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Paladin Canada Inc. - Canadian Nuclear Safety Commission Staff Protocol for the Patterson Lake South Application for CNSC Licence to Prepare Site for and Construct a Uranium Mine and Mill

Preface

The Paladin Canada Inc. - Canadian Nuclear Safety Commission Staff Protocol for the Patterson Lake South Application for CNSC Licence to Prepare Site for and Construct a Uranium Mine and Mill (Protocol) is strictly administrative in nature. None of the statements in this Protocol are to be construed or interpreted as constituting a contract, or as affecting the jurisdiction or discretionary powers of the Canadian Nuclear Safety Commission (CNSC) in its assessments of licence applications made in accordance with the Nuclear Safety and Control Act (NSCA).

Nothing in this Protocol fetters the powers, duties, or discretion of CNSC staff or the Commission respecting regulatory decisions or taking regulatory action. Also, this Protocol does not change in any way any applicable laws or regulations, application requirements or hearing process as set by the CNSC Rules of ProcedureFootnote 1.

The timelines outlined in this Protocol provide a transparent and reasonable outline of what may be expected from a regulatory perspective, but do not, and cannot, bind CNSC staff or Paladin Canada Inc. (Paladin) in any legally enforceable manner.

This Protocol does not, in any way, affect or influence the Commission decision on Paladin’s application for a Licence to Prepare Site for and to Construct its proposed Patterson Lake South project.

1. Introduction

1.1 Purpose

Paladin has a project for the site preparation and construction of a new uranium mine and mill identified as Patterson Lake South (PLS) Project. The Paladin PLS Project is a proposed new uranium mining and milling operation that is owned by Paladin Canada Inc. The Project is located in the Western Athabasca Basin of northern Saskatchewan, approximately 155 km north of La Loche by road and approximately 550 km north-northwest of Prince Albert by air. The Project would include a mining and milling facility that would use underground mining methods to produce up to 15 million pounds of uranium on an annual basis, with a total production of 93.7 million pounds of uranium over the 10 year planned life of the mine. The Project is proposed to include underground mining operations, and above ground infrastructure including waste rock / stockpile management facilities, a process plant area, a tailings management facility, a permanent camp, ancillary buildings, support infrastructure, and a network of access roads.

A Commission decision regarding the licence to prepare site for and construct application is required. This Protocol only addresses communications on licensing matters. Recognizing the importance of a project schedule and scope, the purpose of this document is to:

  • establish a communication process (formal and informal) between Paladin and CNSC staff;
  • provide a framework within which CNSC staff will perform a technical assessment of the application and supporting documentation to make a recommendation to the Commission on Paladin’s PLS application.

Target dates for deliverables and milestones are described in Section 4.2 in this Protocol.

This Protocol should be followed to allow for open and transparent processes that do not fetter the discretion of the Commission.

1.2 Scope

This Protocol will come into effect on the date of the last signature to this Protocol. It will terminate on the date that the Commission announces its licensing decision on Paladin’s application for a licence to prepare site for and construct the PLS Project.

1.3 Document security

The CNSC follows the Policy on Government Security, Access to Information Act and the Privacy Act for information management. It is important for Paladin to request classification of any submitted documents at appropriate levels, to ensure that CNSC staff can handle Paladin’s information appropriately. In most cases, Paladin’s documents should be unprotected / unclassified.

Further, CNSC's Directive on Requesting Confidentiality provides direction to all parties on how to make a request under Rule 12 of the CNSC Rules of Procedure for information to be kept confidential.

1.4 Exchange of information

The exchange of correspondence between Paladin and CNSC staff should be effectively coordinated, managed, retained, and retrievable by both participants. The following principles will be applied:

  • Formal communication between Paladin and CNSC staff will be controlled using the single point of contact (SPOC) approach, including copying the CNSC secondary officer and others as identified by both parties.
  • The information exchanged will reflect the position of Paladin or of CNSC staff – not of the individuals involved.
  • Paladin and CNSC subject matter experts may communicate directly with each other to request clarification or to share information. SPOCs must be aware of these communications and involved as required.
  • CNSC staff will not recommend specific technical approaches to address regulatory requirements or identified deficiencies. If and when deficiencies are identified, CNSC staff will specify the regulatory requirement that is not met.

There are two types of communication: formal and informal.

1.4.1 Formal communication

The purpose of formal communication is to document any official regulatory requests or positions from CNSC staff, and for Paladin to provide an official response or a formal submission. All formal communication must have a record number associated with it in the corresponding document management systems and captured in action tracking, where appropriate.

