# Regulatory Oversight Report for Uranium and Nuclear Substance Processing Facilities in Canada: 2019

## Executive summary

The Regulatory Oversight Report for Uranium and Nuclear Substance Processing Facilities in Canada: 2019 presents the regulatory efforts of Canadian Nuclear Safety Commission (CNSC) staff in relation to such facilities for the 2019 calendar year. This report also provides an update on CNSC staff’s regulatory activities pertaining to public information, community engagement, and aspects of the CNSC’s Independent Environmental Monitoring Program that relate to uranium and nuclear substance processing facilities. Where possible, the report shows trends and compares information to that of previous years.

CNSC staff use 14 safety and control areas (SCAs) to evaluate the performance of each licensee. The resulting performance ratings for all 14 SCAs are set out in this report. Particular focus is placed on the 3 SCAs – radiation protection, environmental protection, and conventional health and safety – that contain the majority of the key performance indicators for these facilities.

The SCA ratings in this report were derived from the results of compliance verification activities conducted by CNSC staff. These activities included onsite inspections, technical assessments, reviews of reports submitted by licensees, reviews of events and incidents, and ongoing exchanges of information with licensees. For the 2019 reporting year, CNSC staff rated all SCAs as “satisfactory” for all uranium and nuclear substance processing facilities, and confirmed that all such facilities in Canada were operating safely.

In 2019, CNSC staff’s efforts supported their ongoing commitment to meeting consultation and accommodation obligations and to continuing to build relationships with Indigenous peoples with interests in Canada’s uranium and nuclear substance processing facilities.

CNSC staff concluded that the licensees for the regulated facilities covered in this report made adequate provision for the health and safety of workers, the protection of the public and the environment, and the fulfillment of Canada’s international obligations.

This report is available on the CNSC website, and the documents referenced in it are available to the public upon request by contacting:

Senior Tribunal Officer, Secretariat
Tel.: 613-996-9063 or 1-800-668-5284
Fax: 613-995-5086
Email: interventions@cnsc-ccsn.gc.ca

## 1 Introduction

Through the application of the Nuclear Safety and Control Act (NSCA) Footnote 1, and its associated regulations, the Canadian Nuclear Safety Commission (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. Licensees are responsible for operating their facilities safely and are required to implement programs that make adequate provision for meeting legislative and regulatory requirements.

This regulatory oversight report (ROR) provides an overview of CNSC regulatory efforts related to uranium and nuclear substance processing facilities in Canada for the 2019 calendar year.

The sites covered by this report are:

*Each alphanumeric expression refers to the licence held by the licensee.

The 3 safety and control areas (SCAs) that this report focuses on – radiation protection, environmental protection, and conventional health and safety – include key metrics to demonstrate each licensee’s performance, such as the radiation dose to workers and the public, releases to the environment and the number of lost-time injuries (LTIs). The report also includes information on the licensees’ public information programs, engagement with Indigenous groups and communities, and reportable events. Appendix A provides a list of links to the licensees’ websites.

## 2 Uranium processing facilities

Uranium processing facilities are part of the nuclear fuel cycle that includes refining, conversion and fuel manufacturing. The fuel produced is used in nuclear power plants for the generation of electricity.

### 2.1 Cameco Blind River Refinery

Cameco Corporation owns and operates the Blind River Refinery (BRR) in Blind River, Ontario. The facility is located about 5 km west of the town of Blind River, Ontario.

The BRR facility refines uranium concentrates (yellowcake) received from uranium mines worldwide to produce uranium trioxide (UO3), an intermediate product of the nuclear fuel cycle. The primary recipient of the UO3 product is Cameco’s Port Hope Conversion Facility (PHCF). For additionalgeneral information, please visit the CNSC web page on the BRR facility.

### 2.2 Cameco Port Hope Conversion Facility

Cameco Corporation owns and operates PHCF, which is located in Port Hope, Ontario, situated on the north shore of Lake Ontario, approximately 100 km east of Toronto.

PHCF converts UO3 powder produced by Cameco’s BRR facility into uranium dioxide (UO2) and uranium hexafluoride (UF6). UO2 is used in the manufacture of CANada Deuterium Uranium (CANDU) reactor fuel, while UF6 is exported for further processing before being converted into fuel for light-water reactors. For additional general information, please visit the CNSC web page on PHCF.

Vision in Motion

Vision in Motion (VIM) is Cameco’s project to clean up and renew the site, as well as address legacy waste from historic operations. The project is being carried out under Cameco’s operating licence for the facility. Licence condition 16.1 requires the licensee to “implement and maintain a program to carry out cleanup, decontamination and remediation work”. In 2019, Cameco carried out work that included the following activities:

• Stored wastes were prepared and transferred to the Canadian Nuclear Laboratories (CNL) Port Hope Area Initiative’s (PHAI’s) Port Hope Project Long-Term Waste Management Facility (LTWMF) from the PHCF main site, Dorset Street site; and transfers from the Centre Pier site were completed.
• Building demolition was completed at the Centre Pier site and the demolition waste was transferred to the LTWMF.
• At Building 27 (former UF6 plant), asbestos abatement and process hazard removal were completed, interior equipment removal was begun, and demolition of the tote bin and emergency generator rooms was completed.
• Infrastructure work in the corridor between building 2 and 6, 7, 12 and 12 A was substantially completed.
• Infrastructure installment was started for stormwater management and the new hydrogen station at the south end of the facility.
• Demolition of the former waterworks plant (garage building demolition pending) was started, as was remediation of low-level radioactive waste (LLRW).

During the Commission proceedings in 2016 on the renewal of Cameco’s licence for the BRR facility, the Commission decided that Centre Pier could be removed as a licensed area once Cameco had completed building demolition and ceased operational activities. Cameco then completed the demolition of all Centre Pier buildings, removed all demolition and stored waste to convey its intent to terminate all operational activities at Centre Pier, and submitted required documentation about these activities. After verifying Cameco’s actions via an onsite inspection in June 2019, Centre Pier was removed from the PHCF licensed area drawing (a document referenced in the PHCF licence conditions handbook (LCH)). Centre Pier is currently under the care and control of CNL. Centre Pier will undergo further remediation of historically contaminated soils and will also be used to support Port Hope Harbour remedial activities.

### 2.3 Cameco Fuel Manufacturing Inc.

Cameco Fuel Manufacturing Inc. (CFM) is a wholly owned subsidiary of Cameco Corporation. CFM operates 2 facilities: a nuclear fuel fabricating facility licensed by the CNSC in Port Hope, Ontario; and a metals manufacturing facility in Cobourg, Ontario, which manufactures fuel bundle and reactor components (non-nuclear activities). This latter facility is not licensed by the CNSC and is not discussed further in this report.

The CFM facility in Port Hope manufactures fuel pellets from natural uranium dioxide (UO2) powder and assembles nuclear reactor fuel bundles. The finished fuel bundles are primarily shipped to Canadian nuclear power reactors. For additional general information, please visit the CNSC web page on CFM.

### 2.4 BWXT Nuclear Energy Canada Inc.

BWXT Nuclear Energy Canada Inc. (BWXT) (formerly known as GE‑Hitachi Nuclear Energy Canada Inc.) produces nuclear fuel and fuel bundles used by Ontario Power Generation’s (OPG’s) Pickering and Darlington nuclear generating stations. BWXT has licensed operations in 2 locations: Toronto and Peterborough, Ontario.

The Toronto site produces uranium dioxide (UO2) fuel pellets, and the Peterborough site manufactures the fuel bundles, using the pellets from Toronto and zircaloy tubes manufactured in-house. The Peterborough site also runs a fuel services business involved with the manufacturing and maintenance of equipment for use in nuclear power plants. For additional general information, please visit the CNSC web pages on BWXT Toronto and BWXT Peterborough.

In November 2018, BWXT submitted a licence application to renew its operating licence for a 10-year period. The Commission conducted an oral public renewal hearing in March 2020 in Toronto and Peterborough. In April 2020, the Commission announced a continuation of the hearing and directed CNSC staff to collect additional soil samples of beryllium from properties adjacent to BWXT’s Peterborough facility. Once the Commission receives CNSC staff’s submission, the Commission will deliberate on BWXT’s licence renewal request. The resampling results and the supplementary submission will be publicly available. More information on the continuation of the hearing is available on the CNSC website.

UPDATE: The sampling results are available on the IEMP Website. The Commission issued the new licences on December 18, 2020

## 3 Nuclear substance processing facilities

Nuclear substance processing facilities process nuclear substances for a variety of end uses in industrial or medical applications. The nuclear substances can be used for lighting self-luminous emergency and exit signs, sterilizing items for sanitary reasons such as surgical gloves, and providing cancer diagnosis and treatment.

### 3.1 SRB Technologies (Canada) Inc.

SRB Technologies (Canada) Inc. (SRBT) operates a Class IB facility that manufactures gaseous tritium light source (GTLS) on the outskirts of Pembroke, Ontario, located approximately 150 km northwest of Ottawa.

The SRBT facility processes tritium gas (HT) to produce sealed glass capsules coated with phosphorescent powder and filled with HT to generate continuous light. Examples of such GTLS include signs, markers and tactical devices. SRBT distributes its products in Canada and internationally.

For additional general information, please visit the CNSC web page on the SRBT facility.

### 3.2 Nordion (Canada) Inc.

The Nordion (Canada) Inc. facility is adjacent to industrial and residential property in Ottawa, Ontario, and is licensed to operate a Class IB nuclear substance processing facility.

At this facility, Nordion processes unsealed radioisotopes (such as yttrium-90 (Y‑90)) for health and life sciences applications, and manufactures sealed radiation sources (cobalt-60 (Co-60)) for industrial and medical applications. The facility consists of 2 major production operations. One involves the processing of radioisotopes used in nuclear medicine (medical isotopes) and the other involves sealed sources used in cancer therapy and irradiation technologies (gamma technologies).

In April 2018, BWX Technologies Ltd. (BWXT) announced an agreement to acquire Nordion’s medical isotope business. The acquisition was completed in August 2018. CNSC staff assessed the information provided by Nordion on the acquisition, including the proposed management system, and determined that the proposed change would have a neutral impact on safety and was within the licensing basis. No licence amendment or Commission decision was required for the acquisition to proceed as Nordion will continue to operate the medical isotope facility until BWXT obtains a separate Class IB nuclear substance processing facility operating licence (NSPFOL).

For additional general information, please visit the CNSC web page on Nordion.

### 3.3 Best Theratronics Ltd.

Best Theratronics Ltd. (BTL) owns and operates a manufacturing facility in Ottawa, Ontario.

BTL manufactures cyclotrons and medical equipment, including cobalt-60 radiation therapy units and cesium-137 blood irradiators. BTL has a licence from the CNSC for the development and testing of Co‑60 teletherapy devices, the manufacturing of self-shielded irradiators and radioactive source teletherapy machines, the storage of nuclear substances, and construction and testing of particle accelerators (cyclotrons). For additional general information, please visit the CNSC web page on BTL.

In September 2018, BTL submitted an application requesting a renewal of its operating licence for a 10-year period. The Commission conducted an oral public renewal hearing in May 2019 and renewed BTL’s Class IB licence for a 10-year period in June 2019.

## 4 CNSC regulatory oversight

The CNSC performs regulatory oversight of licensed facilities to verify compliance with the requirements of the NSCA and associated regulations made under the NSCA, each site’s licence and licence conditions, and any other applicable standards and regulatory documents.

CNSC staff use the safety and control area (SCA) framework to assess, evaluate, review, verify and report on licensee performance. The SCA framework includes 14 SCAs, each subdivided into specific areas that define its key components. For further information on the SCA framework can be found on the CNSC’s website.

### 4.1 Regulatory activities

CNSC staff conducted risk-informed regulatory oversight activities at Canada’s uranium and nuclear substance processing facilities in 2019. Table 4-1 presents the licensing and compliance verification efforts from CNSC staff for these facilities throughout 2019. Of note are the high numbers for BWXT and BTL licensing activities. This is due to activities associated with licence renewal efforts for both licensees.

Table 4-1: CNSC regulatory oversight licensing and compliance verification activities, uranium and nuclear substance processing facilities, 2019

Facility Number of onsite inspections Person-days for compliance verification activities Person-days for licensing activities Number of safeguards inspections led by IAEA*
BRR 4 157 11 5
PHCF 4 275 7 6
CFM 3 200 17 4
BWXT 3 232 302 6
SRBT 2 110 2 N/A
Nordion 4 91 20 1
BTL 1 66 225 0

*International Atomic Energy Agency

Compliance verification

The CNSC ensures licensee compliance through verification, enforcement and reporting activities. CNSC staff implement compliance plans for each site by conducting regulatory activities including onsite inspections, desktop reviews and technical assessments of licensee programs, processes and reports.

Appendix B contains a list of CNSC inspections carried out at each uranium and nuclear substance processing facility in 2019. All findings in these inspections were considered low risk and did not have an impact on safety at the facilities.

Licensing

As part their licensing activities, CNSC staff draft new licences, prepare Commission member documents, and draft or revise LCHs.

As the CNSC publishes its regulatory documents, CNSC staff update the LCHs as applicable for each site, taking into consideration the licensee’s implementation plans. Appendix C lists changes to uranium and nuclear substance processing facility licences and LCHs. CNSC staff verify the implementation as part of ongoing compliance verification activities. Appendix D lists CNSC regulatory documents implemented at uranium and nuclear substance processing facilities and used by CNSC staff for compliance verification. Appendix E presents the financial guarantee amounts for each facility.

IAEA safeguards activities

Under the terms of the Canada–IAEA safeguards agreements, the IAEA has the right to perform independent verification activities at various types of sites in Canada. IAEA activities are not CNSC compliance inspections, but CNSC staff accompany the IAEA in approximately 75% of its activities.

### 4.2 Performance ratings, 2019

Performance ratings result from regulatory oversight activities. Table 4-2 shows how CNSC staff rated each licensee’s performance for each SCA in 2019.

Table 4-2: SCA performance ratings, 2019

SCA BRR PHCF CFM BWXT SRBT Nordion BTL
Management system SA SA SA SA SA SA SA
Human performance management SA SA SA SA SA SA SA
Operating performance SA SA SA SA SA SA SA
Safety analysis SA SA SA SA SA SA SA
Physical design SA SA SA SA SA SA SA
Fitness for service SA SA SA SA SA SA SA
Radiation protection SA SA SA SA SA SA SA
Conventional health and safety SA SA SA SA SA SA SA
Environmental protection SA SA SA SA SA SA SA
Emergency management and fire protection SA SA SA SA SA SA SA
Waste management SA SA SA SA SA SA SA
Security SA SA SA SA SA SA SA
Safeguards and non-proliferation SA SA SA SA N/A* SA SA
Packaging and transport SA SA SA SA SA SA SA

*There are no safeguard verification activities associated with this facility.

Appendix F provides SCA ratings for each licensee from 2015 to 2019.

For 2019, all licensees received SA ratings for each applicable SCA. Please note that, to prioritize work in the context of the COVID-19 pandemic, a binary approach to facility performance assessment was taken for this ROR. That is, licensees would be rated only as “satisfactory (SA)” or “below expectations (BE)” and the “fully satisfactory (FS)” rating would not be used. It is important to recognize that, if a facility received an FS for an SCA in the 2018 ROR but an SA rating for the same SCA in the 2019 ROR, this does not necessarily indicate a reduction in facility performance. The binary rating approach considerably reduced the effort often needed to reach a consensus on a final rating.

## 5 CNSC assessment of safety at uranium and nuclear substance processing facilities

The CNSC regulates all aspects of safety at nuclear sites in Canada, including risks to workers, the public and the environment. Information related to the SCAs of radiation protection, environmental protection, and conventional health and safety are most representative of overall safety performance. In particular, the SCAs of radiation protection and conventional health and safety are a good measure of the safety of workers at uranium and nuclear substance processing facilities, while the SCA of environmental protection is a good measure of the safety of the public and the environment.

