FAQ Canadian Nuclear Safety Commission

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Note: this page began with questions that were asked of the Canadian Nuclear Safety Commission (CNSC) during a “CNSC 101 Information Session for Stakeholders” which was held on June 23, 2011 at the Hilton Convention Centre in St. John, New Brunswick. They were sent to the CNSC Directorate of Nuclear Cycle and Facilities Regulation in July, 2011. CNSC responded to some of these and other questions on November 9, 2011. Please see FAQ answers from CNSC 101 info session June 23 2011 Saint John NB http://nb.referata.com/wiki/FAQ_answers_from_CNSC_101_info_session_June_23_2011_Saint_John_NB to review their responses... or perhaps you'd like to provide comment for the public.

We encourage you to participate in a transparent, public editing process of the questions and responses by CNSC staff

    • User questions about the Canadian Nuclear Safety Commission are indicated by triple asterisk*** (deeply indented text)


Questions to Canadian Nuclear Safety Commission (CNSC) June, 2011[edit]

Notes from “CNSC 101 Information Session for Stakeholders” - 23 June 2011, Hilton Convention Centre, St. John, NB


Questions/Comments/Requests/Responses that were put forward at the information session.


      • 1. Will CNSC please provide copies of its MOUs with: Health Canada; Public Safety Canada/Federal Nuclear Emergency Management Plan; Community of Federal Regulators; Joint Regulatory Group (especially including agreement(s) with the Province of New Brunswick WorkSafe NB and NB Emergency Management departments).


Response: will provide.


      • 2. Will CNSC please provide copies of its 2008-2011 reports to the Treasury Board of Canada?


Response: will provide.


      • 3. Will CNSC please provide names and contact information for their “Office of Audit” and audit reports for 2008-2011?


Response: will provide.


      • 4. Regarding S-21 of the Nuclear Safety and Control Act (NCSA), will the Canadian Nuclear Safety Commission (CNSC) please confirm the process for petitioning for revocation of a nuclear operator licence?


Response: will provide.


      • 5. Are CNSC staff being placed in conflict of interest if they act to protect proprietary and/or commercial interests and/or information above public health and safety, in the fulfillment of their duties on behalf of the Commission? [ref. S-21(f) NSCA 2002]


Response: will consult with CNSC legal staff and provide a response.


      • 6. Will CNSC please provide a list of names and contact information for CNSC “specialized” and technical staff i.e. Nuclear, Physics, Mathematics, Environmental Sciences, Biology, Epidemiology, Chemistry, Computer, Aboriginal people?


Response: will provide


      • 7. Does CNSC operate in accordance with the medically accepted fact that there is no safe level of exposure to ionizing radiation caused by human activity?


Response: will consult with CNSC policy and report back to the group.


      • 8. Will the CNSC provide raw data from its radiation detection and exposure monitoring for humans, marine life, water/plant life and soil for 2006-2011?


Response: will provide raw data.


      • 9. How is medical oversight provided for CNSC's Radiation Protection program?


Response: Will respond with related CNSC reports.


      • 10. What are the containment standards for nuclear fuels and waste? What are the containment requirements for transport of nuclear materials?


Response: This information is contained in the regulations. CNSC staff will provide digital and/or hard copies of the NCSA Regulations.


      • 11. Can copies of nuclear emergency preparedness documentation be retrieved for interested members of the public?


Response: CNSC staff can provide digital and/or hard copies of documents related to nuclear emergencies. [ref.: Federal Nuclear Emergency Management Plan, agreements for Nuclear Emergency Management Plan with Canadian provinces and border states.]


      • 12. What is the definition of “abridged” public hearing?


Response: will consult with CNSC legal staff and provide a response.


      • 13. How can people without broadband, internet or online access and/or with educational and literacy barriers access CNSC public information and departments?


Response: (Sandra) Please provide an outline of what will be required to inform these citizens and CNSC will try to provide.


      • 14. Under CNSC requirements, how is the licensee responsible and liable for its contractors, i.e. AECL?


Response: will provide details of licensee responsibilities for external contractors, labour, etc.


      • 15. How does CNSC apply the principle of precaution in protecting public health and safety?


Response: Will provide CNSC policy on precaution.


