take place under a CNSC licence and would last for three or four decades prior to the onset of active dismantling, allowing for radioactive decay and safe storage of dismantling equipment. The strategies for the WMFs, on the other hand, involve immediate decommissioning, with dismantling activities beginning once the waste is moved to a permanent repository.

2.12 Security

This SCA covers the programs licensees are required to implement in support of the requirements stipulated in the Nuclear Security Regulations, associated regulatory documents and orders, as well as the expectations for their facilities or activities.

The performance objective of this SCA is to prevent loss, theft or sabotage of nuclear material or sabotage of the licensed facility.

Security encompasses the following specific areas:

• facilities and equipment
• response arrangements
• security practices
• drills and exercises
• cyber security

In accordance with the General Nuclear Safety and Control Regulations, licensees are required to take all reasonable precautions to maintain the security of their facilities. NPP and WMF licences have a condition requiring the licensee to maintain a security program. CNSC compliance verification activities may include compliance assessments of licensees’ quarterly security reports (for NPPs, per REGDOC-3.1.1) and quarterly operations reports (for WMFs, per their LCHs).

Facilities and equipment

The Nuclear Security Regulations establish specific security-related requirements related to facilities and equipment associated with NPPs and Category I, II and III nuclear materials.

Response arrangements

The Nuclear Security Regulations establish requirements for on-site nuclear response forces and arrangements with off-site response forces.

Security practices

The Nuclear Security Regulations establish requirements for preventing and detecting intrusion and authorizing legitimate access to secure areas. NPP and WMF licensees have programs and procedures in place to control access to facilities, nuclear materials and prescribed information.

Drills and exercises

The Nuclear Security Regulations establish requirements for drills and exercises that involve on-site and off-site nuclear response forces. Licensees have exercise and drill programs to validate their security programs, ensure regulatory compliance and identify areas for improvement in security operations, including drills with the participation of offsite response.

Cyber security

NPP licensees maintain cyber security programs to protect cyber-essential assets from cyber-attacks. CNSC compliance verification activities for cyber security at NPPs may include Type II inspections.

2.13 Safeguards and non-proliferation

This SCA covers the programs and activities required for the successful implementation of Canada’s obligations arising from the Canada/IAEA safeguards agreements ^{Footnote 3} as well as other measures arising from the Treaty on the Non-Proliferation of Nuclear Weapons.

The performance objective of this SCA is to ensure that the licensee conforms to measures required to meet Canada’s international safeguards obligations through:

• timely provision of accurate reports and information
• provision of access and assistance to IAEA inspectors for verification activities
• submission of annual operational information and accurate design information on plant structures, processes and procedures
• development and satisfactory implementation of appropriate facility safeguards procedures
• demonstration of capability, as confirmed through CNSC onsite evaluations, to meet all requirements in support of physical inventory verifications of nuclear material by the IAEA

Safeguards and non-proliferation encompasses the following specific areas:

• nuclear material accountancy and control
• access and assistance to the IAEA
• operational and design information
• safeguards equipment, containment and surveillance
• import and export

In accordance with the General Nuclear Safety and Control Regulations, licensees are required to take all necessary measures to facilitate Canada’s compliance with any applicable safeguards agreement. Furthermore, NPP and WMF licences have a condition requiring the licensee to maintain a safeguards program. The scope of the non-proliferation program is limited to tracking and reporting of foreign obligations and origins of nuclear material.

CNSC compliance verification activities under this SCA may include CNSC field inspections, compliance field activities (typically during most scheduled IAEA inspections), and routine reviews of nuclear material accountancy, operational, and design information.

Nuclear material accountancy and control

As per their licensing bases, the NPP and WMF licensees are required to report the quantities of nuclear material present within defined areas, and changes in those quantities. This includes nuclear material measurement, record keeping, preparation and submission of accounting reports, and verification of accounting information.

CNSC compliance verification activities may include reviews of the timeliness and content of licensees’ nuclear material accountancy reports.

Access and assistance to the IAEA

As per their licensing bases, the NPP and WMF licensees are required to provide access and assistance to IAEA inspectors in order to enable the IAEA to verify Canada’s declarations to the IAEA.. IAEA activities include inspections and visits for the installation and maintenance of IAEA safeguards equipment. IAEA inspections, which include annual physical inventory verifications and short-notice and unannounced inspections, verify specific inventories or transfers of nuclear material. The IAEA also conducts verifications of the design information and occasionally performs complementary access visits. The purpose of these IAEA activities is to verify the nuclear material inventory and assure the absence of undeclared nuclear material and activities.

