CNSC Assessment Report: Management System Pre-Licensing Review

Report Number: NWMO-2025-01
Report Date: August 26, 2025

Executive summary

The Nuclear Waste Management Organization (NWMO) requested Canadian Nuclear Safety Commission (CNSC) staff to conduct a pre-licensing review of the NMWO’s management system and records with respect to data acquisition and verification activities for geoscientific site assessment. This review is enabled through a Special Project Service Arrangement with the NWMO. The review was intended to identify any concerns meeting regulatory requirements and to increase regulatory certainty for the NWMO while in the pre-licensing phase. This review is not required as part of the licensing process and the conclusions of the review do not guarantee that any application for a licence will be successful. The output of this arrangement is in no way a guarantee or representation that the proposed project will be licensed in Canada.

CNSC assessed the NWMO’s governance and practices for the purpose of data acquisition and verification activities to confirm that they meet the guidance provided in sections 6.2 (Data Management) and 6.3.1 (Procedures for underground investigation using borehole drilling) of REGDOC-1.2.1, Class IB Facilities Guidance on Deep Geological Repository Site Characterization. The review focused on the Management System Safety and Control Area (SCA) to verify if the NWMO meets regulatory requirements. CNSC staff assessed the processes related to NWMO’s data acquisition and verification activities, to ensure the integrity, accuracy and completeness of the information and data generated as a result of site characterization activities. CNSC staff also reviewed the quality assurance and quality control of the NWMO’s underground borehole drilling investigation procedures to ensure that the objectives of the drilling program are achievable and controlled.

This review took into consideration the NWMO Management System governance, programs, procedures, project and records that were in place at the time Boreholes 4, 5 and 6 were drilled.

This review identifies areas for improvement to better demonstrate regulatory requirements and guidance are being met. Recommendations resulting from this review will strengthen the NWMO’s management system in the following areas:

• Independent verification of contractors’ work
• Contractor oversight
• Documenting quality processes and how it is controlled
• Conducting and documenting effectiveness reviews

CNSC staff acknowledge that the NWMO is currently revising its governance and programs to align with current standards and regulatory guidance documents. CNSC staff recommend that the NWMO perform a gap analysis of its current governance program against current standards and regulatory guidance documents and consider having a third party verify the gap analysis.