      • 16. Are Health Physicists the singular staff responsible for monitoring radioactively-exposed nuclear power employees?


Response: Yes.


      • 17. Regarding Point Lepreau and CNSC duty to consult with Aboriginal people and according to CNSC information, neither Passamaquoddy, Union of New Brunswick Indians nor Wulustukyieg Traditional Council have ever received clear information about nuclear operations in the province. Passamaquoddy have publicly denied approval for Lepreau reload and restart and have asked that the facility be removed from their ancestral territory. What is CNSC's intended course of action when/if consultation requirements have not been met by CNSC and/or licensees?


Response: will provide a statement regarding CNSC attempts to fulfill this requirement. CNSC provides specific funding for Aboriginal participation.


      • 18. Who is responsible for cleanup of “legacy” sites? How may these offices be contacted by the public.


Response: The CNSC “Low Level Office” is responsible for cleanup of historically contaminated (pre-legislation) sites. Responsibility for monitoring and reporting of several “legacy sites in Canada have become community and/or municipal responsibility i.e. abandoned sites containing uranium tailings, mines, etc. Such as Uranium City and others in Saskatchewan, radioactive contamination in Port Hope.

Staff will provide information about these offices.


      • 19. What is the contact information for site inspectors/Duty Officers for reporting problems at Point Lepreau?


Response: will provide information about NB site inspectors.


      • 20. Can CNSC provide reports on their participation/interactions with New Brunswick for the 2002 Energy and Utility Board (EUB, now known as Public Utilities Board [PUB]) where the EUB recommended against the refurbishment of the Point Lepreau station.


Response: will provide historic documents regarding CNSC communications and/or interventions with EUB.


      • 21. When will the next public hearings on Point Lepreau take place?


Response: a public hearing on application for reloading fuel into the reactor will take place on October 4th 2011 in Ottawa. Public hearings on application to re-licence Lepreau for for 5 yrs. as well hearings for reload and restart will take place concurrently on November 30th in Ottawa and on December 1st 2011 in St. John.


      • 22. What is the publicly available nuclear emergency information for New Brunswickers and Canadians? Has this information been updated or modified in light of the nuclear disaster at Fukushima?


Response: New Brunswick (provinces) Emergency Measures department is/are responsible for providing nuclear emergency information to the public. CNSC consults with these departments.


      • 23. We understand that a policy is in place where iodine tablets are provided to residents within a 12 mile radius of Point Lepreau. What is the new plan?


Response: New Brunswick (provinces) Emergency Measures department is/are responsible for providing nuclear emergency planning for the public. CNSC consults with these departments.


      • 24. New Brunswick citizens have been distributing an aerial map of at-risk areas surrounding Point Lepreau with a 200 mile fallout radius in the event of emergency. What portion of surrounding areas does CNSC consider at risk in the event of a nuclear accident at Lepreau?


Response: CNSC staff expressed surprise at public concern for affected areas in a 200 mile radius of the station.


      • 25. We understand that CANDU licensees were recently required to re-assess risks from seismic activity, flooding, tsunami and fire hazards. What has been reported on compliance with these new requirements?


Response: Reports on these risks are due from licensees on June 30th and again in August 2011


      • 26. We are aware of media coverage and technical reports from seismological experts, including Dr. Ferahion and NB geologist Dr. Mark Connell regarding historical knowledge and concern related to active earthquake formations under the region where Point Lepreau is sited. AECB (CNSC) is publicly reported to have participated in meetings where these concerns were expressed during and after planning for the construction of Point Lepreau took place. Will the CNSC provide their reports on this issue?


Response: will provide historical reports.


      • 27. CNSC reported at least 16 deficiencies for CANDU reactors, including Point Lepreau, regarding compliance in its recent Integrated Safety Reports (ISR). Will CNSC provide historic, detailed information on Point Lepreau compliance and outstanding deficiencies with the ISR items?


Response: will provide a report on compliance related to the ISR.


      • 28. Will CNSC provide digital and/or hard copies of the CNSC 101 and CNSC 101-Fukushima slide presentations for participants for further study?


Response: will provide copies upon request.