Operational and design information

As per their licensing bases, the NPP and WMF licensees are required to submit to the CNSC operational and design information, as well as necessary information pursuant to the additional protocol to the Canada-IAEA safeguards agreements, . CNSC staff review the information provided for its timeliness, correctness, and completeness.

Safeguards equipment, containment and surveillance

As per their licensing bases, the NPP and WMF licensees are required to install safeguards equipment at the licensed site or facilitate the IAEA’s installation of such equipment (such as IAEA cameras, seals and spent (used) fuel monitors) and to provide the services required for the operation of such equipment, in accordance with the specifications provided. CNSC staff assure that the support provided by the licensees meets the IAEA’s requirements.

Import and export

NPPs and WMFs require a licence, separate from the licensing of their operations, for the import and export of controlled nuclear substances, equipment and information identified in the Nuclear Non-proliferation Import and Export Control Regulations.

2.14 Packaging and transport

This SCA pertains to programs that cover the safe packaging and transport of nuclear substances to and from the licensed facility.

The performance objective of this SCA is to ensure that the packaging and transport of nuclear substances are conducted safely.

The packaging and transport SCA encompasses the following specific areas:

• package design and maintenance
• packaging and transport
• registration for use

Licensees have programs for compliance with the requirements of both the Packaging and Transport of Nuclear Substances Regulations, 2015 and the Transportation of Dangerous Goods Regulations for all shipments of nuclear substances to and from their facilities.

All licensees are required to have appropriate training for personnel involved in the handling and transport of dangerous goods and to issue a training certificate to those workers in accordance with the Transportation of Dangerous Goods Regulations. Nuclear substances originating from NPPs and WMFs must be transported in packages that meet regulatory requirements. In addition, all licensees who use a package of a certified design must register their use of the package with the CNSC.

While the Packaging and Transport of Nuclear Substance Regulations, 2015 do not apply to onsite transfers of packages, the NPP and WMF licensees ensure a level of safety equivalent to that required for offsite transportation to protect the health and safety of workers, the public and the environment.

NPP and WMF licences have a condition requiring the licensee to maintain a packaging and transport program.

CNSC compliance verification activities under this SCA may include field inspections.

2.15 Other matters of regulatory interest

Assessments of compliance and performance of NPPs and the WMFs regularly address other matters of regulatory interest, including licensees’ measures for public information and disclosure, Indigenous consultation and engagement and financial guarantees. Other areas, such as nuclear liability insurance and environmental assessment, may also be addressed.

Public information and disclosure

The availability and clarity of information pertaining to nuclear activities are essential to establishing an atmosphere of openness, transparency and trust between the licensee and the public. Licences for NPPs and WMFs contain a condition requiring the licensee to maintain a public information and disclosure program. The licensee is required to support the program by a robust disclosure protocol and addresses local communities and stakeholders’ needs.

Indigenous consultation and engagement

CNSC staff are committed to building long-term relationships with Indigenous groups who have interests in the regulation of nuclear facilities within their traditional and/or treaty territories. The CNSC’s Indigenous engagement practices, which include information sharing and funding support for Indigenous peoples to meaningfully participate in Commission proceedings and ongoing regulatory activities, are consistent with the principles of upholding the honour of the Crown and reconciliation with Indigenous communities. As part of upholding the Crown’s duty to consult Indigenous communities, the CNSC also confirms that its licensees engage those communities in a meaningful way.

Financial guarantees

As allowed in the NSCA, licences for NPPs and WMFs contain a condition requiring the licensee to maintain a financial guarantee for decommissioning that is acceptable to the Commission.

Appendix A: Responsibilities and details for nuclear emergency preparedness and response

Nuclear emergency response in Canada

In Canada, nuclear emergency response is a shared responsibility among all levels of government and the private sector. In accordance with IAEA guidance and requirements, Canadian nuclear emergency response responsibilities are subdivided into onsite and offsite nuclear emergency response.

Onsite nuclear emergency response pertains to all actions and measures taken within the boundary of the licensee site, whereas offsite nuclear emergency response pertains to actions and measures taken outside and beyond the boundary of the licensee site. These two areas of response require specific roles and responsibilities from different stakeholders; yet, closely related as they are, they also require coordination between all levels of government and the CNSC licensee. For example:

• CNSC licensees are responsible for onsite nuclear emergency response and emergencies that may occur offsite.
• Provincial governments are responsible for offsite nuclear emergency response.
• If requested by the provincial government, the federal government may provide support to the province.