## 5.1 Environmental protection

Protection of the environment and the public are linked in the SCA of environmental protection. This SCA covers programs that identify, control and monitor all releases of radioactive and hazardous substances, and the effects on the environment from facilities or that result from licensed activities.

Currently, all licensees covered by this ROR have acceptable environmental protection programs in place to ensure the protection of the public and the environment. For 2019, CNSC staff rated the environmental protection SCA at all uranium and nuclear substance processing facilities as “satisfactory”.

Appendix G provides the total annual releases of radionuclides for each uranium and nuclear substance processing facility from 2015 to 2019. Appendix H contains data on dose to the public from 2015 to 2019. Appendix I contains supplemental environmental data on all licensees.

Effluent and emissions control (releases)

All uranium and nuclear substance processing facilities implement effluent and environmental monitoring programs commensurate with the risks of their operations. Airborne and waterborne releases of radioactive and hazardous substances at all uranium and nuclear substance processing facilities remained below regulatory limits in 2019.

Action levels

The following environmental action level exceedances were reported to the CNSC in 2019:

• On July 1 2019, Cameco PHCF reported a fluoride measurement of 266 g HF/h, which exceeded the action level of 230 g HF/h. The action level was exceeded due to an electrolytic cell gland failure in the UF6 plant cell room. Cameco isolated the cell, which resulted in fluoride concentrations returning to normal. The exceedance did not pose a risk to people or the environment. As a corrective action, Cameco followed up its investigation by revising its procedure on how to troubleshoot a cell failure and how to adequately implement isolation and purging techniques.
• During the second and third quarters of 2019, Cameco PHCF reported 18 instances where the daily action level of 100 µg U/L was exceeded for uranium discharges to the sanitary sewer. This was attributed to the unusually high Lake Ontario water elevations and associated groundwater infiltration to the sanitary sewer system resulting from significant precipitation events. Cameco completed its corrective actions; this has helped reduce the number of action level exceedances in 2020. Cameco is continuing to repair sections of the sanitary sewer network and is upgrading it as part of the Vision in Motion (VIM) project. The discharges remained below the monthly mean release limit of 275 µg U/L.

CNSC staff have assessed that no impact on workers, the public or the environment resulted from these exceedances. CNSC staff also reviewed Cameco’s corrective actions in relation to the action level exceedances and are satisfied with the licensee’s responses.

Environmental management system

The CNSC requires each licensee to develop and maintain an environmental management system (EMS) that provides a framework for integrated activities related to environmental protection. EMSs are described in environmental management programs and include activities such as the establishment of annual environmental objectives, goals and targets. Licensees conduct internal audits of their programs at least once a year. As part of regular compliance verification, CNSC staff review and assess these objectives, goals and targets. CNSC staff determined that, in 2019, the uranium and nuclear substance processing facility licensees established and implemented their EMSs in compliance with the CNSC regulatory requirements.

Assessment and monitoring

CNSC staff verified that each uranium and nuclear substance processing facility licensee has environmental monitoring programs commensurate with the risks of the operations at each of its facilities. The environmental monitoring programs are designed to monitor releases of radioactive and hazardous substances, and to characterize the quality of the environment associated with the licensed facility.

Environmental risk assessment

Licensees develop environmental risk assessments (ERAs) to analyze the risks associated with contaminants in the environment that result from licensed activities. ERAs provide the basis for the scope and complexity of environmental monitoring programs at the uranium and nuclear substance processing facilities.

CNSC staff use CSA standard N288.6-12, Environmental Risk Assessments at Class I Nuclear Facilities and Uranium Mines and Mills Footnote 2, to help determine whether licensees are complying with regulatory requirements for protection of the environment and human health. CSA N288.6-12 specifically states: “Facility ERAs should be reviewed on a five-year cycle or more frequently if major facility changes are proposed that would trigger a predictive assessment” Footnote 2. CNSC staff expect licensees to periodically review ERAs for their facilities, as appropriate.

Protection of the public

The CNSC requires licensees to demonstrate that the health and safety of the public are protected from exposures to hazardous (non-radiological) substances released from their facilities. Licensees use effluent and environmental monitoring programs to verify that releases of hazardous substances do not result in environmental concentrations that may affect public health. CNSC staff receive reports of discharges to the environment in accordance with reporting requirements outlined in the licences and the LCHs. Based on assessments of the programs at the uranium and nuclear substance processing facilities, CNSC staff concluded that, in 2019, the public continued to be protected from facility emissions of hazardous substances.

Estimated dose to the public

When the maximum dose to the public from licensed activities is calculated, the monitoring results from air emissions, liquid effluent releases and gamma radiation are taken into account. The CNSC requires the licensees to follow the ALARA principle, taking into account social and economic factors. (The acronym ALARA stands for “as low as reasonably achievable”.) This means that licensees must monitor their facilities and keep doses to the public below the annual public dose limit of 1 millisievert (mSv)/year prescribed in the Radiation Protection Regulations Footnote 3.

Table H-1 of appendix H compares estimated public doses from 2015 to 2019 for the uranium and nuclear processing facility licensees. Estimated doses to the public from all these facilities continued to be well below the regulatory annual public dose limit of 1 mSv/year.

Conclusion on environmental protection

CNSC staff concluded that the uranium and nuclear substance processing facility licensees implemented their environmental protection programs satisfactorily during 2019. The licensees’ programs are effective in protecting the health and safety of the public and the environment.

### 5.2 Radiation protection

The radiation protection SCA covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations Footnote 3. The program must ensure that contamination levels and radiation doses received by individuals are monitored, controlled and maintained ALARA.

For 2019, CNSC staff rated the radiation protection SCA at all uranium and nuclear substance processing facilities as “satisfactory”.

Appendix J contains data on dose to workers for each uranium and nuclear substance processing facility from 2015 to 2019.

Application of ALARA

CNSC staff confirmed that in 2019 all uranium and nuclear substance processing facility licensees continued to implement radiation protection measures to keep radiation exposures and doses to persons ALARA. The CNSC requirement for licensees to apply the ALARA principle has consistently resulted in these doses staying well below regulatory dose limits.

Worker dose control

The design of radiation protection programs includes the dosimetry methods and the determination of workers who are identified as nuclear energy workers (NEWs). These designs vary, depending on the radiological hazards present at the different facilities due to complex and varying work environments, and to the expected magnitude of doses received by workers. The dose statistics provided in this report are primarily for NEWs, with the inherent differences in the design of radiation protection programs among licensees taken into consideration. For this reason, direct comparison of doses received by NEWs among facilities does not necessarily provide an appropriate measure of a licensee’s effectiveness in implementing its radiation protection program. The facility-specific sections provide additional information on the total number of monitored persons, including workers, contractors and visitors.

CNSC staff confirmed that, in 2019, all uranium and nuclear substance processing facility licensees monitored and controlled the radiation exposures and doses received by all persons present at their licensed facilities, including workers, contractors and visitors.

Radiation protection program performance

CNSC staff conducted regulatory oversight activities at all uranium and nuclear substance processing facilities in 2019 to verify that the licensees’ radiation protection programs complied with regulatory requirements. These oversight activities included onsite inspections, desktop reviews, and compliance verification activities specific to radiation protection. Through these activities, CNSC staff confirmed that all these licensees have effectively implemented their radiation protection programs, to control occupational exposures to workers and keep doses ALARA.

Action levels

Action levels for radiological exposures are established as part of the licensees’ radiation protection programs. Each licensee is responsible for identifying the parameters of its own program(s) to represent timely indicators of potential losses of control of the program(s). These licensee-specific action levels may also change over time, depending on operational and radiological conditions.

If an action level is reached, it triggers the licensee to determine the cause, notify the CNSC and, if applicable, take corrective action to restore the effectiveness of the radiation protection program. It is important to note that occasional action level exceedances indicate that the action level chosen is likely an adequately sensitive indicator of a potential loss of control of the program.

It is possible that action levels that are never exceeded have not been established low enough to detect the emergence of a potential loss of control. For this reason, licensee performance is not evaluated solely on the number of action level exceedances in a given period, but rather on how the licensee responds and implements corrective actions to enhance program performance and prevent reoccurrence. Licensees are also required to periodically review their action levels to validate their effectiveness.

The following radiation protection action level exceedances were reported to the CNSC in 2019:

• At the BRR facility, a worker’s dosimeter recorded whole body and skin doses of 0.72 mSv and 13.62 mSv respectively during the wearing period for the second quarter of 2019. These doses exceeded the action levels for quarterly whole body dose (0.70 mSv) and quarterly skin dose (6 mSv). Following Cameco’s investigation into the action level exceedances, it was determined that the exposures were mostly non-personal in nature. The dosimeter had been lost in a processing area for some time, where it had been exposed to radiation. When the dosimeter was found, it was returned to the dosimeter storage rack where it was collected and returned to the dosimetry service provider for processing. The dose recorded on the dosimeter was assigned to the worker in the National Dose Registry (NDR). Cameco reviewed the worker’s work practices during the quarter and developed a more reasonable dose estimate. Cameco subsequently pursued a dose change with the NDR and established corrective actions around communicating to workers its expectations when dosimeters are lost.
• CFM’s extremity dose action level of 55 mSv/quarter was reached when a worker’s extremity dose for the third quarter was determined to be 73.7 mSv. Cameco’s investigation into the exceedance did not identify a clear cause, and determined the dose was not possible given the job tasks assigned to the worker, consideration of the worker’s past extremity doses, and comparisons with other workers’ extremity doses. CFM confirmed that the dose is not personal. CFM will be pursuing a change to the worker’s dose record with the NDR.

CNSC staff reviewed the action level exceedances and are satisfied with the licensee’s responses.

CNSC staff verified that, in 2019, all uranium and nuclear substance processing facility licensees continued to implement adequate measures to monitor and control radiological hazards in their facilities. These measures included delineation of zones for contamination control purposes and in-plant air-monitoring systems. Licensees demonstrated that they have implemented workplace monitoring programs to protect workers. The licensees have also demonstrated that levels of radioactive contamination were controlled within their facilities throughout the year.

Conclusion on radiation protection

CNSC staff concluded that, throughout 2019, the uranium and nuclear substance processing facility licensees effectively implemented and maintained their radiation protection programs, to ensure the health and safety of persons working in their facilities.

### 5.3 Conventional health and safety

The conventional health and safety SCA coversthe implementation of a program to manage workplace safety hazards and to protect workers.

Based on regulatory oversight activities, CNSC staff rated the performance of all uranium and nuclear substance processing facilities for the conventional health and safety SCA as “satisfactory” in 2019.

Appendix K contains health and safety information for each uranium and nuclear substance processing facility from 2015 to 2019.

Performance

Employment and Social Development Canada (ESDC) and the CNSC regulate conventional health and safety programs at uranium and nuclear substance processing facilities. Licensees submit hazardous-occurrence investigation reports to both ESDC and the CNSC, in accordance with their respective reporting requirements. CNSC staff monitor compliance with regulatory reporting requirements and, when a concern is identified, consult with ESDC staff.

Licensees are required to report to the CNSC as directed by section 29 of the General Nuclear Safety and Control Regulations Footnote 4. These reports include serious illnesses or injuries incurred or possibly incurred as a result of a licensed activity.

A key performance measure for the conventional health and safety SCA is the number of lost-time injuries (LTIs) that occur per year. An LTI is an injury that takes place at work and results in the worker being unable to return to work to carry out their duties for a period of time.

In 2019, there were 2 LTIs at Nordion and 2 at BTL. More information is available in appendix K.

Practices

Licensees are responsible for developing and implementing conventional health and safety programs for the protection of their workers. These programs must comply with Part II of the Canada Labour Code Footnote 5.

CNSC staff conducted desktop reviews and onsite inspections at all uranium and nuclear substance processing facilities during 2019 to verify compliance of the licensees’ conventional health and safety programs with regulatory requirements. CNSC staff determined, based on these regulatory oversight activities, that these licensees met all regulatory requirements for this specific area.

Awareness

Licensees are responsible for ensuring that workers have the knowledge to identify workplace hazards and take the necessary precautions to protect against these hazards. This is accomplished through training and ongoing internal communications with workers.

During onsite inspections, CNSC staff verify that workers are trained to identify hazards at the facilities. CNSC staff confirmed that the uranium and nuclear substance processing facilities have effectively implemented their conventional health and safety programs to keep workers safe.

Conclusion on conventional health and safety

CNSC staff concluded that the uranium and nuclear substance processing facility licensees implemented their conventional health and safety programs satisfactorily throughout 2019. The programs are effective in protecting the health and safety of persons working in these facilities.

## 6 Events and other matters of regulatory interest

### 6.1 Reportable events

Detailed requirements for reporting events to the CNSC – specifically unplanned situations or events – at uranium and nuclear substance processing facilities are included in the applicable LCH. CNSC regulatory document REGDOC-3.1.2, Reporting Requirements for Non-Power Reactor Class I Facilities and Uranium Mines and Mills Footnote 6, came into force for these licensees in January 2019. Over the period covered by this ROR, they complied with the requirements for submission of these reports.

All reportable events that occurred in 2019 (listed below) were of low safety significance, and CNSC staff are satisfied with the licensees’ corrective actions.

BRR

In March 2019, Cameco received 4 drums with missing drum ring bolts that are necessary under Type IP-1 packaging requirements. Cameco identified the deficiency and secured each drum ring prior to offloading the drums. No contamination or loss of material occurred, and no impacts on the health and safety of workers resulted from this reportable event.

PHCF

• Cameco reported 13 reportable events in 2019. As summarized below, the licensee effectively reported all of these events in accordance with its regulatory reporting requirements. Cameco also reported all airborne and liquid releases to the Government of Ontario’s Spills Action Centre. In all cases, there were no impacts on the environment, or on the health and safety of workers or the public.
• On March 28, Cameco reported that a purge meter had caught fire at the UF6 facility. The fire was immediately extinguished and work resumed within the hour. This event did not result in injuries, and no further damage was reported to the facility.
• Cameco reported 5 releases to Port Hope Harbour. Releases reported on May 8 and June 21 were discharges of steam condensate. The June 18 release was a sanitary sewer spill due to the failure of an underground sanitary sewer pipe connection, which led to surface pooling onsite. Cleanup and repairs were immediately carried out to minimize the release and prevent reoccurrence. The June 27 event consisted of releases of potable municipal water during the flushing of a condensate line used in VIM activities. The November 26 releases came from a broken water main.  Cameco reported these releases to the government of Ontario’s Spills Action Centre. In all cases, there were no impacts on the environment or on the health and safety of the public.
• Cameco reported 3 transportation-related events. On January 5, Cameco reported a minor transportation accident involving a vehicle transporting a UF6 cylinder. No injuries were reported and there was no damage to the cylinder or to the tractor-trailer.  On April 9, contamination (loose dirt) was discovered on the outside of a transport vehicle carrying drums to the Canadian Nuclear Laboratories (CNL) Port Hope Long Term Waste Management Facility (LTWMF). The area in question was cleaned up, and additional measures were put in place to check for loose dirt on all remaining shipments. On July 18, Cameco reported a loose stem on a uranium cylinder. The cylinder was found to have an incorrect torque applied on the stem; this was rectified upon discovery. No loose contamination was observed and the cylinder pressure was deemed unaffected by this occurrence.
• On July 19, Cameco reported the receipt of a flexible pressurized hose of suspect quality. Upon further investigation, it was determined that the hose’s flange was not fully welded and that quality control was lacking. Cameco’s internal quality control steps identified this issue before the hose was used.
• Cameco reported 3 Emergency Response Team (ERT) activation events. On July 17, Cameco activated its ERT to respond to an onsite building that reported floodwaters entering and egressing the building. The ERT response and immediate cleanup ensured that no impacts on the environment resulted from this event. On October 4, the ERT was activated when fluorine was detected in the UF6 cell room. The release was due to a gasket failure. The affected area was isolated and repaired before being returned to service. Two personnel who were working in the area in question were monitored for fluorine exposure; it was found that this incident had not elevated their fluorine levels. Because of action taken, there were no impacts on site personnel or the environment. On October 24, the ERT was activated to respond to an individual experiencing shortness of breath unrelated to work activities. The employee was later taken to the hospital for observation and released the same day.