      • 29. Regarding “Beyond Design Basis Accidents”, we understand that many reactor components are tested to destruction prior to their use in reactors produced in Canada. Will CNSC provide information on reports about and related to “Beyond Design Basis Accidents” along with any critiques that it has received about these tests?


Response: will provide CNSC information on “Beyond Design Basis Accidents”. No critiques of these tests are available.


      • 30. Will CNSC provide reports on its compliance orders and enforcement activities as provided to the Canadian government and international bodies under the Nuclear Non-Proliferation Treaty (NPT)?


Response: will provide publicly available information. Items related to national security may not be publicly available.


      • 31. The Nuclear Waste Management Organization (NWMO) has publicly stated that waste from nuclear installations will remain inherently radioactive indefinitely; it will therefore be chemically toxic forever. What are CNSC requirements for long term containment of radioactive waste from the biosphere?


Response: will respond.


      • 32. The CNSC-101 presenter described NWMO as a government organization. However, it is our understanding that NWMO is actually an industry association with an undetermined relationship to the federal government. Will CNSC please clarify the role of the NWMO in relation to CNSC?


Response: will consult with CNSC legal staff and provide a response.


      • 33. CNSC appears to be in an apparent conflict by divesting responsibility for nuclear workers to the provinces, who then assign responsibility to the licensee. What is CNSC's responsibility for protecting the health and safety of nuclear power workers?


Response: will contact legal staff and provide response.


      • 34. In our discussion about the NCSA and the regulations, it was stated that the licensee is responsible for compliance with provincial labour standards. What is the CNSC process for ensuring that licensees meet their obligations for protecting worker health and safety?


Response: will provide relevant CNSC policy.


      • 35. We understand that software control systems are an identified safety issue. How does CNSC monitor and review operational logs for maintenance, testing and event reporting?


Response: will contact technical staff and provide response.


      • 36. We understand that there have been serious concerns related to CANDU simulation software, particularly for life extension projects. What is the policy for software testing and reporting for Canadian reactors? How is a CANDU simulated to verify that the software can respond to known and new conditions?


Response: will contact technical staff and provide response.


      • 37. We understand that personnel qualified as health physicists collect radiation dose data at licensed facilities without the involvement of medical doctors. How does CNSC obtain medical opinion about exposed workers?


Response: will contact specialized staff and provide response.


      • 38. How, given the information that the licensee is responsible for radiation protection for workers, contractors and subcontractors, does the CNSC ensure that it has fulfilled its mission to protect public health, safety, security and the environment? For example, does CNSC forensically audit a random set of licensee claims of compliance? What do CNSC consider to be significant detriments to the health and safety of workers, the general public or future generations?


Response: will contact policy staff and provide response.


      • 39. We understand that CNSC includes health information with its environment reporting. However, health and environment are listed separately in the CNSC mission statement. Where can members of the public access reports on the impact of nuclear operations on the health of Canadians?


Response: will contact specialized staff and provide response.


      • 40. Given that environmental protection is under both federal and provincial jurisdiction, how are responsibilities shared?


Response: will contact specialized staff and provide response.


      • 41. Which closed plants are listed on CNSC's “Nuclear Statistics” slide presented at the CNSC 101 information session?


Response: will contact reporting staff and provide response.


      • 42. We understand that under the Nuclear Liability Act, licensees are covered under no-fault insurance. What are CNSC requirements for licensee insurance coverage? Under what set of conditions is compliance with insurance requirements recognized?


Response: will contact policy staff and provide response.


      • 43. Please provide CNSC reports submitted to IAEA member states for the Integrated Regulatory Review Service.


Response: will provide.


      • 44. Please provide the CNSC cost-benefit analysis on the cost effectiveness of nuclear power as compared to a) active conservation; b) passive conservation; c) other energy sources, as discussed.


Response: will provide.


      • 45. What is the CNSC definition of “naturally occurring substances?” Which “naturally occurring substances” are exempted under the NSCA?


Response: will contact specialized staff and provide response.


      • 46. What are the skill requirements and job descriptions for Radiation Protection Officers?


Response: will provide response.


      • 47. Regarding staff evaluations, please provide performance reviews for CNSC senior and specialized staff.


Response: will provide.