All levels of government and the CNSC have nuclear emergency response plans in place, including operational facilities equipped and staffed for coordinating and directing their responses to a nuclear emergency. In addition, all CNSC licensees have emergency response plans and/or measures in place to effectively respond in the event of an emergency. The CNSC maintains regulatory oversight of the nuclear emergency response carried out by the licensee.

Licensees

In Canada, the CNSC licensees are the onsite authorities responsible for the management and implementation of onsite emergency response, in accordance with their CNSC-approved emergency response plans and procedures. This means that the licensees are directly responsible for:

• identifying and assessing the safety significance of the emergency
• controlling and mitigating the emergency
• notifying and coordinating with the offsite authorities and the CNSC
• notifying the CNSC in accordance with applicable regulations and licence conditions
• providing recommendations regarding offsite protective actions
• informing the public about onsite actions and conditions (such as reactor status)

The licensees’ communications and alert strategies include sirens (in the immediate vicinity of NPPs), automated phone dialing systems, vehicle-mounted mobile public address systems, media messages (radio/television), website information, email alerts and, in some areas, door-to-door notification.

Provincial, territorial or municipal governments

For emergencies that have an offsite impact, the provincial, territorial or municipal government is the appropriate responsible authority for offsite actions.

Provincial and territorial governments have the primary responsibility for protecting public health and safety, property, and the environment within their borders. They are also the primary authorities for informing the public about protective actions and offsite conditions.

The provinces determine the needs for, and direct the implementation of, protective actions, which can include:

• sheltering
• evacuation
• ingestion of KI (potassium iodide) pills
• ingestion control measures

The provinces also ensure, in coordination with municipalities, that arrangements are in place for:

• facilitating the availability of KI pills
• establishing reception and evacuation centres to accommodate evacuees
• establishing emergency worker centres to ensure radiation protection for emergency workers

The provinces have mechanisms to ensure communications and coordinated responses between stakeholders during emergencies. The following describes the arrangements in place for Ontario.

The Provincial Emergency Operations Centre (PEOC) is responsible for disseminating information to its members and to the emergency management stakeholders. The PEOC is also responsible for providing information to ministries and communities indirectly involved in the emergency response regarding the province’s response to the emergency.

Figure 1 describes the various information products that the PEOC develops and disseminates to relevant emergency organizations, depending on the situation. (Note that ERO stands for emergency response organization.)

Figure 1: PEOC information products

Federal government

Under the Emergency Management Act, the Minister of Public Safety is responsible for coordinating the Government of Canada’s (GC) response to an emergency. The Federal Emergency Response Plan (FERP) is the GC’s “all-hazards” response plan. The Federal Nuclear Emergency Plan (FNEP) is an annex to the FERP, providing the supplemental and specific multi-departmental and inter-jurisdictional arrangements necessary to address the health risks associated with a radiological or nuclear emergency.

During an integrated GC response to a nuclear emergency under the FERP/FNEP, all levels of government and various agencies and organizations have the responsibility to develop and implement emergency response plans to deal with the consequences and impacts outside the boundaries of the nuclear facility licensed by the CNSC. The licensee is responsible for the response inside the boundaries of its facility.

An integrated GC response is required when:

• a province/territory requests federal support to deal with an emergency
• an emergency affects multiple jurisdictions and/or government institutions, and requires a coordinated response
• an emergency directly involves federal assets, services, employees, statutory authority or responsibilities, or affects confidence in government
• an emergency affects other aspects of the national interest

Global Affairs Canada is also responsible for liaisons with the international community and their diplomatic missions in Canada, for assisting Canadians abroad, and for coordinating the national response to nuclear emergencies that occur in foreign countries but have an impact on Canada.

CNSC

For nuclear emergencies involving licensed facilities and substances, the CNSC:

• performs regulatory oversight of the licensee’s activities (monitoring, evaluation of protective action recommendations, advice, assistance, and, when appropriate, direction in the form of directives and orders)
• performs an independent assessment of the onsite conditions and potential offsite consequences, to provide or confirm the licensee’s recommendations concerning any protective measures that may be needed
• participates, as a federal agency, in the whole-of-government response to a nuclear emergency, in accordance with the requirements of both the FERP and the FNEP

For nuclear emergencies not involving licensed substances, the CNSC plays a supporting role to the response under the FERP/FNEP. This includes (but is not limited to) providing technical assistance and support to the lead organization, in accordance with the CNSC’s authorities and responsibilities.

CNSC inspectors, including emergency preparedness inspectors, perform inspections routinely to confirm that the licensees’ emergency preparedness programs are always fully implemented and functional.