CFM

• In January 2019, Cameco detected a leak of nitrogen gas from a valve on exterior equipment at CFM. Following this discovery, the faulty valve was quickly replaced. The release was estimated to be approximately 136 m3 of nitrogen gas. Cameco reported this event to the Government of Ontario’s Spills Action Centre and posted details of this event on its website. This event did not result in impacts on the environment, or on the health and safety of the public.

BWXT

• In March 2019, BWXT reported that an operator’s personal air sample was above the occupational exposure limit for beryllium. Subsequent investigations by the licensee showed that the local ventilation equipment needed adjustment. The equipment was then upgraded to increase the capture efficiency. This improvement was found to be effective and it continues to be monitored. BWXT submitted an event report that detailed root causes and corrective actions.
• In March 2019, BWXT reported a minor motor vehicle accident involving a transport truck that was carrying a consignment of uranium dioxide (UO2) powder contained within Type IP-1 steel drums from Cameco in Port Hope. There was minor damage to the truck, but no damage to the contents and no release of material. This event did not result in effects on the environment, the health and safety of persons, or national or international security.

SRBT

• In January 2019, a significant fire occurred at an industrial lumber facility near the SRBT facility. The fire resulted in the loss of power for much of the city of Pembroke, including the SRBT facility. For the duration of the loss of power, an employee was present in the facility per the requirements of the SRBT Security Program. Power returned to the facility the next morning. There were no effects on the health and safety of persons or on the environment resulting from the loss of power to the SRBT facility.
• In January 2019, SRBT accepted 3 aircraft signs containing 279.72 GBq of tritium gas from a customer in the European Union. SRBT had sold and exported the signs in accordance with an export licence issued by the CNSC. However, the signs did not meet the customer’s design requirements, so the customer sent them back. The shipment was mistakenly accepted upon arrival; that is, without first being authorized by SRBT. SRBT reinforced with the customer that the returns process had not been followed, and that SRBT expects this process to be followed in the future in all cases where products may need to be returned to Canada. The shipments took place without any incident and there was no impact on the public or the environment from this event.

Nordion

• Nordion reported 3 events related to packaging and transport in 2019. In all these cases, the events were low risk, involving damage to Type A packages sustained during handling by shippers or carriers, and there was no impact on the radioactive contents of the packages.
• In July 2019, Nordion reported an event related to the discovery of a potentially leaking cobalt-60 (Co-60) source received from CNL’s Chalk River Laboratories. The slightly elevated contamination levels were found to be due to an abnormal weld. There were no corrective actions by Nordion as this was the second-to-last shipment of Co-60 from CNL before CNL ceased production.

BTL

• In February 2019, BTL reported that a fire alarm was activated due to an electrical short in the fire safety system. Emergency fire personnel responded to the alarm and confirmed the false alarm. The electrical short was caused by water entering the building in an area that was to undergo roof repair at a later date.
• In February 2019, BTL reported that a pre-shipment notification about a non-compliance had been sent to an incorrect importing authority. The correct importing authority was advised, corrective action was taken, and procedure retraining was administered.

CNSC staff are satisfied that uranium and nuclear substance processing facility licensees responded appropriately to the events and implemented appropriate corrective actions in response to each event.

### 6.2 Public engagement

Public engagement has 2 aspects: activities carried out directly by CNSC staff and activities carried out by licensees.

#### 6.2.1 CNSC

The NSCA mandates the CNSC to disseminate objective scientific, technical and regulatory information to the public about its activities and the activities it regulates. CNSC staff fulfill this mandate in a variety of ways, such as publishing the RORs and holding “Meet the Regulator” sessions. CNSC staff also seek out other opportunities to engage with the public and Indigenous groups, often participating in meetings or events in communities with interest in nuclear sites. These allow CNSC staff to answer questions about the CNSC’s mandate and role in regulating the nuclear industry, including the uranium and nuclear substance processing facilities. For the facilities covered in this ROR, CNSC staff participated in the following events:

• BWXT annual summer barbecues – Toronto and Peterborough
• Port Hope Fall Fair

#### 6.2.2 Uranium and nuclear substance processing facilities

All uranium and nuclear processing facility licensees are required to maintain and implement public information and disclosure programs, in accordance with CNSC REGDOC-3.2.1, Public Information and Disclosure Footnote 7. These programs are supported by disclosure protocols that outline the type of facility information to be shared with the public, as well as details on how that information is to be shared. This ensures that timely information is effectively communicated to the public about the health, safety and security of persons and the environment, and about other issues associated with the lifecycle of nuclear facilities.

In 2019, CNSC staff evaluated licensees’ implementation of their public information and disclosure programs by reviewing the communications activities they conducted. CNSC staff determined that all uranium and nuclear substance processing facility licensees were complying with requirements and that they issued information in accordance with their public disclosure protocols.

### 6.3 Indigenous consultation and engagement

As an agent of the Crown and as Canada’s nuclear regulator, the CNSC recognizes and understands the importance of consulting and building relationships with Indigenous peoples in Canada. CNSC staff are committed to building long-term relationships with Indigenous groups who have interest in CNSC-regulated facilities within their traditional and/or treaty territories. By pursuing informative and collaborative ongoing interactions, the CNSC’s goal is to build relationships and trust. The CNSC’s Indigenous engagement practices – which include information sharing and funding support (through the CNSC’s Participant Funding Program (PFP)) to assist Indigenous peoples in meaningfully participating in Commission proceedings and ongoing regulatory activities – are consistent with the principles of upholding the honour of the Crown and reconciliation.

#### 6.3.1 CNSC staff engagement

The uranium and nuclear substance processing facilities in Canada fall within the traditional and/or treaty territories of many Indigenous communities (see appendix L). CNSC staff efforts in 2019 supported the CNSC’s ongoing commitment to meet its consultation obligations and build relationships with Indigenous peoples with interests in Canada’s nuclear processing facilities. CNSC staff continued to work with Indigenous communities and organizations to identify opportunities for formalized and regular engagement, including meetings and workshops, throughout the lifecycle of these facilities. Through this engagement, CNSC staff welcomed the opportunity to discuss and address topics of interest and concern related to CNSC-regulated activities to interested Indigenous communities.

In addition, to ensure that interested Indigenous communities were made aware of this 2019 ROR, CNSC staff provided them with a notice of the PFP opportunity to review and comment on it, as well as the opportunity to submit a written intervention and/or appear before the Commission as part of the Commission meeting. CNSC staff also sent copies of this report to all Indigenous communities and organizations who had requested that they be kept informed of activities at the facilities covered in the report.

#### 6.3.2 Licensee engagement activities

In 2019, CNSC staff continued to monitor the engagement work conducted by the uranium and nuclear substance processing facility licensees (Cameco, BWXT, SRBT, Nordion and BTL) to ensure that they actively engage and communicate with Indigenous groups who have interest in their facilities.

CNSC staff confirmed that the licensees have Indigenous engagement and outreach programs. Throughout 2019, the licensees met and shared information with interested Indigenous communities and organizations. These efforts included emails, letters, meetings, site visits and tours, as well as community visits, upon request. The CNSC encourages licensees to continue to develop relationships and engage with Indigenous groups who have expressed an interest in the licensee’s activities.

## 6.4 CNSC Independent Environmental Monitoring Program

As a standard licence condition, the licensee of each nuclear facility must develop, implement and maintain an environmental monitoring program to demonstrate that the public and the environment are protected from emissions resulting from the licensee’s licensed activities. The licensees submit the results of these monitoring programs to the CNSC to ensure compliance with applicable requirements, as set out in the applicable regulations.

The CNSC implements its Independent Environmental Monitoring Program (IEMP) to independently verify that the public and the environment around licensed nuclear facilities are protected. The IEMP is separate from, but complementary to, the CNSC’s ongoing compliance verification program. Under the IEMP, samples are taken from public areas around licensed facilities. The radioactive and hazardous substances in those samples are measured and analyzed, and the results are compared against relevant guidelines, limits and objectives.

In 2019, CNSC staff conducted independent environmental monitoring at BWXT Toronto and BWXT Peterborough. The 2019 IEMP results, which the CNSC posts on its IEMP web page, demonstrate that the public and the environment around these facilities are protected, and that no adverse environmental or health effects are expected to result from these facility operations. In addition, these results are consistent with the results submitted by the licensees and demonstrate that the licensees’ environmental protection programs continue to protect the health and safety of people and the environment.

However, in March 2020 during the BWXT licence renewal hearing, several intervenors expressed concerns over the levels of beryllium in soil near the Peterborough facility observed during the CNSC’s IEMP sampling campaigns in 2014, 2018 and 2019.  In response to public concerns, the Commission directed CNSC staff to carry out expedited soil resampling for beryllium of properties adjacent to BWXT’s Peterborough facility, with a special focus on the property where the Prince of Wales Public School is located. The Commission also directed CNSC staff to analyze the results and to clarify the risk that the beryllium levels may present to the health and safety of the public and the environment. CNSC staff completed the additional sampling in July 2020.

Update: The sampling results are available on the IEMP Website.

### 6.5 Follow-up from previous Commission meeting

On December 11, 2019, during the presentation of the Regulatory Oversight Report for Uranium and Nuclear Substance Processing Facilities in Canada: 2018 Footnote 8, the Commission requested 2 follow-up actions from CNSC staff:

• The Commission requested that licensees provide a direct point of contact to CNSC staff so that it can then be made publicly available to assist intervenors.
• Status: Licensees provided the requested information and this action is closed.
• CNSC staff were requested to provide a summary of the basis behind derived release limits (DRLs)
• Status: Please see the fact sheet on licensed limits for releases to the environment in appendix M.

### 6.6 Update on CNSC COVID-19 response and nuclear fuel cycle facility oversight

On March 15, 2020, the CNSC activated its Business Continuity Plan in response to the COVID-19 pandemic. Effective March 16, all CNSC staff in Ottawa and at regional and site offices were directed to work from home. CNSC management immediately suspended all regular nuclear fuel cycle facility compliance verification activities and identified activities that were considered critical, in order to support continued safe operation of licensed facilities and delivery of the CNSC mission and mandate. For example, files scheduled to be presented to the Commission, and the associated timelines for submission to the Secretariat, were reviewed to confirm any impact and plan any mitigation measures.

The majority of nuclear fuel cycle program licensees (such as CNL, Cameco, Orano, and OPG’s waste management facilities) shut down their operations when the pandemic started. All licensees activated business continuity plans. Most stopped operations, with non-essential staff working remotely. For licensees with operations deemed to be essential services (e.g., medical isotope production, global health care service providers), operations were not interrupted and public health guidelines were followed with additional safety protocols. As well, all licensees maintained all appropriate security measures at their sites. In all other cases, onsite licensees reduced the number of staff to the minimum required to maintain safety of the facility or site while in shutdown state.

In April 2020, CNSC staff reviewed all planned onsite compliance verification activities on a risk-informed basis to determine an appropriate path forward. CNSC staff identified planned compliance verification activities well suited for delivery by other means (e.g., remote verification methods, desktop review of documents and submission of licensee records or other supporting evidence) and adjusted planned activities as appropriate. Licensee changes drove many changes to CNSC oversight, particularly in cases where no regulatory oversight was needed because a licensee had cancelled a particular activity.

The CNSC developed a pandemic-related pre-job brief as additional instructions for CNSC directors to deliver to inspectors before they perform onsite oversight activities. The CNSC also provided personal protective equipment (PPE) to inspectors prior to any onsite activity. The pre-job brief clearly outlines the rights of individual employees to not attend an in-person inspection if they do not feel it is safe for them to attend.

Compliance verification activities of nuclear fuel cycle facilities continued remotely. Onsite oversight activities have since resumed on a risk-informed basis in observance of relevant COVID-19 health protocols. CNSC staff continue to conduct oversight activities during the COVID-19 pandemic to ensure the protection of the environment, and the health and safety of people. The 2020 regulatory oversight report will further describe oversight activities completed in 2020 during the pandemic.

## 7 Overall conclusions

CNSC staff concluded that uranium and nuclear substance processing facilities in Canada operated safely during the 2019 calendar year. This assessment is based on CNSC staff’s verification of licensee activities, including onsite inspections, reviews of reports submitted by licensees, and reviews of events and incidents, supported by follow-up and general communication with the licensees.

For 2019, performance in all 14 SCAs for all the facilities was rated as “satisfactory”.

CNSC staff’s compliance verification activities confirmed that:

• radiation protection programs at all facilities were effective and adequately controlled radiation exposures, keeping doses ALARA
• environmental protection programs at all facilities were effective in protecting people and the environment
• conventional health and safety programs at all facilities continued to protect workers

CNSC staff concluded that, in 2019, the licensees discussed in this report made adequate provision for the health and safety of workers, as well as for the protection of the public and the environment, and for meeting Canada’s international obligations on the peaceful use of nuclear energy.

CNSC staff continue to provide regulatory compliance oversight to all licensed facilities.

## References

Note de bas de page 1

Nuclear Safety and Control Act, S.C. 1997, c. 9.

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Note de bas de page 2

CSA Group, CSA N288.6-12, Environmental Risk Assessments at Class I Nuclear Facilities and Uranium Mines and Mills, 2012.

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Note de bas de page 3

Radiation Protection Regulations (2000), SOR/2000-203.

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Note de bas de page 4

General Nuclear Safety and Control Regulations (2000), SOR/2000-202.

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Note de bas de page 5

Canada Labour Code, R.S.C., 1985, c. L-2.

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Note de bas de page 6

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Note de bas de page 7

CNSC, REGDOC-3.2.1, Public Information and Disclosure, Ottawa, Canada, 2018.

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Note de bas de page 8

CNSC, Regulatory Oversight Report for Uranium and Nuclear Substance Processing Facilities in Canada: 2018, CNSC staff presentation on the subject report to the Commission, Ottawa, Canada, 2019.

Retour à la référence de la note de bas de page 8 referrer

Note de bas de page 9

CNSC, REGDOC 3.6, Glossary of CNSC Terminology, Ottawa, Canada, 2019.

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Note de bas de page 10

CSA Group, CSA N288.1-14, Guidelines for Calculating Derived Release Limits for Radioactive Materials in Airborne and Liquid Effluents for Normal Operation of Nuclear Facilities, 2019.

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Note de bas de page 11

Ministry of the Environment, Conservation and Parks, Ontario’s Ambient Air Quality Criteria, 2019.

Retour à la référence de la note de bas de page 11 referrer

Note de bas de page 12

Health Canada, Guidelines for Canadian Drinking Water Quality, 2017.

Retour à la référence de la note de bas de page 12 referrer

Note de bas de page 13

Canadian Council of Ministers of the Environment, Canadian Water Quality Guidelines for the Protection of Aquatic Life, 1999.

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Note de bas de page 14

Canadian Council of Ministers of the Environment, Canadian Soil Quality Guidelines for the Protection of Environmental and Human Health, 1999.

Retour à la référence de la note de bas de page 14 referrer

Note de bas de page 15

CSA Group, CSA N288.7, Groundwater Protection Programs at Class I Nuclear Facilities and Uranium Mines and Mills, 2015.

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## Glossary

For definitions of terms used in this document, see REGDOC-3.6, Glossary of CNSC Terminology Footnote 9, which includes terms and definitions used in the Nuclear Safety and Control Act Footnote 1 and the regulations made under it, and in CNSC regulatory documents and other publications. REGDOC-3.6 is provided for reference and information.