      • 48. Please provide “Q-850 Risk Management Guidelines for Decision Makers – Fulfilling the Mandate,” as discussed. We understand that these guidelines are used to support decision making and establish levels of oversight and control.


Response: will provide.


      • 49. We have concerns about the safety of CANDU life extension projects. How often are site inspections scheduled for piping systems for reactors and nuclear waste management systems??


Response: will provide.


      • 50. We understand that the steam generators at Point Lepreau need to be replaced under the CNSC-approved refurbishment plan. Will the old generators be stored on site? Will there be a separate hearing for the installation of the steam generators?


Response: will contact specialized staff and provide response.


      • 51. Regarding the sale of AECL, what escrow provisions does CNSC require to ensure that the ability of licensees to comply with license conditions is maintained? For example, does CNSC require escrow provisions for event logs, monitoring data and software source code?


Response: will contact legal staff and provide response.


      • 52. What exceptional circumstances in Canada would justify the CNSC in exempting nuclear plant operators from submitting in time Safety Analysis Reports for consideration of applications for licensing and license extension applications?


      • 53. Given that CNDU reactor refurbishments would impose the risk of a nuclear accident over a period potentially as long as 30 years on the public, wouldn’t CNSC be acting diametrically against the spirit and intent of the Nuclear Safety and Control Act of 1997 by granting nuclear power plant operators permission to go ahead with life extension projects without having wholly satisfactory Safety Analysis Reports?


      • 54. CNSC’s abundant archived documentation shows that CNSC staff has been working closely with nuclear power plant operators on refurbishment plans. Why doesn’t the CNSC openly divulge problems that have prevented operators from delivering Safety Analysis Reports in time for licensing hearing to the public?


      • 55. In light of the nuclear disasters at Fukushima Japan, isn’t there an unreasonable risk imposed on the public by encouraging nuclear power plant operators to proceed with refurbishments without knowing design modifications that will be required for the refurbishment and that will presumably be described in the Safety Analysis Report ?


      • 56. Why is it that the numerous safety issues that plague CANDU reactors were reason enough for the CNSC to reject OPG’s safety report in April 2008, whereas essentially the same safety issues were simply ignored by the CNSC by having recourse to Article 7 in their June 2011 decision regarding the Point lepreau and Gentilly-2 refurbishments?


      • 57. Is there not an unknown and possibly unreasonable risk imposed on the public by the CNSC granting permission for refurbishment without having received and thoroughly analyzed the Safety Analysis Reports for Point Lepreau and Gentilly-2?


      • 58. What were the safety issues that OPG nuclear engineers had the most difficulties with, regarding Pickering B refurbishment, and what evidence does the CNSC have that NB Power and Hydro-Québec will be able to resolve these safety issues in refurbishing Point Lepreau and Gentilly-2?


      • 59. Nuclear secrecy only increases public distrust. Given that CNSC possesses considerable knowledge concerning the many safety issues plaguing CANDU reactors, what prevents you from disclosing them fully to the public?


      • 60. Considerable controversy exists regarding seismic risk, flawed cooling system and fuel supply design and the Point Lepreau and Gentilly 2 insallations. What data are available to the CNSC on the resistance of eroded high pressure tubes in nuclear reactors? What is the probability that a 6-Richter scale earthquake could cause such tubes to rupture?


      • 61. Using modern CANDU physics models and simulation software, has CNSC staff analyzed the reasons for the failure of Gentilly-1 and applied the lessons learned to the modifications that should now be incorporated into CANDU life extension projects (refurbishments) in order to meet the best international safety standards? What are the lessons that have been learned from the failure of Gentilly-1?


      • 62. Specifically, what changes have been made or will be made to protect the reactor and the reactor building at Pt.Lepreau against the possibility of terrorist attacks, thefts of radioactive or fissionable materials, or direct strikes by aircraft? In the opinion of the CNSC, could the reactor building survive a direct aircraft strike without endangering the public?


      • 63. We understand that the Nuclear Waste Management Organization (NWMO), a quasi-governmental organization controlled by NB Power, Hydro-Quebec and Ontario Power Generation, is on the hunt for a “willing” community where nuclear waste can be stored, presumably underground, for the scores of generations—longer than human history—that it will be necessary to isolate this waste from the environment, from water intrusion, and from human and animal contact. Is CNSC overseeing and regulating this NWMO hunt and site selection process to assure that it complies with applicable law and regulations and that the public will be fully informed about any discussions about or decisions to store this waste?


