Order by an inspector under subsection 35(1) of the nuclear safety and control act
Date of Order: October 26, 2023
2121 – 11th Street West
Corporate Number 332981-0
Shawn Harriman, General Manager Rabbit Lake Operation
WHEREAS Cameco Corporation, hereinafter referred to as “the licensee”, holds Canadian Nuclear Safety Commission (CNSC) licence number UML-MINEMILL-RABBIT.01/2023 issued pursuant to the Nuclear Safety and Control Act (NSCA) which authorizes the licensee to:
- prepare a site for, construct, operate, modify and decommission a nuclear facility (hereinafter “the facility”) for the mining of uranium ore and the production of uranium concentrate at a site known as the Rabbit Lake Operation in the Province of Saskatchewan as shown on the drawing referenced at Appendix A to this licence.
- mine a nuclear substance (uranium ore);
- produce a uranium concentrate;
- possess, transfer, import, use, store, and dispose of nuclear substances; and
- possess, transfer, import and use prescribed equipment that is required for or associated with laboratory studies, field studies, fixed gauge usage and borehole logging devices in relation to (a), (b) and (c).
AND WHEREAS pursuant to licence condition 10.1, the licensee is required to implement and maintain an emergency preparedness program at the Rabbit Lake Operation. The Rabbit Lake Operation Emergency Preparedness and Response Program (LIC-008) was considered to be adequate for the purposes protecting the health and safety of persons by the Commission at paragraph 127 of the Record of Decision DEC 23-H7.
AND WHEREAS Section 3.5.2 of the Rabbit Lake Operation Emergency Preparedness and Response Program (LIC-008) states that: “A comprehensive supply of safety and personal protective equipment (PPE) is maintained at site. In addition, specialized PPE, equipment and medical supplies are maintained on site for use by the ERT, MRT and medical staff during an emergency. These materials are inventoried and inspected on a routine basis by the appropriate personnel to ensure that all equipment is maintained in an appropriate state of readiness.”
AND WHEREAS for the period of October 24, 2023 to October 26, 2023, CNSC staff conducted an emergency management focused compliance inspection of the Rabbit Lake Operation, including an evaluation of the readiness of emergency response equipment, such as the Personal Protective Equipment (PPE) used by Emergency Response Team (ERT) members.
AND WHEREAS on October 25, 2023, Rabbit Lake Operation staff informed the inspectors that Cameco was in the process of replacing expired ERT PPE.
AND WHEREAS on October 25, 2023, CNSC inspectors checked the expiry dates for select ERT PPE, including coats and helmets, and found that most equipment had exceeded their expiry dates.
AND WHEREAS on October 25, 2023, Rabbit Lake Operation staff informed CNSC inspectors that Cameco was aware of the expired ERT PPE for at least one year prior to the inspection.
AND WHEREAS on October 25, 2023, CNSC inspectors verbally informed Cameco that the expired ERT PPE represented an impairment of safety-critical equipment and that Cameco was not in a state of readiness and therefore immediate remedial action was required.
AND WHEREAS on October 26, 2023, inspectors reviewed the results from a November 2020 Cameco Integrated SHEQ Corporate Audit (CAM-RLO-20-011) in which it was identified that ERT hart hats/helmets had exceeded their expiry dates.
AND WHEREAS, this evidence demonstrates a non-compliance of the licensee with the in-force emergency preparedness and response program and a failure of the licensee to meet its obligation to take all reasonable precautions to protect the health and safety of persons, and the environment, pursuant to paragraph 12(1)(c) of the General Nuclear Safety and Control Regulations (GNSCR) made under the NSCA.
AND WHEREAS, I am an inspector authorized by the Canadian Nuclear Safety Commission under subsection 35(1) of the NSCA to make any order considered necessary to protect the environment or the health or safety of persons or to maintain national security or compliance with international obligations to which Canada has agreed.
THEREFORE, in accordance with subsection 35(1) of the NSCA, I order Cameco Corporation to:
- Immediately suspend non-essential activities conducted at the Rabbit Lake Operation that may pose increased fire hazard risk, including, but not limited to welding or use of open flame devices.
- By October 27, 2023, provide the CNSC with a plan to obtain sufficient non-expired ERT PPE to ensure the emergency response personnel can respond to fires or other emergency events, including the timeline to obtain all necessary equipment.
- By October 27, 2023, provide the CNSC with documentation describing Cameco’s current ERT capabilities with respect to responding to emergencies at the Rabbit Lake Operation, given the state of the ERT PPE which cannot be safely used.
- By November 10, 2023, provide the CNSC with a plan and schedule for the replacement of all remaining expired ERT PPE at the Rabbit Lake Operation for CNSC review and acceptance.
- By November 30, 2023, conduct an investigation into why the impaired state of readiness for the ERT PPE was not reported to the CNSC, and inform the CNSC of the results of said investigation.
- By November 30, 2023 provide the CNSC with the corrective actions and preventative measures which will be implemented to ensure the Rabbit Lake Operation ERT PPE is inspected regularly for equipment expiry and equipment is replaced, prior to its expiry.
The licensee must comply with the requirement of subsection 29(2) of the GNSCR and submit a full report to the Commission within 21 days of having after becoming aware of this non-compliance.
This order will remain in effect until all of the information required by this Order has been provided, actions required by this Order have been completed and that I am satisfied that Cameco Corporation can operate in accordance and in compliance with the licence issued by the CNSC, and in doing so, has made adequate provision for the health and safety of persons, protection of the environment and maintenance of national security.
Inspector and Senior Project Officer
Uranium Mines and Mills Division
Canadian Nuclear Safety Commission
Dated at Rabbit Lake Operation, Saskatchewan, Canada this 26th day of October 2023.
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