Licensee Website 2019 annual compliance reports
Cameco BRR camecofuel.com/business/blind-river-refinery 2019 Annual Compliance Report
Cameco PHCF camecofuel.com/business/port-hope-conversion-facility 2019 Annual Compliance Report
Cameco CFM camecofuel.com/business/cameco-fuel-manufacturing 2019 Annual Compliance Report
BWXT Toronto and Peterborough nec.bwxt.com 2019 Annual Compliance Report
SRBT srbt.com 2019 Annual Compliance Report
Nordion nordion.com 2019 Annual Compliance Report
BTL theratronics.ca 2019 Annual Compliance Report

## B. CNSC inspections

Table B-1: Inspections, BRR, 2019

Inspection title Safety and control areas covered Inspection report sent date
CAMECO-BRR-2019-01 Management system, fitness for service, operating performance, radiation protection, conventional health and safety, human performance management May 31, 2019
CAMECO-BRR-2019-02 Emergency management and fire protection December 6, 2019
CAMECO-BRR-2019-03 Packaging and transport January 21, 2020
CAMECO-BRR-2019-04 Fitness for service March 4, 2020

Table B-2: Inspections, PHCF, 2019

Inspection Title Safety and control areas covered Inspection report sent date
CAMECO-PHCF-2019-01 Security PROTECTED
CAMECO-PHCF-2019-02 Management system, human performance management, fitness for service, radiation protection, conventional health and safety, environmental protection June 13, 2019
CAMECO-PHCF-2019-03 Emergency management and fire protection October 1, 2019
CAMECO-PHCF-2019-04 Management system, fitness for service, operating performance, radiation protection, conventional health and safety November 1, 2019

Table B-3: Inspections, CFM, 2019

Inspection title Safety and control areas covered Inspection report sent date
CAMECO-CFM-2019-01 Management system June 21, 2019
CAMECO-CFM-2019-02 Operating performance, fitness for service, conventional health and safety, radiation protection September 19, 2019
CAMECO-CFM-2019-03 Emergency management and fire protection January 8, 2020

Table B-4: Inspections, BWXT Toronto and Peterborough, 2019

Inspection title Safety and control areas covered Inspection report sent date
BWXT-2019-01 Management system July 31, 2019
BWXT-2019-02 Operating performance, physical design, fitness for service, radiation protection, conventional health and safety, environmental protection, emergency management and fire protection June 3, 2019
BWXT-2019-03 Radiation protection January 21, 2020

Table B-5: Inspections, SRBT, 2019

Inspection title Safety and control areas covered Inspection report sent date
SRBT-2019-01 Operating performance, fitness for service, radiation protection, conventional health and safety, environmental protection, waste management May 6, 2019
SRBT-2019-02 Environmental protection November 1, 2019

Note: Security inspection reports contain sensitive information and will not be made public.

Table B-6: Inspections, Nordion, 2019

Inspection title Safety and control areas covered Inspection report sent date
NORDION-2019-01 Security PROTECTED
NORDION-2019-02 Packaging and transport June 3, 2019
NORDION-2019-03 Emergency management and fire protection September 18, 2019
NORDION-2019-04 Packaging and transport November 18, 2019

Table B-7: Inspections, BTL, 2019

Inspection title Safety and control areas covered Inspection report sent date
BT-2019-01 Waste management, radiation protection, environmental protection, operating performance, conventional health and safety July 16, 2019

## C. Significant changes to licences and licence conditions handbook

Table C-1: Changes to licences

Licensee Date Facility licence Summary of changes
Nordion February 26, 2019 NSPFOL-14.01/2025 Nordion requested a transfer of its operating licence to a new corporate identity with the same name but with a new corporate number, to reflect the amalgamation of Nordion with its direct parent company and 2 other non-licensee-affiliated companies.

There are no changes to the existing licensed operations resulting from the licence transfer.

BTL July 1, 2019 NSPFL-14.00/2029 On May 2019, the Commission held a hearing in Ottawa on the renewal of BTL’s operating licence.

The Commission issued BTL’s licence on July 1, 2019.

Table C-1: Changes to the LCHs

Licensee Date Facility licence Summary of changes
Nordion January 25, 2019 NSPFOL-14.00/2025 LCH Revision 1
• Updated formatting
• Removed transition descriptions for:
• CSA N286-12 (management system)
• REGDOC-2.2.2, personnel training (human performance management)
• CSA N393 (fire protection)
• CSA N288.4 (environmental protection)
• REGDOC-2.10.1 (emergency response)
• REGDOC-2.12.3 (security, sealed sources)
• Updated release limits table treflect implementation of CSA N288 series documents
• Added guidance for
• CSA N288.7 and N288.8 (environmental protection)
• CSA B-51 (physical design)
• CSA N292.1 and IAEA NS‑R-5 (safety analysis)
• CSA N292.0 (waste management)
• Included REGDOC-2.13.1 as compliance verification criteria for safeguards and non-proliferation, and removed RD-336
• Included REGDOC-3.1.2 as compliance verification criteria for reporting
• Revised action level reporting dates from 60 days t21 days, in line with REGDOC-3.1.2
• Included REGDOC-2.11.1 as guidance for waste management, and removed G-320 and P-290
• Added REGDOC-3.2.1 as guidance for public information and disclosure
Nordion February 26, 2019 NSPFOL-14.01/2025 LCH Revision 2
• Updated licence number from NSPFOL-11A.00/2025 tNSPFOL‑11A.01/2025
• Updated Nordion corporate number from 891613-6 t1115250-5 treflect licence transfer
• Updated licence period from “November 1, 2015 tOctober 31, 2025” t“February 26, 2019 tOctober 31, 2025”, treflect licence transfer
BTL July 1, 2019 NSPFL-14.00/2029 First release of BTL’s LCH after the May 2019 licence renewal hearing held in Ottawa. The Commission issued BTL’s licence on July 1, 2019.

## D. Regulatory document implementation

Regulatory document Version PHCF BRR CFM BWXT
REGDOC-2.10.1, Nuclear Emergency Preparedness and Response February 2016 Implemented Implemented Implemented Implemented
REGDOC-2.2.2, Personnel Training December 2016 Implemented Implemented Implemented Implemented
REGDOC-2.9.1, Environmental Protection: Environmental Principles, Assessments and Protection Measures April 2017 Implementation plans expected in 2020 Implementation plans expected in 2020 Implementation plans expected in 2020 Implementation plans expected in 2020
REGDOC-3.1.2, Reporting Requirements, Volume I: Non-Power Reactor Class I Nuclear Facilities and Uranium Mines and Mills January 2018 Implemented Implemented Implemented Implemented
REGDOC-2.13.1, Safeguards and Nuclear Material Accountancy February 2018 Implemented Implemented Implemented Implementation expected by January 2019
REGDOC-2.1.2, Safety Culture April 2018 Implementation expected by June 2022 Implementation expected by June 2022 Implementation expected by June 2022 Implemented
REGDOC-3.2.1, Public Information and Disclosure May 2018 Implementation plans expected in 2020 Implementation plans expected in 2020 Implementation plans expected in 2020 Implementation plans expected in 2020
Regulatory document Version SRBT Nordion BTL
REGDOC-2.10.1, Nuclear Emergency Preparedness and Response February 2016 Implemented Implemented Implemented
REGDOC-2.2.2, Personnel Training December 2016 Implemented Implemented Implemented
REGDOC-2.9.1, Environmental Protection: Environmental Principles, Assessments and Protection Measures April 2017 Implementation plans expected in 2020 Implementation plans expected in 2020 Implementation expected by December 2020
REGDOC-3.1.2, Reporting Requirements, Volume I: Non-Power Reactor Class I Nuclear Facilities and Uranium Mines and Mills January 2018 Implemented Implemented Implemented
REGDOC-2.13.1, Safeguards and Nuclear Material Accountancy February 2018 N/A Implemented Implemented
REGDOC-2.1.2, Safety Culture April 2018 Implemented Implemented Implementation expected by December 2020
REGDOC-3.2.1, Public Information and Disclosure May 2018 Implementation plans expected in 2020 Implementation plans expected in 2020 Implementation expected by December 2020

## E. Financial guarantees

Table E-1: Financial guarantees, uranium processing facilities

 Facility Amount Canadian dollar (CAD) BRR $48,000,000 PHCF$128,600,000 CFM $21,000,000 BWXT Toronto$45,568,100 BWXT Peterborough $6,803,500 Table E-2: Financial guarantees, nuclear substance processing facilities Facility Amount (CAD) SRBT$727,327
Nordion $45,124,748 BTL$1,800,000

## F. Safety and control area ratings

For 2019, all licensees received SA ratings for each applicable SCA. Please note that, to prioritize work in the context of the COVID-19 pandemic, a binary approach to facility performance assessment was taken for this ROR. That is, licensees would be rated only as “satisfactory (SA)” or “below expectations (BE)”, and the “fully satisfactory (FS)” rating would not be used. It is important to recognize that, if a facility received an FS for an SCA in the 2018 ROR but an SA rating for the same SCA in the 2019 ROR, this does not necessarily indicate a reduction in facility performance. The binary rating approach considerably reduced the effort often needed to reach a consensus on a final rating.

Table F-1: SCA ratings, BRR facility, 2015 to 2019

SCAs 2015 rating 2016 rating 2017 rating 2018 rating 2019 rating
Management system SA SA SA SA SA
Human performance management SA SA SA SA SA
Operating performance SA SA SA SA SA
Safety analysis SA SA SA SA SA
Physical design SA SA SA SA SA
Fitness for service SA SA SA SA SA
Radiation protection SA SA SA SA SA
Conventional health and safety FS FS FS FS SA
Environmental protection SA SA SA SA SA
Emergency management and fire protection SA SA SA SA SA
Waste management SA SA SA SA SA
Security SA SA SA SA SA
Safeguards and non-proliferation SA SA SA SA SA
Packaging and transport SA SA SA SA SA

FS = fully satisfactory; SA = satisfactory

Table F-2: SCA ratings, PHCF, 2015 to 2019

SCAs 2015 rating 2016 rating 2017 rating 2018 rating 2019 rating
Management system SA SA BE SA SA
Human performance management SA SA SA SA SA
Operating performance SA SA SA SA SA
Safety analysis SA SA SA SA SA
Physical design SA SA SA SA SA
Fitness for service SA SA SA SA SA
Radiation protection SA SA SA SA SA
Conventional health and safety SA SA SA SA SA
Environmental protection SA SA SA SA SA
Emergency management and fire protection SA SA SA SA SA
Waste management SA SA SA SA SA
Security SA SA SA SA SA
Safeguards and non-proliferation SA SA SA SA SA
Packaging and transport SA SA SA SA SA

BE = below expectations; SA = satisfactory

Table F-3: SCA ratings, CFM, 2015 to 2019

SCAs 2015 rating 2016 rating 2017 rating 2018 rating 2019 rating
Management system SA SA SA SA SA
Human performance management SA SA SA SA SA
Operating performance SA SA SA SA SA
Safety analysis SA SA SA SA SA
Physical design SA SA SA SA SA
Fitness for service SA SA SA SA SA
Radiation protection SA SA SA SA SA
Conventional health and safety SA SA SA SA SA
Environmental protection SA SA SA SA SA
Emergency management and fire protection SA SA SA SA SA
Waste management SA SA SA SA SA
Security SA SA SA SA SA
Safeguards and non-proliferation SA SA SA SA SA
Packaging and transport SA SA SA SA SA

SA = satisfactory

Table F-4: SCA ratings, BWXT Toronto and Peterborough, 2015 to 2019

SCAs 2015 rating 2016 rating 2017 rating 2018 rating 2019 rating
Management system SA SA SA SA SA
Human performance management SA SA SA SA SA
Operating performance SA SA SA SA SA
Safety analysis SA SA SA SA SA
Physical design SA SA SA SA SA
Fitness for service SA SA SA SA SA
Radiation protection SA SA SA SA SA
Conventional health and safety SA SA SA SA SA
Environmental protection SA SA SA SA SA
Emergency
management and fire protection
SA SA SA SA SA
Waste management SA SA SA SA SA
Security SA SA SA SA SA
Safeguards and non-proliferation SA SA SA SA SA
Packaging and transport SA SA SA SA SA

SA = satisfactory

Table F-5: SCA ratings, SRBT, 2015 to 2019

SCAs 2015 rating 2016 rating 2017 rating 2018 rating 2019 rating
Management system SA SA SA SA SA
Human performance management SA SA SA SA SA
Operating performance SA SA SA SA SA
Safety analysis SA SA SA SA SA
Physical design SA SA SA SA SA
Fitness for service FS FS FS FS SA
Radiation protection SA SA SA SA SA
Conventional health and safety FS FS SA FS SA
Environmental protection SA SA SA SA SA
Emergency management and fire protection SA SA SA SA SA
Waste management SA SA SA SA SA
Security SA SA SA SA SA
Safeguards and non-proliferation* N/A N/A N/A N/A N/A
Packaging and transport SA SA SA SA SA

FS = fully satisfactory; N/A = not applicable; SA = satisfactory

*There are no safeguard verification activities associated with this facility.

Table F-6: SCA ratings, Nordion, 2015 to 2019

SCAs 2015 rating 2016 rating 2017 rating 2018 rating 2019 rating
Management system SA SA SA SA SA
Human performance management SA SA SA SA SA
Operating performance SA SA SA SA SA
Safety analysis SA SA SA SA SA
Physical design SA SA SA SA SA
Fitness for service SA SA SA SA SA
Radiation protection SA SA SA SA SA
Conventional health and safety SA SA SA SA SA
Environmental protection FS FS FS FS SA
Emergency management and fire protection SA SA SA SA SA
Waste management SA SA SA SA SA
Security FS FS FS FS SA
Safeguards and non-proliferation SA SA SA SA SA
Packaging and transport SA SA SA SA SA

FS = fully satisfactory; SA = satisfactory

Table F-7: SCA ratings, BTL, 2015 to 2019

SCAs 2015 rating 2016 rating 2017 rating 2018 rating 2019 rating
Management system SA SA SA SA SA
Human performance management SA SA SA SA SA
Operating performance SA SA SA SA SA
Safety analysis SA SA SA SA SA
Physical design SA SA SA SA SA
Fitness for service SA SA SA SA SA
Radiation protection SA SA SA SA SA
Conventional health and safety SA SA SA SA SA
Environmental protection SA SA SA SA SA
Emergency management and fire protection BE SA SA SA SA
Waste management SA SA SA SA SA
Security SA SA SA SA SA
Safeguards and non-proliferation SA SA SA SA SA
Packaging and transport SA SA SA SA SA

BE = below expectations; SA = satisfactory

## G. Total annual releases of radionuclides directly to the environment

The CNSC is making radionuclide release data more readily accessible to the public as part of its commitment to open government and its mandate to disseminate this information to the public. This appendix reflects the continued commitment to provide data, within the regulatory oversight reports, on the total annual release of radionuclides.

CNSC staff have commenced publishing annual releases of radionuclides to the environment from nuclear facilities on the CNSC Open Government Portal.

Uranium processing facilities

Direct releases of radionuclides to the environment from uranium fuel refinery, manufacturing and conversion facilities are primarily limited to uranium released to the atmosphere. As uranium is more chemically toxic than radiologically toxic, releases are monitored as total uranium. As a result, the annual load is reported in kilograms. Of these facilities, only Cameco’s Blind River Refinery has direct releases to surface water; the relevant radionuclides are uranium and radium-226.

