What We Heard Report – DIS-21-01
DIS-21-01, The Canadian Nuclear Safety Commission: Regulatory Oversight Report Review
Discussion papers play an important role in the selection and development of the regulatory framework and regulatory program of the Canadian Nuclear Safety Commission (CNSC). They are used to solicit early public feedback on CNSC policies or approaches.
The use of discussion papers early in the regulatory process underlines the CNSC’s commitment to a transparent consultation process. The CNSC analyzes and considers preliminary feedback when determining the type and nature of requirements and guidance to issue.
As Canada’s nuclear regulator, the CNSC regulates the use of nuclear energy and materials to protect health, safety, security and the environment; to implement Canada's international commitments on the peaceful use of nuclear energy; and to disseminate objective scientific, technical and regulatory information to the public.
In 2015, CNSC staff developed regulatory oversight reports (RORs), which have since been used as the primary reporting tool to present the results of the CNSC’s compliance activities and assessments of licensees’ safety performance. RORs are completed for all regulated activities and for most facilities. They are presented to the Commission annually through public Commission meetings (with the exception of the RORs for historic mines and decommissioned sites and for nuclear research reactors and particle accelerator facilities, which are presented to the Commission every 3 years).
The scope of the RORs has expanded over the years to incorporate feedback from the Commission, Indigenous Nations and communities, the public, and interested parties, with the result being more complex and comprehensive reports.
In January 2018, staff established a cross-functional team to conduct a review that initially focused on the reporting frequency of RORs to the Commission. This was the CNSC’s first ROR process review since the inception of the reports in 2015. The objective was to examine current practices, review value for effort, identify potential efficiencies for future reporting of RORs to the Commission, and review and address comments from intervenors and the Commission. In addition, staff wanted to ensure that RORs continued to serve their purpose for their target audience, which is the Commission itself.
Subsequently, a public discussion paper was developed based on key themes identified by CNSC staff. The goal of the discussion paper was to seek feedback on the RORs and the ROR process from the Commission, Indigenous Nations and communities, the public and interested parties.
The CNSC posted DIS-21-01 for public comment from April 8 to June 7, 2021. Indigenous Nations and communities and interested parties were informed of the posting through various mechanisms, including announcements in the “Latest News” and “What’s New” sections of the CNSC website, and were invited to comment. A message was also sent to the CNSC’s email subscription list, alerting recipients that DIS-21-01 had been posted. The 98 comments received were posted on the CNSC website from June 8 to 23, 2021, for further comment. No further comments were received during that period.
Summary of comments received
The CNSC received feedback on DIS-21-01 from the following:
- Canadian Radiation Protection Association (CRPA)
- Canadian Nuclear Association (CNA)
- Bruce Power
- New Brunswick Power (NB Power)
- Ontario Power Generation (OPG)
- Nordion Inc.
- Canadian Nuclear Laboratories (CNL)
- Hydro Québec
- Canadian Nuclear Workers' Council (CNWC)
- G. Dalzell, Citizens Coalition for Clean Air (CCCA)
- Canadian Environmental Law Association (CELA)
Indigenous Nations and communities
- Manitoba Métis Federation (MMF)
- Kevin Scissons
- Anne Gent
The comments received were constructive. The following summarizes the comments in support of the current ROR process:
- RORs provide a good overview of the performance of licensees with enough detail to make the reports useful.
- Industry appreciates the recent efforts that CNSC staff have made to streamline the reports and make them more reader-friendly and accessible to members of the public.
- The frequency of RORs is appropriate:
- High-risk events or issues can be reported more quickly using Commission member documents, event initial reports, and other tools such as the CNSC website, Open Government, engagement activities, webinars and the Let’s Talk Nuclear Safety website.
The following summarizes the comments suggesting areas for improvement:
- RORs are time-consuming to produce and should be written clearly and concisely.
- It takes too long to produce RORs and they are not sufficiently clear or concise.
- Additional outreach would help the public better understand technical aspects of RORs.
- The annual RORs could be enhanced with the addition of dashboards.
In response to all comments received, CNSC staff implemented the following changes to RORs in 2022:
- introduced plain-language executive summaries
- made greater use of hyperlinks for readily available online content
- ensured data included error bars on graphs, an explanation on sampling and analytical techniques, and the sources of equations
- clarified the rating definitions and removed the “fully satisfactory” rating
- ensured greater acknowledgement and inclusion of Indigenous Nations and communities and their traditional and/or treaty territories
A questionnaire was sent to Commission members, with comments received in September 2022. In summary, the recommended areas for improvement included:
- increase the use of hyperlinks and references to publicly available documents
- increase the use of dashboards where applicable
- provide additional information on outliers (ratings, emissions doses, etc.)
- provide more information on what other reporting /engagement mechanisms are available
Overall, the Commission indicated that the frequency of the RORs is sufficient and that they are clearly written, comprehensive and data-rich.
The Commission directed the CNSC’s Commission Registry to seek comments/input from the members of the CNSC’s Environmental Non-Governmental Organizations (ENGO) Forum for additional potential improvements to the RORs and the process; no comments were received.
A cross-functional internal CNSC ROR Working Group has been established to meet the following objectives:
- streamline the information provided in the RORs
- identify and enhance existing communication tools and other mechanisms to improve and facilitate outreach and engagement with Indigenous Nations and communities, the public and interested parties
The CNSC remains committed to ongoing engagement and open communication with all interested parties and encourages participation in Commission proceedings by way of interventions when applicable.
Canadian Nuclear Safety Commission
280 Slater St
PO Box 1046 Stn B
Ottawa ON K1P 5S9
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