      • 64. And since the NWMO is focusing its search for waste sites in just two provinces--New Brunswick and Ontario--does CNSC have knowledge of any preliminary or advanced explorations of or negotiations for possible sites for this NWMO waste storage project that have taken place or are taking place in the province of New Brunswick?


      • 65. We understand that CNSC has known for about a decade that at Pt. Lepreau certain pipes or lines that transmit steam are routed directly over the plant’s control room, and that in the event of a rupture of one or more of these lines everyone in the control room would be killed immediately. We also understand that CNSC has not ordered the rerouting of these lines as part of the Lepreau refurbishment project. Please comment on this and tell us whether CNSC will require that these lines be relocated before granting Pt. Lepreau a license to restart.


      • 66. Why are Pt. Lepreau’s steam generators not being replaced as part of the refurbishment process? Because of their age and likely deterioration, isn’t their replacement necessary for Pt. Lepreau to be considered safe by post-Fukushima safety standards prior to its restart?


      • 67. With regard to Pt. Lepreau’s steam generators, we have an important request. Will you please provide us as soon as possible with all correspondence between or among your agency, NB Power, AECL and any other contractors, along with any other documents and information you may have regarding the steam generators? When can we expect to receive copies of these documents and of this correspondence?


      • 68. As you are aware, many of the problems at Fukushima involved the reactors themselves, but other critical problems involved the used fuel pools and used fuel storage areas. Since used uranium fuel when taken from CANDU reactors is highly radioactive and unstable, it requires reliable cooling that cannot be interrupted for a long period of time. Also, used fuel taken from the cooling pools remains dangerously radioactive for hundreds to thousands of years. Given these facts and the recent tragedy at Fukushima, please tell us what changes you have made to assure that the used fuel pool and the used fuel storage sheds at Pt. Lepreau will not in the event of a serious accident or deliberate attack release dangerous radioactivity into the environment of our region?


      • 69. Are you or will you be requiring that the rudimentary, unshielded used fuel storage sheds at Pt. Lepreau be replaced or fortified with appropriate cladding and be structurally strengthened to withstand earthquakes and aircraft strikes? (By the way, we are using the term used fuel rather than spent fuel because we think calling used fuel “spent” is misleading, and we think you should stop using this term. The radioactivity in used fuel is anything but “spent”. As you know, used reactor fuel is far more radioactive than unused fuel bundles, so calling it “spent” is extremely—and in our opinion deliberately—misleading.)


      • 70. We understand that NB Power has invested heavily in uranium and if our understanding is correct, NB Power is the owner of a considerable stockpile of uranium. Please tell us how you oversee and regulate NB Power’s uranium holdings. How much uranium does NB Power own? In general terms, where is it stored or located? Is it processed in whole or partly in New Brunswick, or is it imported as ready-to-use fuel bundles?


      • 71. Releases of tritium (radioactive hydrogen) to the air and water are routine whenever Lepreau is operating. Tritium is a dangerous radioactive element and a known carcinogen. Because the Bay of Fundy is not a source of drinking water, you allow much more tritium to be released at Pt. Lepreau than you allow for nuclear reactors in Ontario. Tritium decays fairly rapidly, but as it does it adds an additional element of stress to an already stressed Bay of Fundy marine environment. Will you require Pt. Lepreau to reduce its tritium releases before it is given the go-ahead to restart?


      • 72. We understand that under applicable law and policies consultation with affected First Nations about nuclear power and its effects is required. We also understand that CNSC may be planning to consult with the Passamaquoddy First Nation about the future of Pt. Lepreau. Will CNSC assure that the Passamaquoddy, the Maliseet, and other First Nations whose territory and traditional rights are affected by the Pt. Lepreau reactor, its used fuel storage sheds and other related infrastructure, will play a meaningful and decisive role in determining the future of the Pt. Lepreau reactor site and of the traditional First Nations territory impacted by the reactor and its infrastructure?


~Nbreferata July 2011