Table G-1: Total annual load of relevant radionuclides released to atmosphere or surface waters for uranium processing facilities, 2015 to 2019

Facility and year Annual uranium release to air

(kg)

Annual uranium released in liquid effluent to surface waters

(kg)

Total radium-226 released in liquid effluent to surface waters

(MBq)

Blind River Refinery
2015 1.3 2.6 1.06
2016 1.0 1.2 0.92
2017 0.8 1.9 1.04
2018 1.2 1.9 1.05
2019 2.0 2.7 2.10
Port Hope Conversion Facility
2015 38.7 N/A N/A
2016 34.3 N/A N/A
2017 31.5 N/A N/A
2018 34.1 N/A N/A
2019 48.5 N/A N/A
Cameco Fuel Manufacturing
2015 0.46 N/A N/A
2016 0.73 N/A N/A
2017 0.58 N/A N/A
2018 1.26 N/A N/A
2019 1.09 N/A N/A
BWXT Toronto
2015 0.0108 N/A N/A
2016 0.0108 N/A N/A
2017 0.0074 N/A N/A
2018 0.0063 N/A N/A
2019 0.0071 N/A N/A
BWXT Peterborough
2015 0.000003 N/A N/A
2016 0.000004 N/A N/A
2017 0.000002 N/A N/A
2018 0.000002 N/A N/A
2019 0.000004 N/A N/A

MBq = megabecquerel; N/A = not applicable

### Nuclear substance processing facilities

#### SRBT

Direct releases to the environment for SRBT are limited to atmospheric releases of tritium. There are no direct releases to surface waters.

Table G-2: Total annual load of relevant radionuclides released to atmosphere, SRBT, 2015 to 2019

Year Tritium
Tritiated water or HTO
(GBq)
Elemental tritium or T2
(GBq)
2015 1.15E+04 4.47E+04
2016 6.29E+03 2.27E+04
2017 7.20E+03 1.76E+04
2018 1.07E+04 2.24E+04
2019 1.19E+04 1.99E+04

GBq = gigabecquerel; HTO = hydrogenated tritium oxide; HT = tritium gas

#### Nordion

Direct radionuclide releases to the environment at Nordion are limited to atmospheric releases.

Table G-3: Total annual load of relevant radionuclides released to the atmosphere, Nordion, 2015 to 2019

Year Cobalt-60 (GBq) Iodine-125 (GBq) Iodine-131 (GBq) Xenon-133 (GBq) Xenon-135 (GBq) Xenon-135m (GBq)
2015 0.005 0.12 0.15 11,916 8,237 10,758
2016 0.006 0.21 0.35 7,277 4,299 5,421
2017 0.0034 0.0012 0.0008 0 0 0
2018 0.002 0 0.006 0 0 0
2019 0.00002 0 0 0 0 0

GBq = gigabecquerel

### BTL

BTL does not have any airborne or liquid radiological releases.

## H. Public dose data

This appendix contains information on the estimated dose to the public around uranium and nuclear substance processing facilities. Regulatory release limits known as derived release limits (DRLs) are site-specific calculated releases that could, if exceeded, expose a member of the public of the most highly exposed group to a committed dose equal to the regulatory annual dose limit of 1 mSv/year, pursuant to subsection 1(3) of the Radiation Protection Regulations Footnote 3. DRLs are calculated using CSA N288.1-14, Guidelines for Calculating Derived Release Limits for Radioactive Materials in Airborne and Liquid Effluents for Normal Operation of Nuclear Facilities Footnote 10.

Considering the fact that the radiological releases from all the sites covered by this ROR have remained small fractions of the DRLs applicable to those sites, the contribution to the dose to the public from these releases remains a very small fraction of the prescribed limit for the general public.

Table H-1: Public dose comparison table (mSv), uranium and nuclear substance processing facilities, 2015 to 2019

Facility Year Regulatory limit
2015 2016 2017 2018 2019
BRR 0.005 0.005 0.005 0.005 0.005

1 mSv/year

PHCF 0.006 0.020 0.153* 0.173 0.127
CFM 0.025 0.023 0.022 0.030 0.027
BWXT Toronto 0.010 0.0007 0.0175 0.0004 0.023
BWXT Peterborough <0.001 <0.001 <0.001 <0.001 0.0115
SRBT 0.0068 0.0046 0.0033 0.0038 0.0021
Nordion 0.0057 0.0021 0.000052 0.000067 0.00087
BTL N/A N/A N/A N/A N/A

N/A = not available (no activities occur inside the BTL facility that result in the release of radioactive material to the environment); mSv = millisievert

*In 2016, PHCF updated the dose calculations related to releases to water and the fenceline gamma locations used for reporting the dose to the public. The amounts in 2017 and 2018 look higher than in previous years, but there has not been an actual increase in emissions/dose from the facility. The results actually represent a much more conservative estimate of dose to the public, as the gamma monitoring location at the facility fenceline is now closer to the operating facility than the previous location, resulting in the increase shown in the table. For this reason, the results beginning in 2017 cannot be compared with previous years’ results.

## I. Environmental data

This appendix provides environmental data for each uranium and nuclear substance processing facility.

### Blind River Refinery

Atmospheric emissions

Cameco monitors uranium, nitrogen oxides (NOx), nitric acid (HNO3) and particulates released from the facility stacks. The monitoring data in table I-1 demonstrates that atmospheric emissions from the facility continued to be effectively controlled as annual averages were consistently well below their respective licensed limits from 2015 to 2019.

Table I-1: Air emission monitoring results (annual averages), BRR, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 Licensed limit
Dust collection and exhaust ventilation stack: uranium (kg/h) 0.00005 0.00005 0.00004 0.00005 0.00005 0.1
Absorber stack: uranium (kg/h) 0.00001 0.00001 0.00001 0.00001 0.00001 0.1
Incinerator stack: uranium (kg/h) 0.00001 <0.00001 <0.00001 <0.00001 <0.00001 0.01
NOX + HNO3
(kg NO2/h)
2.5 1.6 1.8 2.3 3.3 56.0
Particulate (kg/h) 0.006 0.006 0.008 0.010 0.012 11.0

HNO3 = nitric acid; kg/h = kilogram per hour; NO2 = nitrogen dioxide; NOx = nitrogen oxides

Note: Results less than detection limit are denoted as “<”.

Liquid effluent

There are 3 sources of allowable liquid effluent from the BRR facility: plant effluent, storm water runoff and sewage treatment plant effluent. These effluents are collected in lagoons and treated, as required, prior to discharge into Lake Huron. Cameco monitors uranium, radium-226, nitrates and pH in liquid effluents to demonstrate compliance with their respective licensed limits. In addition to licensed limits, the BRR facility has action levels that are used to provide assurance that these licensed limits will not be exceeded. No action levels for liquid effluents were exceeded at any time in 2019.

Table I-2 summarizes the average monitoring results from 2015 to 2019. In 2019, the liquid discharges from the facility continued to be within their respective licensed limits.

Table I-2: Liquid effluent monitoring results (annual averages), BRR facility, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 Licensed limit
Uranium (mg/L) 0.02 0.01 0.01 0.01 0.01 2
Nitrates (mg/L) 13 11 14 20 21 1,000
Radium-226 (Bq/L) <0.01 0.01 0.01 0.01 0.01 1
pH (min) 7.2 7.3 7.3 7.3 7.2 Min 6.0
pH (max) 8.4 8.6 8.2 8.5 8.4 Max 9.5

Bq/L = becquerel per litre; mg/L = milligram per litre

Note: Results less than detection limit are denoted as “<”.

Uranium in ambient air

The concentrations of uranium in the ambient air, as monitored by Cameco’s sampling network around the BRR facility, continued to be consistently low. In 2019, the highest annual average concentration (among the sampling stations) of uranium in ambient air measured was 0.004 μg/m3, which is well below the Ministry of the Environment, Conservation and Parks (MECP) Ambient Air Quality Criteria (AAQC) for uranium of 0.03 μg/m3 Footnote 11.

Groundwater monitoring

Cameco has an extensive groundwater monitoring program in place around the facility with 35 monitoring wells: 14 wells located inside the perimeter fence and 21 outside the fenceline. Though not used as a potable water source, uranium concentrations from all the groundwater monitoring wells in 2019 were below Health Canada’s Guidelines for Canadian Drinking Water Quality (GCDWQ) for uranium Footnote 12.Table I-3 provides groundwater monitoring results.

Table I-3: Annual groundwater monitoring results, BRR, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 GCDWQ*
Average uranium concentration (µg/L) 1.7 1.3 1.2 2.3 2.0 20
Maximum uranium concentration (µg/L) 18.5 14.0 11.0 27.0 14.0 20

GCDWQ = Guidelines for Canadian Drinking Water Quality Footnote 12; µg/L = microgram per litre

*None of the groundwater wells monitored are used for drinking water.

Surface water monitoring

Cameco continues to monitor surface water for uranium, nitrate, radium-226 and pH at the location of the BRR facility’s outfall diffuser in Lake Huron. The concentrations of uranium, nitrate and radium-226 levels in the lake remained well below the CCME guidelines and pH levels remained well within them. Table I-4 provides surface water monitoring results.

Table I-4: Surface water annual average results at the BRR outfall diffuser in Lake Huron, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 CCME guidelines*

Uranium  (µg/L)

Average 0.2 <0.8 <0.8 <0.7 <0.7

15

Maximum 0.4 <0.8 <0.8 <0.7 <0.7

Nitrate (mg/L as N)

Average 0.2 0.2 0.2 0.2 0.1

13

Maximum 0.2 0.2 0.2 0.2 0.2

Average <0.005 <0.005 <0.005 0.008 <0.005

N/A

Maximum <0.005 <0.005 <0.005 0.008 <0.005

pH

Average 7.3 8.0 7.3 8.0 8.1

6.5–9.0

Maximum 7.9 8.2 7.7 8.3 8.2

Bq/L = becquerel per litre; CCME = Canadian Council of Ministers of the Environment; mg/L = milligrams per litre; µg/L = microgram per litre

Note: Results below the detection limit are denoted as “<”.

*CCME, Canadian Water Quality Guidelines for the Protection of Aquatic Life Footnote 13

Soil monitoring

Cameco collects soil samples at the 0 to 5 cm depth each year and at the 5 to 15 cm depth every 5 years, in order to monitor uranium concentrations in surface soil for long-term effects of air emissions on soil quality due to deposition of airborne uranium on soil in the vicinity of the BRR facility. The 2019 soil monitoring results remained consistent with the respective concentrations detected in previous years as shown in table I-5; that is, uranium soil concentrations did not appear to increase in the area surrounding the facility. The maximum uranium-in-soil concentrations measured near the facility were slightly above Ontario’s natural background levels (up to 2.5 μg/g) and well below 23 μg/g, which is the most restrictive soil quality guideline set by the CCME for uranium (for residential and parkland land use) Footnote 14. This data demonstrates that the current BRR operations do not contribute to accumulation of uranium in surrounding soil, and that no adverse consequences to relevant human and environmental receptors are expected.

Table I-5: Soil monitoring results (0-5 cm depth), BRR facility, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 CCME guidelines*
Average uranium concentration (µg/g) within 1,000 m 3.8 1.5 1.6 2.0 2.1

23

Average uranium concentration (µg/g) outside 1,000 m 1.4 0.5 0.6 0.7 1.0
Maximum uranium concentration  (µg/g) 9.7 2.9 2.8 3.7 3.8

cm = centimetre; CCME = Canadian Council of Ministers of the Environment; µg/g = microgram per gram

*CCME, Soil Quality Guidelines for the Protection of Environmental and Human Health Footnote 14 (for residential/parkland land use)

Gamma monitoring

A portion of radiological public dose from BRR operations is due to gamma radiation sources. Consequently, it is necessary to monitor gamma radiation effective dose rates at the fenceline of the BRR main site and the nearby golf course (the critical receptor location) to ensure that levels of potential gamma radiation exposure are maintained ALARA. Cameco continues to own and control the land immediately outside the perimeter fence. Therefore, Cameco sets an action level for gamma dose rates of 1.0 µSv/h at the north fence only, because the critical receptor location for the gamma component of dose to the public is the neighbouring golf course north of the BRR site. Cameco uses environmental dosimeters that are replaced monthly to measure the effective dose rates for gamma radiation. In 2019,  the maximum monthly fenceline gamma measurements at the BRR site was 0.50 µSv/h (east), 0.30 µSv/h (north), 0.51 µSv/h (south) and 1.01 µSv/h (west). All north fenceline results in 2019 were below the action level. These measurements indicate that gamma dose rates are controlled and that the public is protected.

### Port Hope Conversion Facility

Atmospheric emissions

Cameco monitors uranium, fluorides and ammonia released from stacks at PHCF. The monitoring data in table I-6 demonstrates that the atmospheric emissions from the facility continued to be effectively controlled, as annual averages remained consistently below their respective licensed limits from 2015 to 2019.

Table I-6: Air emission monitoring results (annual daily average), PHCF, 2015 to 2019

Location Parameter 2015 2016 2017 2018 2019 Licensed limit

UF6 plant

Uranium (kg/h) 0.0017 0.0012 0.0011 0.0014 0.0027 0.280
Fluorides (kg/h) 0.0170 0.0100 0.021 0.030 0.018 0.650

UO2 plant

Uranium (kg/h) 0.0012 0.0010 0.0005 0.0007 0.0008 0.240
Ammonia (kg/h) 2.4 1.7 1.4 1.7 2.1 58

UO2 = uranium dioxide; UF6 = uranium hexafluoride

The annual daily average uranium emission in 2019 at the UF6 increased compared to other levels within the 5-year period, as a result of increased production days and volumes.

Liquid effluent

Cameco’s operating licence does not allow the discharge of any process waste water effluent from PHCF. In 2019, there were no process liquid discharges from PHCF. Cameco continues to collect and evaporate rather than discharge process liquid effluent.

Cameco does discharge non-process liquid effluent, such as cooling water and sanitary sewer discharges, from PHCF. Cameco monitors these releases in compliance with the requirements of other regulators that have jurisdiction. In 2016 and early 2017, as part of the licence renewal process, a daily sanitary sewage discharge action level of 100 µg uranium per litre (U/L) and a monthly mean release limit of 275 µg U/L were developed and accepted. The sanitary sewage action level was exceeded on multiple occasions in 2017, 2018 and 2019. This was attributed to the unusually high Lake Ontario water elevations and associated groundwater infiltration into the sanitary sewer system due to significant precipitation events.

In response to these exceedances, Cameco implemented a number of corrective actions, starting in 2017, and completed all of them by fall 2019. This helped reduce the number of action level exceedances in 2020.

Cameco is continuing to repair sections of the sanitary sewer network and is upgrading it as part of the Vison in Motion (VIM) project. CNSC staff concluded that, in 2019, Cameco met its licence requirement not to discharge process waste water effluent and to keep the sanitary sewer discharges below their respective release limits.

Groundwater monitoring

Cameco samples groundwater quality at PHCF in the following monitoring wells:

12 pump-and-treat wells on a monthly basis

55 monitoring wells in the overburden (soil) on a quarterly basis

15 monitoring wells in the bedrock on an annual basis

The pump-and-treat wells have been performing as expected. They continue to reduce the mass of groundwater contaminants before discharging water into the harbour, at rates similar to previous years, as shown in table I-7 below.

CNSC staff review Cameco’s annual groundwater monitoring reports and, in 2019, noted increasing trends of nitrite concentrations in South Plume groundwater monitoring wells, radium-226 concentrations in East Plume monitoring wells, and ammonia concentrations in the original UF6 plant area. The elevated concentrations do not have an adverse impact on surface water in the harbour. However, CNSC staff are communicating with Cameco to ensure that the legacy onsite groundwater contamination is under control and that Cameco’s current operation is not adversely affecting the groundwater environment.