1.4.2 Informal communication

It is a normal and accepted practice that Paladin and CNSC staff interact on a regular and informal basis. The basis of this communication is normally to clarify technical points that may relate to administrative, licensing or compliance issues. Neither CNSC staff nor Paladin will communicate regulatory positions or application commitments in this manner. Informal verbal communications (calls, meetings, workshops, etc.) will be followed by written summaries. Transcription of virtual meetings can be used for the purposes of creating meeting summaries.

2. Roles and responsibilities

The signatories to this Protocol have the following roles and responsibilities:

  • The CNSC has regulatory and statutory responsibilities under the Nuclear Safety and Control Act and its regulations. CNSC staff are responsible for assessing Paladin’s application for CNSC licence to prepare site for and construct a uranium mine and mill and for making a recommendation to the Commission.
  • Paladin is the applicant and is responsible for submitting adequate and complete information to support the licence application as per regulatory requirements.

For the purposes of this Protocol, the CNSC staff shall be represented by the following representatives:

  • Director of the Uranium Mines and Mills Division
  • Single Point of Contact, Senior Project Officer assigned to the Patterson Lake South file, Uranium Mines and Mills Division and the secondary Project Officer assigned to the Patterson Lake South file.

For the purposes of the Protocol, Paladin shall be represented by the following representatives:

  • President, Paladin Canada Inc.
  • Director Health, Safety, Environment and Regulatory Relations, Paladin Canada Inc.

CNSC staff and Paladin will identify an alternate if a primary team member is unavailable.

3. Long lead items – early infrastructure and procurement

Early infrastructure development and procurement of long-lead items in advance of a Commission decision, subject to applicable provincial approvals issued by the Environmental Protection Branch, to advance project readiness and procurement timelines, are undertaken with the understanding that such activities are carried out entirely at Paladin’s risk. Such activities may include limited civil and ground works, test works, and supporting infrastructure installations, and procurement of long lead items.

Any applications submitted by Paladin to the Province in relation to such activities will be provided to CNSC staff with sufficient time to allow for review and feedback. Upon request, CNSC staff may provide technical review and advisory feedback on proposed activities, including identification of potential licensing considerations or anticipated review timeframes. Any such feedback is nonbinding and does not prejudice or constrain the Commission’s authority, which rests solely with the Commission as part of its formal decision making processes.

4. Application work

CNSC staff will review the Patterson Lake South application against applicable CNSC regulations, including the General Nuclear Safety and Control Regulations, the Uranium Mines and Mills Regulations, and the Radiation Protection Regulations, among others. Further review criteria are captured in CNSC regulatory and guidance documents and in industry codes and standards applicable to a site preparation and construction licence for a uranium mine and mill, including CNSC’s draft REGDOC-1.3.1 Licence Application Guide: Uranium Mines and Mills.

4.1 Project schedule

Paladin will provide CNSC staff with a project schedule that includes an overview of the completion of the project, as well as more detailed schedules on components of the project or information that will be required to enable, or are tied to, the accomplishment of scheduled activities.

CNSC staff will in turn notify Paladin of items in the schedule which are of particular regulatory significance. Paladin will update the schedule regularly and will notify CNSC staff of any significant changes in the schedule that are related to the items identified by CNSC staff upon such changes being identified.

To realize Paladin’s objectives, the target to complete hearings for the LTPS/LTC application would be the end of 2027.

4.2 Application review time

CNSC staff’s review for Application sufficiency began when Paladin submitted its initial licence application to construct a uranium mine and mill at its PLS property on April 3, 2023.

On June 27, 2023, Paladin submitted a revised application to construct and operate a uranium mine and mill and then on May 1, 2024, Paladin submitted their final revised application to prepare site for and construct a uranium mine and mill facility.

On March 6, 2026, CNSC staff communicated its formal sufficiency assessment of the application package to Paladin which identified aspects of CNSC’s regulatory framework (regulations, safety and control areas) that were sufficient and not sufficient. On June 11, 2026, a notice of sufficiency was provided to Paladin and subsequently posted to the CNSC website.

Upon confirmation that Paladin’s Application contains sufficient detailed information for CNSC staff’s review, a 24-month timeline has been initiated for technical assessment, preparation of the Commission Member Document (CMD) and the CNSC Commission hearing process, including issuance of a Commission decision.