Table I-7: Mass (kg) of contaminants removed by pumping wells, PCHF, 2015 to 2019

Parameter 2015 2016 2017 2018 2019
Uranium 25.3 22.8 34.0 27.0 27.0
Fluoride 48.3 36.9 61.0 57.0 47.0
Ammonia 63.7 73.6 70.0 66.0 39.0
Nitrate 44.0 42.6 56.0 124.0 69.0
Arsenic 2.6 1.9 3.0 1.0 0.5

kg = kilogram

Surface water monitoring

The surface water quality in the harbour near the PHCF site has been monitored since 1977 through the analysis of samples collected from the south cooling water intake near the mouth of the Ganaraska River. The trend of surface water quality over time shows improvement since 1977 and very low uranium levels.

PHCF samples surface water in the harbour at 13 locations on a quarterly basis. This activity includes the collection of samples at depths slightly below the water surface and slightly above the harbour sediment layer at each location. These sampling locations were restricted beginning in 2018 due to CNL’s remedial harbour activities. However, PHCF has continued to monitor the cooling water intake located in the Port Hope harbour near the mouth of the Ganaraska River. Given its proximity to the harbour outlet, the cooling water intake provides a good indication of the overall water quality in the Port Hope harbour under routine/baseline conditions. Unusual and non-routine circumstances such as the 2018 west turning basin wall failure, CNL harbour isolation works and CNL harbour remedial activities have influenced the Port Hope Harbour water quality. Table I-8 provides annual average and maximum concentrations of uranium, fluoride, nitrate and ammonia monitored in the harbour water from 2015 to 2019.

The maximum uranium concentration was elevated compared to previous years due to CNL’s inner harbour remedial work and associated sediment disturbances in 2019. Uranium concentrations in the cooling water intake trended downward in 2020.

Table I-8: Harbour water quality, 2015 to 2019

Parameter Value 2015 2016 2017 2018 2019 CCME*
guidelines

Uranium (µg/L)

Average 2.9 2.6 3.3 5.2 5.1

15

Maximum 6.6 10 8.8 31 46

Fluoride (mg/L)

Average 0.13 0.15 0.19 0.16 0.092

0.12

Maximum 0.17 0.22 0.29 0.36 0.18

Nitrate (mg/L)

Average 0.89 0.85 1.0 1.0 0.95

13

Maximum 1.7 1.6 2.2 1.8 1.6

Ammonia + ammonium (mg/L)

Average 0.20 0.16 0.18 0.13 0.031

0.3

Maximum 0.66 0.58 0.40 0.47 0.21

CCME = Canadian Council of Ministers of the Environment; mg/L = milligrams per litre; µg/g = microgram per gram

*CCME, Canadian Water Quality Guidelines for the Protection of Aquatic Life

Soil monitoring

Cameco’s soil monitoring program consists of 5 monitoring locations beyond the facility’s fenceline in Port Hope. Three of these locations are within a 0 to 500 m radius zone from the facility, while the remaining ones are within the 500 to 1,000 m and 1,000 to 1,500 m radius zones. This includes a waterworks side yard remediated with clean soil to avoid interference from historical uranium soil contamination. Cameco takes samples annually at various depths within the soil profile to determine whether the concentration of uranium has changed as compared with previous sample results.

The measured average uranium-in-soil concentrations in 2019 have remained similar to those of past years. This suggests that uranium emissions from current PHCF operations do not contribute to accumulation of uranium in soil. Table I-9 provides soil sampling results for thewaterworks side yard location from 2015 to 2019. The results have been well below the most restrictive CCME Soil Quality Guidelines for the Protection of Environmental and Human Health Footnote 14 for residential and parkland land use (23 μg/g) and within the range of the natural background levels for Ontario (up to 2.5 µg/g).

Cameco has made a commitment to maintain the existing 5 soil monitoring locations and to report the results to the CNSC each year. Reclamation activities, as part of the Port Hope Area Initiative, will provide an opportunity for Cameco to review the locations of its soil monitoring stations throughout the Port Hope community.

Table I-9: Uranium concentrations at waterworks side yard remediated with clean soil (µg/g), 2015 to 2019

Soil depth (cm) 2015 2016 2017 2018 2019 CCME guidelines*
0–5 1.0 1.2 0.8 0.91 0.82

23

5–10 1.0 1.1 0.8 0.85 0.74
10–15 1.2 1.0 0.9 0.98 0.80

CCME = Canadian Council of Ministers of the Environment; cm = centimetre; µg/g = microgram per gram

*CCME, Soil Quality Guidelines for the Protection of Environmental and Human Health Footnote 14 (for residential/parkland land use)

Fluoride monitoring

The impact of fluoride emissions from PHCF on the environment is determined each growing season. At that time, samples of fluoride-sensitive vegetation are collected and then analyzed for fluoride content. The vegetation sampling program was modified in 2017, when sampling locations were standardized to Manitoba maple locations where clusters of trees were sampled as composite samples versus single location sampling. The results in 2019, as shown in table I-10, continued to be well below the MECP’s Upper Limit of Normal Guideline of 35 parts per million.

Table I-10: Fluoride concentration in local vegetation, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 MECP guidelines*
Fluoride in vegetation (ppm) 3.2 3.0 11.0 5.0 5.0 35

MECP = Ontario Ministry of the Environment, Conservation and Parks; ppm = parts per million

*MECP’s Upper Limit of Normal Guidelines

Gamma monitoring

A portion of radiological public dose from PHCF operations is due to gamma radiation sources. For this reason, monitoring gamma radiation effective dose rates at the fenceline of the 2 PHCF sites is essential to ensuring that levels of potential gamma radiation exposure are maintained ALARA. The gamma radiation effective dose rates for both sites are measured with environmental dosimeters supplied by a licensed dosimetry service. Per the 2016 operating release level (ORL), the dose to the public is calculated for both Site 1 (PHCF main site) and Site 2 (Dorset Street) using specific gamma fenceline monitoring locations. The modifications to the ORL in 2016 came into effect in 2017 and represent a much more conservative estimate of dose to the public. Due to these significant changes, the results beginning in 2017 cannot be compared with those of previous years. For more information about the ORL, see the 2018 ROR, available on the CNSC website.

The 2015 and 2016 annual average of doses for gamma are shown in table I-11. The 2017, 2018 and 2019 maximum monthly doses for gamma are shown in table I-12. For 2017 to 2019, the specific gamma fenceline monitoring locations used for Site 1 included results from monitoring stations 2, 10 and 13; for Site 2, they included results from stations 2 and 21.

In 2019, the maximum monthly gamma measurements were all below the respective licensed limits for Cameco. These measurements indicate that gamma dose rates are controlled and the public is protected.

Table I-11: Gamma monitoring results, annual average, BRR, 2015 to 2016

Parameter 2015 2016 Licensed limit
Site 1 (μSv/h) 0.007 0.005 0.14
Site 2 (Dorset Street)) (μSv/h) 0.044 0.054 0.40

µSv/h = microsievert per hour

Table I-12: Gamma monitoring results, maximum monthly, BRR, 2017 to 2019

Station number and site 2017 2018 2019 Licensed limit
Station 2 - Sites 1 and 2 (µSv/h) 0.25 0.26 0.20 0.57
Station 13/10* - Site 1 (µSv/h) 0.03 0.07 0.00/0.05* 0.40/0.61*
Station 21 - Site 2 (µSv/h) 0.08 0.07 0.06 0.26

µSv/h = microsievert per hour

*Denotes values for station 10. The results at stations 2 and 13 are used for Site 1 public dose calculations prior to July 1, 2019, and stations 2 and 10 are used for Site 1 public dose calculations after July 1, 2019, due to the removal of station 13 at Centre Pier.

### Cameco Fuel Manufacturing Inc.

Atmospheric emissions

Cameco continued to monitor uranium released as atmospheric emissions from the facility. The monitoring data in table I-13 demonstrates that stack and building exhaust ventilation emissions from the facility continued to be effectively controlled as annual averages remained consistently well below their licensed limits from 2015 to 2019.

Table I-13: Air emission monitoring results, CFM, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 Licensed
limit
Total uranium discharge through stacks (kg/year) 0.01 0.03 0.01 0.01 0.004

14

Total uranium discharge through building exhaust ventilation (kg/year) 0.45 0.70 0.57 1.25 1.09

kg = kilogram

In 2018 and 2019, Cameco calculated annual uranium discharge through building exhaust ventilation by summing up the daily release values to get a total sum for the year. This capability was built into the CFM facility’s new environmental monitoring software and is a better reflection of day-to-day operations compared to using an average quarterly result. Previously, the annual value was calculated by adding the quarterly results (2016 and 2017) or by using the annual average (2015). This caused the 2018 and 2019 annual results to be higher when compared with those of previous years due to the number of days used in the annual calculation compared to the number of days used in the quarterly calculation. The summation of the daily values is more representative of the actual building ventilation emissions.

In addition to the licensed limits, Cameco uses action levels to provide assurance that the licensed limits will not be exceeded. No action levels for atmospheric emissions were exceeded at any time in 2019.

Liquid effluent

After liquid effluent generated from the production process is collected, an evaporator process is used to remove most of the uranium. The condensed liquid is sampled and analyzed prior to a controlled release to the sanitary sewer line. Cameco continues to monitor uranium released as liquid effluent from the facility. The monitoring data in table I-14 demonstrates that liquid effluent from the facility in 2019 remained consistently well below the licensed limit and continued to be effectively controlled.

Table I-14: Liquid effluent monitoring results, CFM, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 Licensed limit
Total uranium discharge to sewer (kg/year) 1.24 0.85 0.64 0.84 0.39 475

kg = kilogram

For 2019, the decrease in the amount of uranium discharged to the sanitary sewer is attributed to the installation and commissioning of the automated pellet grinding equipment in 2018. The pellet wash water on the automated lines is processed in the waste treatment circuit and not released to the sanitary sewer.

In addition to the licensed limits, Cameco uses action levels to provide assurance that the licensed limits will not be exceeded. No action levels for liquid effluent were exceeded at any time in 2019.

Uranium in ambient air

Cameco operates high-volume air samplers to measure the airborne concentrations of uranium at points of impingement of stack plumes. The samplers are located on the east, north, southwest and northwest sides of the facility. The results in 2019 from these samplers showed that the highest annual average concentration of uranium in ambient air (among the sampling stations) was 0.0016 μg/m3. This is well below MECP’s Ambient Air Quality Criteria (AAQC) for uranium of 0.03 μg/m3 Footnote 11

Due to the benefits offered by ICP-MS (inductively coupled plasma – mass spectrometry), CFM ceased alpha counting and, beginning in 2018, has exclusively used ICP-MS to analyze filters. The ICP-MS method allows results to be reported directly through the Cameco database system.

Groundwater monitoring

Groundwater has been monitored at the site twice a year since 1999 with a network of 70 monitoring wells, including 43 overburden, 23 shallow bedrock and 4 deep bedrock wells. The groundwater monitoring results confirmed that operations in 2019 were not contributing to the concentrations of uranium in groundwater on the licensed property.

Surface water monitoring

In 2019, Cameco collected surface water samples at 9 locations in April, June and October. The sample locations were on and adjacent to the facility, and were analyzed for uranium.

Uranium concentrations in all surface water samples collected in 2019 met the applicable CCME Water Quality Guidelines for the Protection of Aquatic Life Footnote 13.

All surface water samples satisfied the CCME guidelines for long-term exposure (15 µg/L) in the Gages Creek tributary. There were a few exceedances in 2019 of the CCME guidelines for short-term exposure (33 µg/L) at the intermittent drainage locations SW-4 (93 µg/L in April and 78 µg/L in June) and SW-9 (51 µg/L in June) that were attributed to groundwater infiltration within the upstream storm sewer works.

CNSC staff will continue to oversee Cameco’s monitoring at locations in the vicinity of CFM to confirm that uranium concentrations remain at safe levels in surface water.

Soil monitoring

Every 3 years, Cameco collects soil samples from 23 locations surrounding the CFM facility. Soil samples were last collected in 2019 and analyzed for uranium content. The soil monitoring results are shown in table I-15. The 2019 average uranium concentration in soil near the CFM facility is within the Ontario natural background level of up to 2.5 μg/g. The maximum concentrations detected are attributable to historical contamination in Port Hope, which has long been recognized and continues to be the focus of environmental studies and cleanup activities. The results for all samples were below the CCME Soil Quality Guidelines for the Protection of Environmental and Human Health Footnote 14 of 23 μg/g. This is the most restrictive guideline; therefore, no adverse consequences to human and environmental receptors are expected. The next soil samples will be collected in 2022.

Table I-15: Soil monitoring results, CFM*

Parameter 2009 2010 2013 2016 2019 CCME guidelines**
Average uranium concentration (µg/g) 6.8 5.6 4.8 3.1 3.0

23

Maximum uranium concentration (µg/g) 17.0 21.1 17.4 10.2 7.6

µg/g = microgram per gram

* CFM reverted to a 3-year soil monitoring program and did not monitor soil in 2011, 2012, 2014, 2015, 2017 and 2018.

** CCME, Soil Quality Guidelines for the Protection of Environmental and Human Health Footnote 14 (for residential and parkland land use)

Gamma monitoring

For the CFM facility, a portion of radiological public dose is due to gamma radiation sources. Consequently, it is necessary to monitor gamma radiation effective dose rates at the fenceline of the CFM site to ensure that levels of potential gamma radiation exposure are maintained ALARA. The gamma radiation effective dose rates for the site are measured with environmental dosimeters supplied by a licensed dosimetry service. In 2019, the annual average of fenceline gamma measurements at the CFM site was 0.051 µSv/h. CFM has a licensed limit for fenceline gamma dose rates of 0.35 µSv/h at the monitoring station corresponding to the critical receptor and 1.18 µSv/h at all other monitoring locations. No licensed limits were exceeded in 2019.

In addition to licensed limits, CFM has action levels for the critical receptor and other locations. There were no exceedances of the action levels in 2019.

### BWXT Toronto

Atmospheric emissions

To ensure compliance with licensed limits, air from the BWXT facilities is filtered and sampled prior to its release into the atmosphere. Table I-16 provides BWXT Toronto’s annual maximum uranium emissions from 2015 to 2019.Table I-17 provides BWXT Peterborough’s annual maximum uranium and beryllium emissions from 2015 to 2019. The annual emissions remained well below the licensed limits for both facilities. The results demonstrate that air emissions of uranium and beryllium were being controlled effectively.

Table I-16: Air emission monitoring results (annual maximum concentrations), BWXT Toronto, 2015 to 2019

Parameter Stack 2015 2016 2017 2018 2019 Licensed limit

Uranium (µg/m3)

Rotoclone 0.197 0.355 0.180 0.464 0.077 65
6H-68 0.375 0.145 0.160 0.118 0.111 47
4H-48 0.217 0.500 0.130 0.086 0.037 97
Furnace #1 NA1 0.105 0.440 0.112 0.081 437
Furnace #2/4 NA1 0.809 0.150 0.092 0.103 55
Furnace #5/6 NA1 0.132 0.230 0.467 0.245 52

1Continuous sampling and reporting of uranium emissions from the 3 furnace stacks started in 2016.

Table I-17: Air emission monitoring results (annual maximum concentrations), BWXT Peterborough, 2015 to 2019

Parameter Stack 2015 2016 2017 2018 2019 Licensed limit
Uranium (µg/m3)     R2 Decan 0.016 0.012 0.003 0.006 0.014 410

Beryllium (µg/m3)

North 0.002 0.001 0.001 0.001 0.001

2.6

South 0.002 0.001 0.001 0.001 0.001
Acid 0.009 0.002 0.001 0.000 0.000

In addition to licensed limits, both facilities have action levels that are used to provide assurance that the licensed limits will not be exceeded. No action levels for atmospheric emissions were exceeded at any time in 2019.

Liquid effluent

To ensure compliance with licensed limits, waste water from the BWXT Toronto and Peterborough facilities is collected, filtered and sampled prior to its release into sanitary sewers. Table I-18 provides BWXT’s annual maximum concentrations of uranium and beryllium released to the sanitary sewers from 2015 to 2019. In 2019, the releases continued to be well below the licensed limits. The results demonstrate that liquid effluent releases were being controlled effectively.

Table I-18: Liquid effluent monitoring results (annual maximum concentrations), BWXT, mg/L, 2015 to 2019

Facility Parameter 2015 2016 2017 2018 2019 Licensed limit
BWXT Toronto Uranium 2.44 2.80 2.56 2.95 2.58 1,000

BWXT Peterborough

Uranium 0.09 0.48 0.09 0.03 0.07 2,500
Beryllium 0.0655 0.0025 0.0054 0.0025 0.0018 26

Uranium in ambient air

BWXT Toronto operates 5 high-volume air samplers to measure the airborne concentrations of uranium at points of impingement of stack plumes. The results from these samplers show that the annual average concentration of uranium (among the sampling stations) in ambient air measured around the facility in 2019 was below the minimum detection limit. This demonstrates that the results are well below MECP’s Ambient Air Quality Criteria (AAQC) for uranium of 0.03 μg/m3 Footnote 11. Table I-19 provides air monitoring results for BWXT Toronto.

BWXT Peterborough does not monitor uranium in ambient air because the atmospheric emissions discharged from the facility already meet the MECP standard of 0.03 µg/m3 at the point of release, thus eliminating the need for additional ambient monitoring.

Table I-19: Uranium in boundary air monitoring results, BWXT Toronto, 2015 to 2019

Parameter 2015 2016 2017 2018 2019
Average concentration (µg/m3) 0.001 0.001 0.000 0.000 0.000

µg = microgram

Note: Ontario’s standard for uranium in ambient air is 0.03 µg/m3.

Soil monitoring

BWXT conducts soil sampling at its Toronto facility as part of its environmental program. In 2019, soil samples were taken from 49 locations and analyzed for uranium content. The samples were collected on the BWXT site, on commercial lands located along the south border of the site and in the nearby residential neighbourhood. In 2019, the measured soil concentrations of uranium ranged from <1.1 µg/g at a residential location to 2.8 µg/g on commercial lands. These concentrations are comparable to Ontario’s background concentrations of up to 2.5 µg/g and well below the applicable CCME Soil Quality Guidelines for the Protection of Environmental and Human Health Footnote 14 for uranium for industrial, commercial and residential/parkland land use.

Tables I-20, I-21 and I-22 provide soil sampling results. The data demonstrates that current BWXT operations do not contribute to the accumulation of uranium in surrounding soil, and that no adverse consequences to relevant human and environmental receptors are expected.

Table I-20: Uranium-in-soil monitoring results, BWXT Toronto property, 2015 to 2019

Parameter Industrial lands
2015 2016 2017 2018 2019
Number of samples 1 1 1 1 1
Uranium concentration (µg/g) 1.4 1.2 1.7 1.3 1.2
CCME guideline (µg/g)*

300

CCME = Canadian Council of Ministers of the Environment; µg/g = microgram per gram

*CCME, Soil Quality Guidelines for the Protection of Environmental and Human Health Footnote 14

Table I-21: Uranium-in-soil monitoring results, commercial lands, BWXT Toronto, 2015 to 2019

Parameter Commercial lands
2015 2016 2017 2018 2019
Number of samples 30 34 34 34 34
Average uranium concentration (µg/g) 2.9 2.7 3.0 2.3 1.5
Maximum uranium concentration (µg/g) 8.7 13.6 20.6 11.9 2.8
CCME guideline (µg/g)*

33

CCME = Canadian Council of Ministers of the Environment; µg/g = microgram per gram

*CCME, Soil Quality Guidelines for the Protection of Environmental and Human Health Footnote 14

Table I-22: Uranium-in-soil monitoring results, residential locations, BWXT Toronto, 2015 to 2019

Parameter Residential locations
2015 2016 2017 2018 2019
Number of samples 18 14 14 14 14
Average uranium concentration (µg/g) 0.7 0.5 1.0 < 1.0 1.1
Maximum uranium concentration (µg/g) 2.1 0.7 1.6 < 1.0 1.7
CCME guidelines (µg/g)*

23

CCME = Canadian Council of Ministers of the Environment; µg/g = microgram per gram

*CCME, Soil Quality Guidelines for the Protection of Environmental and Human Health Footnote 14

Gamma monitoring

A portion of public radiological dose from both the BWXT Toronto and Peterborough facilities is due to gamma radiation sources. Consequently, it is necessary to monitor gamma radiation effective dose rates at the fenceline of the Toronto site and at the Peterborough plant boundary to ensure that levels of potential gamma radiation exposure are maintained ALARA.

Since 2014, BWXT has used environmental dosimeters to measure the effective dose rates for gamma radiation for the Toronto site. The estimated effective dose as a result of gamma radiation during 2019 was 23 µSv, for a total estimated critical receptor dose of 23.5 µSv when combined with the contribution from air emissions (0.5 µSv). This is well below the regulatory dose limit of 1 mSv (1,000 µSv) per year to a member of the public.

Since 2016, the gamma radiation effective dose rate for the BWXT Peterborough plant has also been measured with environmental dosimeters. The estimated effective dose as a result of gamma radiation during 2019 was 11.5 µSv, for a total estimated critical receptor dose of 11.5 µSv when combined with the contribution from air emissions (0.0 µSv). This is well below the regulatory dose limit of 1 mSv (1,000 µSv) per year to a member of the public.

These estimates indicate that gamma dose rates from both BWXT facilities are controlled and that the public is protected.

### SRB Technologies (Canada) Inc.

Atmospheric emissions

SRBT monitors tritium releases from the facility stacks and reports them on an annual basis. The monitoring data for 2015 through 2019, provided in table I-23, demonstrates that atmospheric emissions from the facility remained below their regulatory limits.

Table I-23: Atmospheric emissions monitoring results, SRBT, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 Licensed limit (TBq/year)
Tritium as tritium oxide (HTO) (TBq/year) 11.55 6.29 7.19 10.74 11.86 67.2
Total tritium as HTO + HT (TBq/year) 56.24 28.95 24.82 33.18 31.77 448

TBq = terabecquerel; HTO = hydrogenated tritium oxide; HT = tritium gas

Liquid effluent

SRBT continues to control and monitor tritium released as liquid effluent from the facility. The monitoring data for 2015 through 2019, provided in table I-24, demonstrates that liquid effluent from the facility remained below regulatory limits.

Table I-24: Liquid effluent monitoring results for release to sewer, SRBT, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 Licensed limit (TBq/year)
Tritium-water soluble (TBq/year) 0.007 0.005 0.007 0.010 0.014 0.200

TBq = terabecquerel

Tritium in ambient air

SRBT has 40 passive air samplers located within a 2 km radius of the facility. These samplers represent tritium exposure pathways for inhalation and skin absorption, and are used in the calculations to determine public dose. The 2019 air monitoring results from these samplers demonstrated that tritium levels in ambient air near SRBT remained low.

Groundwater monitoring

In 2019, groundwater was sampled from 29 monitoring wells installed by SRBT at its facility and from an additional 8 wells at surrounding residential and business properties. From the 2019 sampling results, the highest average tritium concentration was reported for monitoring well MW06-10 (34,592Bq/L, with a minimum of 23,900 Bq/L and maximum of 52,321 Bq/L). This well is located directly beneath the area where the active ventilation stacks are located. This well is a dedicated, engineered groundwater monitoring well very near to the facility within a secured area, and is not available for use as a source of water consumption. Throughout 2019, no other wells exceeded the Ontario Drinking Water Standard for tritium of 7,000 Bq/L. Figure I-1 below shows annual average tritium concentrations in select groundwater wells around the SRBT facility.

Tritium concentrations decrease significantly at locations farther away from SRBT. In 2019, the highest concentration of tritium sampled from the 3 business wells was 916 Bq/L and the highest in the 5 sampled residential wells was 58 Bq/L. These results are far below Ontario’s drinking quality standard of 7,000 Bq/L. All of the residential wells are over 1 km away from SRBT and are not in the groundwater flow pathway.

Tritium concentrations in Muskrat River (the receiving surface water environment about 420 m from the SRB property) in 2019 fell below the minimum detectable activity (MDA) (between 5 and 6 Bq/L), as they did in 2018.

Overall, CNSC staff concluded that the tritium inventory in the groundwater system around the facility has been trending downward since 2006. This trend is due to SRBT’s initiative to reduce emissions, which includes the commissioning of improved tritium trap valves and remote display units, the real-time monitoring of gaseous effluent, and a reduction in failed leak tests of manufactured light sources. Along with the reduced emissions, the concentration of tritium in the groundwater is decreasing due to the natural decay of tritium and the flushing of historical tritium emissions through the groundwater system.

Since 2016, SRBT has been in compliance with CSA N288.7-15, Groundwater Protection Programs at Class I Nuclear Facilities and Uranium Mines and Mills Footnote 15.

Figure I-1: Annual average tritium concentrations in groundwater and the Muskrat River, SRBT, 2019

Description

This photo shows an aerial view of a few groundwater monitoring wells around the SRBT site. It also indicates the concentration of tritium in becquerels per litre (Bq/L) in those wells and the Muskrat River.

Muskrat River and groundwater monitoring wells Tritium concentration (Bq/L) Exceed or below provincial limit
Muskrat River Below detection limit* Below
MW06-10 34,592 Exceed
MW07-13 5,647 Below
B-1 874 Below
B-2 730 Below
B-3 Below detection limit* Below
RW-2 41 Below
RW-3 48 Below

* The detection limit is approximately 5 Bq/L. The provincial limit for tritium in drinking water is 7,000 Bq/L.

Other monitoring

SRBT also samples and analyzes runoff water from its facility, and engages a qualified third party to perform monitoring and analysis of precipitation, surface water, produce, milk and wine. The 2019 monitoring data results for these items are low and consistent with previous years. This monitoring complements the principal monitoring activities, which focus on air and groundwater.

### Nordion (Canada) Inc.

Atmospheric emissions

Nordion continues to control and monitor the releases of radioactive materials from its facility to prevent unnecessary releases of radioisotopes to the atmosphere. Table I-25 shows Nordion’s radioactive air emissions monitoring results from 2015 to 2019.

The monitoring data demonstrates that the radioactive air emissions from the facility in 2019 remained below the regulatory limits. In November 2016, Nordion ceased the production of molybdenum-99, iodine-125, iodine-131 and xenon-133.

Table I-25: Air emissions monitoring results, Nordion, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 Licensed limit (DRL) (GBq/year)
Cobalt-60 0.005 0.006 0.0034 0.002 0.00002 250
Iodine-125 0.12 0.21 0.0012 0 0 952
Iodine-131 0.15 0.35 0.0008 0.006 0 686
Xenon-133 11,916 7,277 0 0 0 677,000,000
Xenon-135 8,237 4,299 0 0 0 102,000,000
Xenon-135m 10,758 5,421 0 0 0 69,000,000

DRL = derived release limit; GBq = gigabecquerel

Liquid effluent

Nordion continues to collect, sample and analyze all liquid effluent releases before discharge into the municipal sewer system. Table I-26 shows Nordion’s monitoring results for radioactive liquid emissions from 2015 to 2019.

The monitoring data demonstrates that the authorized radioactive liquid effluent releases from the facility in 2019 remained below the regulatory limits.

In 2019, Nordion reported 2 reportable environmental limit exceedances involving non-radiological releases to the sanitary sewer and a release of halocarbon. CNSC staff acknowledge that these few reportable short-term exceedances do not pose undue risk to the environment or human health due to conservatisms built in to the reportable limits used, but do expect Nordion to continue to investigate non-radiological sanitary sewer and halocarbon releases and identify ways to minimize or remove the source of such releases.

Table I-26: Liquid effluent monitoring results for release to sewer, Nordion, 2015 to 2019

Parameter 2015 2016 2017 2018 2019 Licensed limit (DRL) (GBq/year)
β < 1 MeV 0.191 0.222 0.212 0.243 0.162 763
β > 1 MeV 0.044 0.051 0.048 0.055 0.038 35,000
Iodine-125 0.111 0.144 0.145 0.146 0.063 1,190
Iodine-131 0.006 0.006 0.006 0.007 0.004 389
Molybdenum-99 0.060 0.052 0.049 0.055 0.036 10,200
Cobalt-60 0.019 0.026 0.022 0.027 0.020 35.4
Niobium-95 0.0010 0.0010 0.0010 0.0010 0.002 3,250
Zirconium-95 0.0010 0.0015 0.0020 0.0017 0.0019 2,060
Cesium-137 0.0004 0.0007 0.0007 0.0007 0.0007 24.8

β < 1 MeV = beta particles less than 1 megaelectronvolt; DRL = derived release limit; GBq = gigabecquerel

Groundwater monitoring

There are currently 9 groundwater monitoring wells on the Nordion site. Since 2005, Nordion has been monitoring groundwater at least once a year for non-radioactive contaminants in 4 monitoring wells. The monitoring results from 2014 to 2019 demonstrate that there were no significant changes in the groundwater in 2019 compared to previous years.

Since 2014, Nordion has been monitoring groundwater at least once a year for radioactive contaminants in 5 monitoring wells. The results since then have detected only naturally occurring radionuclides that are not processed at the Nordion facility. These results, which are either below detection limits or at natural background levels, indicate that releases of radioactive and hazardous substances from Nordion’s facility have had no measurable impact on groundwater quality.

Nordion has completed a gap analysis against the requirements of CSA N288.7-15, Groundwater Protection Programs at Class I Nuclear Facilities and Uranium Mines and Mills Footnote 15 and is continuing to update internal procedures and programs to meet these requirements and fill gaps identified.

Soil sampling

Nordion performed soil sampling in 2019. No radionuclides attributable to licensed activities were detected in the soil samples.

Environmental thermoluminescent dosimeters program

Nordion monitors environmental gamma radiation with the use of thermoluminescent dosimeters (TLDs). The dosimeters are deployed at locations to generally cover the points of a compass and preferentially to the east of the facility, which receives the prevailing west winds. Dosimeters are also placed in residences of Nordion employees located near the facility. The annual monitoring results for 2019 showed that the levels of gamma radiation at offsite monitoring locations are in the range of natural background levels. These results indicate that Nordion’s operations are not contributing to the public’s exposure to gamma radiation at, and beyond, the perimeter of the facility.

### Best Theratronics Ltd.

Effluent and emissions control (releases)

BTL has determined that, at the BTL facility, there are no radiological releases (liquid or airborne) requiring controls or monitoring. BTL’s operation uses radioactive sealed sources that do not produce any radioactive releases.

BTL safely manages hazardous liquid effluents from routine operations. They are collected, temporarily stored onsite, and then regularly removed for disposal by a certified third party contractor. Lubricating oil for onsite boring and milling machines is recovered and recirculated. Therefore, there would be no hazardous waterborne releases into the environment requiring controls or effluent monitoring.

Hazardous airborne emissions from BTL are related to the exhausting of the lead pouring, paint booth, fire-torching and sand blasting areas. Engineering controls, such as filters and ventilation, are in place to reduce or eliminate emissions generated during operations. As a result, BTL does not have an effluent monitoring program or an environmental monitoring program.

Assessment and monitoring

BTL does not conduct environmental monitoring around its facility, as there are no radiological releases requiring controls or monitoring. Hazardous airborne emissions pertain to exhausting associated with the lead pouring area. BTL submits a report on lead, and its compounds, to the National Pollutant Release Inventory, thus maintaining annual compliance with the Toxics Reduction Act. There have not been any abnormal instances within the licensing period.

## J. Worker dose data

This appendix presents information on doses to nuclear energy workers (NEWs) and non-NEWs at uranium and nuclear substance processing facilities.