The Uranium Mines and Mills Regulations identifies review timelines for licence to prepare site and construct uranium mine and mill facilities as follows:

  • 8.1 The Commission shall, within 60 days after the day on which an application for a licence to prepare a site for and construct a uranium mine or mill is received, determine whether the application contains sufficient detailed information for the Commission to commence its review.
  • 8.2 The Commission shall, within 5 days after the day on which it determines that an application contains sufficient detailed information for it to commence its review, give notice of the commencement of its review
    • (a) by providing notice in writing to this effect by mail or email to the applicant; and
    • (b) by posting notice to this effect on its Internet site.
  • 8.3 (1) The Commission shall render its decision in respect of an application within a time period of 24 months from the day on which the notice is posted in accordance with paragraph 8.2(b).
  • (2) The following are excluded from the 24-month time period:
    • (a) any period granted by the Commission for the preparation and submission of information requested by the Commission, which in the opinion of the Commission is necessary to complete the review;
    • (b) any period, not to exceed 30 days following the Commission’s receipt of a response to the request for information referred to in paragraph (a), that the Commission requires to determine whether the information requested has been provided and is adequate;
    • (c) any period that is required by any jurisdiction to respond to an offer to consult and cooperate made by the Commission under section 18 of the Canadian Environmental Assessment Act, 2012 with respect to the environmental assessment of the proposed preparation of the site for, and construction of, the uranium mine or mill, or its operation, decommissioning or abandonment, and, if the offer is accepted by any jurisdiction, any period that is required for consultation and cooperation with that jurisdiction;
    • (d) any period that is required to conduct, and render a decision on, an environmental assessment of the proposed preparation of the site for, and construction of, the uranium mine or mill, or its operation, decommissioning or abandonment, by any jurisdiction that is obligated by law to conduct that assessment and render a decision; and
    • (e) any period during which the licence application review was adjourned under section 14 of the Canadian Nuclear Safety Commission Rules of Procedure.

The Commission shall render its decision in respect of an application within a time period of 24 months based on the assumption that the information submitted by Paladin is sufficiently complete and detailed to allow the regulatory assessment and licensing process to proceed efficiently. CNSC staff will endeavor to review the application expeditiously without compromise to the level of effort required to ensure a thorough technical assessment. CNSC staff will not compromise on timelines for engagement and consultation with the public and Indigenous groups.

In addition to the Uranium Mines and Mills Regulations, REGDOC-3.5.1, Information Dissemination: Licensing Process for Class I Nuclear Facilities and Uranium Mines and Mills, Version 2, identifies a 24-month timeline for the licence to prepare site and construct phase for uranium mines and mills.

The table below outlines current and future Paladin document submissions.

Table 1: Paladin tentative submission schedule
Package Timing
Documentation submitted in support of sufficiency Complete
Climate Change Resilience Assessment Report August 2026
Mine Waste Safety Case October 2026
Mining and Milling Facilities Description Manual November 2026
Environmental Risk Assessment (ERA Update) January 2027
Best Available Technology and Techniques Economically Achievable and updated ECOP January 2027

The status of these submissions and any updates shall be tracked in a shared document outside of this Protocol.

Table 2: CNSC staff Anticipated Review Timelines
Activity # of business days
CNSC staff technical assessment* 60
Paladin response to IRs 20
CNSC staff review of IRs 20

* This reflects an upper boundary.  The timing for the technical assessment period could be less for an SCA depending on the number of documents, etc.

Disclaimer: In some instances, the number of days may be extended as these timelines do not include processing times of the application and responses.

The planned review time may be extended under various circumstances, including, but not limited to:

  • any significant change(s) made to the design;
  • any delay in Paladin’s submissions, incomplete submissions, or any delay in responding to CNSC staff questions on Paladin’s submissions;
  • insufficiency of information or supporting references provided by Paladin: for an expeditious review, the submissions must be complete, comprehensive and of sufficient quality;
  • resolution of information requests issued by CNSC staff; and any additional time to ensure adequate public and Indigenous engagement and consultation;
  • unanticipated CNSC resource shortages;
  • competing deliverables on the same file (e.g., CMD contribution vs technical review of updated documents).

In circumstances where the review timelines may be delayed:

  • Paladin and CNSC staff will communicate review timelines delays to the other as soon as they are reasonably able to;
  • CNSC staff will continue reviewing material in other submission packages where possible; and
  • Paladin and CNSC staff will provide updated estimated timelines for the completion of applicable work and resolutions.

Paladin will notify CNSC staff as early as possible if slippages occur in the schedule of submissions. CNSC staff will attempt to accommodate slippages to the extent practicable.

For the purposes of this Protocol, CNSC staff’s assessment consists of technical assessment comments (i.e., those areas / safety and control areas deemed sufficient but where further information is required to inform the drafting of CNSC staff’s CMD). CNSC is committed to working proactively with Paladin staff to support an efficient, well-coordinated, and timely regulatory review process.

4.3 Results of the Technical Review

During the technical review, CNSC staff will issue an information request (IR) if it is determined that there is insufficient information available to complete the review. Upon completion of the detailed technical reviews to satisfy each safety and control area, CNSC staff will confirm the closure of any IRs. Once all IRs are closed and finalized, CNSC staff will indicate to Paladin that the document or documents associated with a submission are acceptable.

4.4 Issue resolution

CNSC staff will review the Licence to Prepare Site for and Construct application submitted by Paladin to make licensing recommendations to the Commission. Disagreements between Paladin and CNSC staff raised during the review, including differences of opinion or interpretation and application of regulatory documents, will be addressed under the issue resolution mechanism.

Nothing in this issue resolution mechanism seeks to bind, or has the effect of binding, the Commission.

Step 1: Identification of the Issue and Resolution at the Project Manager/Working Level

  1. Periodic Paladin and CNSC licensing or technical review meetings will be held to review progress on the key activities and highlight any potential major issues. Minimum attendance at these review meetings will be the Licensing SPOC for CNSC staff and Paladin but may include technical SPOCs as well.
  2. The intent is to identify any potential major issues either through these licensing and technical review meetings or through outstanding CNSC staff’s review of technical comments. Where all technical comments associated with a Safety and Control Area or a specific subject have been resolved, CNSC staff will confirm resolution of that area and the item will be considered closed for the purposes of the licence application review and recommendation.
  3. It is the intention of both participants to resolve issues at this level.
  4. If an issue cannot be resolved at this level, it will be documented (typically, a brief factual summary of the issue and a paragraph representing the view of each organization) within 1 week of the indecision and forwarded to the Director / Manager Level (Step 2).

Step 2: Resolution at the Director/ Manager Level

  1. A Step 1 issue, once documented, will be provided to the CNSC Director of Uranium Mines and Mills Division and Paladin Canada Inc. Director, Health, Safety, Environment and Regulatory Relations. A meeting will be called, normally within 7 business days, to resolve the issue, and the resolution documented.
  2. Issues which cannot be resolved at this level will be referred to the Executive Level (Step 3) within 10 business days, supported by the original or revised documentation from Step 1 and any additional documentation from Step 2.

Step 3: Resolution at the Executive Level

  1. A Step 2 issue with documentation will be sent to the CNSC Director General, Directorate of Nuclear Cycle and Facilities Regulation and Paladin Canada Inc. President. A meeting will be called, normally within 30 days, to resolve the issue and the resolution documented. In exceptional circumstances, CNSC Vice President and Paladin Energy Ltd. Chief Operating Officer will resolve issues that remain outstanding from Step 3. If the issue cannot be resolved at CNSC staff level, the issue will be presented to the Commission for decision as part of the hearing process.

4.5 Managing change

When a proposed change has a potential impact on the review of Paladin’s application, the change will be submitted to the CNSC as a formal notification. Any changes to the application and/or supporting documents that have a potential impact on the design and safety and control measures contained within the application, will be communicated as “notification requiring CNSC concurrence”, as these changes may impact the conclusions of CNSC technical review. Changes will be communicated immediately to CNSC staff.

4.6 Interfacing with other jurisdictions

Paladin and CNSC staff will identify potential areas of coordination with various jurisdictions in the federal and provincial level. CNSC staff and the Government of Saskatchewan will coordinate and harmonize their respective regulatory regimes as defined under existing agreements or memoranda of understanding.

4.7 Project communications

Monthly or more frequent meetings will be held between Paladin and CNSC staff at the project management team level to discuss the review progress and highlight any potential major issues.

On a quarterly basis or more frequently, manager level meetings will be held between Paladin and CNSC staff to discuss the overall progress for the project and any issues as required.

4.8 Activities at the Patterson Lake South site

It is important that any activities on the Patterson Lake South site are controlled so that activities remain within Paladin’s authorizations. Paladin is strongly encouraged to keep the CNSC staff well informed of activities at the site, and to provide a rationale for why any activities correspond to Paladin’s authorizations.

5.0 Revisions of the protocol

Significant material revisions of this Protocol shall be coordinated by the managers and approved by the signatories of this Protocol. For example, changes to the proposed delivery or response dates will trigger a formal amendment. Managers can approve minor revisions (e.g., editorial corrections, clarification of text, or updates to organizational structure) to this Protocol.

6.0 Approval by signatories

The participants hereto have signed the Protocol, in counterpart, on the dates indicated below.

Dale Huffman, President, Paladin Canada Inc.

Ramzi Jammal, Executive Vice-President and Chief Regulatory Operations Officer, Canadian Nuclear Safety Commission

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