### Cameco BRR

Figure J-1 provides the average and maximum effective doses for NEWs at the BRR facility from 2015 to 2019. The maximum effective dose received by a NEW in 2019 was 7.7 mSv, which is approximately 15% of the CNSC’s regulatory effective dose limit of 50 mSv in a 1-year dosimetry period. Average and maximum total effective doses over this 5-year period are reflective of the work activities at the facility, and increased in 2019 due to production levels and operating days that increased over previous years.

Figure J-1: Effective dose statistics for NEWs, BRR facility, 2015 to 2019

Description

Figure J-1: Effective dose statistics for nuclear energy workers, Cameco Blind River Refinery, 2015-2019

Dose statistic 2015 2016 2017 2018 2019
Average effective dose (mSv) 1.7 1.5 0.9 1.4 1.6
Maximum effective dose (mSv) 7.4 6.1 3.3 6.9 7.7
Number of nuclear energy workers monitored 154 154 145 150 172

Note: The regulatory limit for effective dose to a nuclear energy worker is 50 mSv/year.

Tables J-1 and J-2 provide average and maximum equivalent dose results for the skin and extremities of NEWs, from 2015 to 2019. In 2019, the maximum individual skin dose received by a NEW at the BRR facility was 29.2 mSv, which is approximately 6% of the CNSC’s regulatory equivalent dose limit of 500 mSv in a 1-year dosimetry period. The maximum individual extremity dose received by a NEW at the BRR facility was 11.9 mSv, which is approximately 2% of the CNSC’s regulatory equivalent dose limit of 500 mSv in a 1-year dosimetry period. The average and maximum equivalent doses have been relatively steady over this 5-year period.

Table J-1: Equivalent (skin) dose statistics for NEWs, BRR facility, 2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average skin dose (mSv) 3.9 3.3 3.1 4.1 4.8 N/A
Maximum individual skin dose (mSv) 28.1 26.0 16.2 28.4 29.2 500 mSv/year

mSv = millisievert; N/A = not applicable

Table J-2: Equivalent (extremity) dose statistics for NEWs, BRR facility, 2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average extremity dose (mSv) 1.5 1.2 1.0 3.5 3.9 N/A
Maximum individual extremity dose (mSv) 15.3 10.6 13.6 14.5 11.9 500 mSv/year

mSv = millisievert; N/A = not applicable

Non-NEWs at BRR

Site visitors and contractors who are not considered NEWs are issued external dosimeters to monitor their radiological exposures while at the BRR facility. In 2019, the maximum individual effective dose received by a site visitor or contactor who was not a NEW was 0.4 mSv, which is well below the CNSC’s regulatory effective dose limit of 1 mSv per calendar year for a person who is not a NEW.

### Cameco PHCF

Figure J-2 provides the average and maximum effective doses for NEWs at Cameco’s PHCF from 2015 to 2019. The maximum individual effective dose received by a NEW in 2019 was 4.9 mSv, which is approximately 10% of the CNSC’s regulatory effective dose limit of 50 mSv in a 1-year dosimetry period. The average and maximum total effective doses over this 5-year period are reflective of the work activities and production levels at PHCF.

Figure J-2: Effective dose statistics for NEWs, PHCF, 2015 to 2019

Description

Figure J-2: Effective dose statistics for nuclear energy workers, Cameco Port Hope Conversion Facility, 2015-2019

Dose statistic 2015 2016 2017 2018 2019
Average effective dose (mSv) 0.6 0.6 0.4 0.6 0.4
Maximum effective dose (mSv) 7.0 5.6 3.9 6.3 4.9
Number of nuclear energy workers monitored 857 859 808 1,025 1,177

Note: The regulatory limit for effective dose to a nuclear energy worker is 50 mSv/year.

Table J-3 provides average and maximum equivalent dose results for the skin of NEWs, from 2015 to 2019. In 2019, the maximum individual skin dose received by a NEW at PHCF was 20.1 mSv, which is approximately 4% of the CNSC’s regulatory equivalent dose limit of 500 mSv in a 1-year dosimetry period. Average and maximum skin doses over this 5-year period have been relatively steady.

Table J-3: Equivalent (skin) dose statistics for NEWs, PHCF, 2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average skin dose (mSv) 0.8 0.8 0.6 0.7 0.5 N/A
Maximum individual skin dose (mSv) 23.4 16.9 13.7 14.9 20.1 500 mSv/year

mSv = millisievert; N/A = not applicable

Non-NEWs at PHCF

Cameco employees, site visitors and contractors whose work does not require NEW status may be issued whole-body dosimeters and participate in the internal dosimetry program to monitor their radiological exposures while at PHCF. In 2019, the maximum individual effective dose received by a person who is not a NEW was 0.13 mSv, which is well below the CNSC’s regulatory effective dose limit of 1 mSv per calendar year for a person who is not a NEW.

### CFM

Figure J-3 provides the average and maximum effective doses for NEWs at CFM from 2015 to 2019. The maximum individual effective dose received by a NEW in 2019 was 8.4 mSv, which is approximately 17% of the CNSC’s regulatory effective dose limit of 50 mSv in a 1-year dosimetry period. Average and maximum total effective doses over this 5-year period are aligned with the work activities and production levels at CFM.

Figure J-3: Effective dose statistics for NEWs, CFM, 2015 to 2019

Description

Figure J-3: Effective dose statistics for nuclear energy workers, Cameco Fuel Manufacturing Inc., 2015-2019

Dose statistic 2015 2016 2017 2018 2019
Average effective dose (mSv) 1.2 1.0 0.7 1.1 1.1
Maximum effective dose (mSv) 12.6 7.8 6.4 8.0 8.4
Number of nuclear energy workers monitored 336 278 270 267 256

Note: The regulatory limit for effective dose to a nuclear energy worker is 50 mSv/year.

Tables J-4 and J-5 provide average and maximum equivalent dose results for the skin and extremities of NEWs, from 2015 to 2019. In 2019, the maximum skin dose received by a NEW at CFM was 56.9 mSv, which is approximately 11% of the CNSC’s regulatory equivalent dose limit of 500 mSv in a 1-year dosimetry period. The maximum extremity dose received by a NEW at CFM was 90.8 mSv, which is approximately 18% of the CNSC’s regulatory equivalent dose limit of 500 mSv in a 1-year dosimetry period. The average and maximum equivalent doses over this 5-year period have been decreasing. CFM attributes this trend to improvements made to work practices and work areas, such as enclosure of the grinder lines.

Table J-4: Equivalent (skin) dose statistics for NEWs, CFM, 2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average skin dose (mSv) 6.3 6.6 5.5 3.4 3.1 N/A
Maximum individual skin dose (mSv) 95.6 95.7 88.1 59.0 56.9 500 mSv/year

mSv = millisievert; N/A = not applicable

Table J-5: Equivalent (extremity) dose statistics for NEWs, CFM, 2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average extremity dose (mSv) 15.5 13.2 10.6 15.8 18.4 N/A
Maximum individual extremity dose (mSv) 87.0 98.4 59.0 57.1 90.8 500 mSv/year

mSv = millisievert; N/A = not applicable

Non-NEWs at CFM

Visitors and contractors who are not considered NEWs are issued dosimeters to monitor their radiological exposures while at CFM. In 2019, dosimeters issued to non-NEWs showed no measurable doses.

### BWXT

Figure J-4 provides the average and maximum effective doses for NEWs at BWXT’s Toronto facility from 2015 to 2019. The maximum effective dose received by a NEW in 2019 at the Toronto facility was 7.2 mSv, or approximately 14% of the CNSC’s regulatory effective dose limit of 50 mSv in a 1-year dosimetry period.

Figure J-4: Effective dose statistics for NEWs, BWXT Toronto facility, 2015 to 2019

Description

Figure J-4: Effective dose statistics for nuclear energy workers, BWXT Toronto Facility, 2015–19

Dose statistic 2015 2016 2017 2018 2019
Average effective dose (mSv) 2.1 2.2 1.6 1.7 1.6
Maximum effective dose (mSv) 8.4 11.8 8.5 9.2 7.2
Number of nuclear energy workers monitored 69 63 61 58 61

Note: The regulatory limit for effective dose to a nuclear energy worker is 50 mSv/year.

Figure J-5 provides the average and maximum effective doses for NEWs at BWXT’s  Peterborough facility from 2015 to 2019. The maximum effective dose received by a NEW in 2019 at the Peterborough facility was 5.8 mSv, or approximately 12% of the CNSC’s regulatory effective dose limit of 50 mSv in a 1-year dosimetry period.

Figure J-5: Effective dose statistics for NEWs, BWXT Peterborough facility, 2015 to 2019

Description

Figure J-5: Effective dose statistics for nuclear energy workers, BWXT Peterborough Facility, 2015–19

Dose statistic 2015 2016 2017 2018 2019
Average effective dose (mSv) 1.4 1.0 1.0 1.1 1.2
Maximum effective dose (mSv) 5.8 5.8 5.1 6.5 5.8
Number of nuclear energy workers monitored 75 88 77 78 71

Note: The regulatory limit for effective dose to a nuclear energy worker is 50 mSv/year.

Tables J-6 and J-7 provide annual average and maximum equivalent dose results from 2015 to 2019. In 2019, the maximum individual equivalent skin dose at the Peterborough facility was 17.44 mSv, while at the Toronto facility it was 39.76 mSv.

Table J-6: Equivalent (skin) dose statistics for NEWs, BWXT Toronto, 2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average skin dose (mSv) 9.89 10.23 7.85 8.92 8.07 N/A
Maximum individual skin dose (mSv) 54.99 74.26 54.27 58.36 39.76 500 mSv/year

mSv = millisievert; N/A = not applicable

Table J-7: Equivalent (skin) dose statistics for NEWs, BWXT Peterborough,
2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average skin dose (mSv) 4.1 2.66 2.77 2.87 3.00 N/A
Maximum individual skin dose (mSv) 22.47 21.15 25.14 17.87 17.44 500 mSv/year

mSv = millisievert; N/A = not applicable

Tables J-8 and J-9 provide the maximum individual equivalent extremity dose from 2015 to 2019. In 2019, this dose at the Peterborough facility was 29.41 mSv, while at the Toronto facility it was 79.67 mSv.

Table J-8: Equivalent (extremity) dose statistics for NEWs, BWXT Toronto,
2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average extremity dose (mSv) 30.30 29.58 27.36 24.56 20.67 N/A
Maximum individual extremity dose (mSv) 109.62 119.47 115.07 83.33 79.67 500 mSv/year

mSv = millisievert; N/A = not applicable

Table J-9: Equivalent (extremity) dose statistics for NEWs, BWXT Peterborough, 2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average extremity dose (mSv) 12.61 9.78 13.62 14.34 11.30 N/A
Maximum individual extremity dose (mSv) 39.34 32.84 43.18 46.06 29.41 500 mSv/year

mSv = millisievert; N/A = not applicable

These maximum individual equivalent doses for Peterborough (29.41 mSv) and Toronto (79.67) are approximately 8% and 15% (respectively) of the CNSC’s regulatory equivalent dose limit of 500 mSv in a 1-year dosimetry period. Over the past 5 years, average equivalent extremity and skin doses have been relatively stable at both facilities. The reason for the consistently lower skin and extremity doses at the Peterborough facility is the low likelihood of direct pellet handling, as opposed to the Toronto facility, where this practice is considered routine. At the Peterborough facility, except in the end cap welding station, all pellets are shielded in zirconium tubes, bundles or boxes.

Non-NEWs at BWXT

For both the Peterborough and Toronto facilities, non-NEWs and contractors (who are all considered non-NEWs) are not directly monitored. Doses are estimated based on in-plant radiological conditions and occupancy factors, to ensure that radiation doses are controlled well below the CNSC’s regulatory effective dose limit of 1 mSv per calendar year for a person who is not a NEW.

### SRBT

Figure J-6 provides the average and maximum effective doses for NEWs at SRBT from 2015 to 2019. The maximum effective dose received by a NEW in 2019 was 0.57 mSv, approximately 1% of the CNSC regulatory effective dose limit of 50 mSv in a 1-year dosimetry period. There was an increase in both average and maximum effective dose in 2019. This is attributed to 4 instances of elevated exposure for a particular worker over the course of the year, in addition to an increase in processing and 3 special projects. A subsequent investigation into the elevated exposure found it was caused by work practices leading to an increased number of light source breakages. In response, corrective actions were taken to improve the handling of light sources, in order to reduce worker exposures.

Figure J-6: Effective dose statistics for NEWs, SRBT, 2015 to 2019

Description

Figure J-6: Effective dose statistics for nuclear energy workers, SRBT, 2015-2019

Dose statistic 2015 2016 2017 2018 2019
Average effective dose (mSv) 0.07 0.05 0.05 0.04 0.07
Maximum effective dose (mSv) 0.87 0.34 0.46 0.48 0.57
Number of nuclear energy workers monitored 47 45 45 47 45

Note: The regulatory limit for effective dose to a nuclear energy worker is 50 mSv/year.

Due to the uniform distribution of tritium in body tissues, equivalent skin doses are essentially the same as the effective whole-body dose and are therefore not reported separately. For the same reason, extremity doses are not separately monitored for workers at SRBT.

Non-NEWs at SRBT

Contractors are not generally identified as NEWs because they do not perform radiological work. However, their radiological exposures are monitored while they are at the SRBT facility to ensure that their doses remain ALARA and below the CNSC regulatory dose limit of 1 mSv/year for a person who is not a NEW. In 2019, no contractors received a recordable dose that resulted from work activities performed at the facility.

### Nordion

Figure J-7 provides the average and maximum effective doses to NEWs at Nordion from 2015 to 2019. Nordion reported that the maximum effective dose received by a NEW in 2019 was 4.79 mSv, approximately 9.6% of the CNSC’s regulatory effective dose limit of 50 mSv in a 1-year dosimetry period. Average and maximum effective doses have been relatively stable over these years.

Figure J-7: Effective dose statistics for NEWs, Nordion, 2015 to 2019

Description

Figure J-7: Effective dose statistics for nuclear energy workers, Nordion, 2015-2019

Dose statistic 2015 2016 2017 2018 2019
Average effective dose (mSv) 0.39 0.49 0.42 0.45 0.48
Maximum effective dose (mSv) 5.24 4.90 5.49 4.23 4.79
Number of nuclear energy workers monitored 264 267 263 248 278

Note: The regulatory limit for effective dose to a nuclear energy worker is 50 mSv/year.

Tables J-10 and J-11 shows annual average and maximum equivalent (extremity) and equivalent (skin) dose results from 2015 to 2019. Nordion reported that the maximum equivalent skin dose for all NEWs monitored at Nordion in 2019 was 4.78 mSv (table J‑10), and that the maximum equivalent extremity dose for a worker in the active area was 20.93 mSv (table J-11). These doses represent approximately 1% and 4% respectively of the CNSC’s regulatory equivalent dose limits of 500 mSv in a 1-year dosimetry period. The maximum extremity dose was received by a worker during a cobalt hot cell manipulator change.

Table J-10: Equivalent (skin) dose statistics for NEWs, Nordion, 2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average skin dose (mSv) 0.42 0.59 0.42 0.45 0.49 N/A
Maximum individual skin dose (mSv) 5.24 5.20 5.52 4.26 4.78 500 mSv/year

mSv = millisievert; N/A = not applicable

Table J-11: Equivalent (extremity) dose statistics for NEWs, Nordion, 2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average extremity dose (mSv) 0.46 0.79 0.53 0.96 1.14 N/A
Maximum individual extremity dose (mSv) 9.3 8.3 16.4 9.08 20.93 500 mSv/year

mSv = millisievert; N/A = not applicable

Note: Only the workers who routinely work in the active area are monitored for extremity dose.

Non-NEWs at Nordion

Nordion also identifies non-NEWs who may enter the active area but do not perform any radiological work. Nordion monitors non-NEWs as required and provides relevant training to ensure that their doses are kept ALARA. In 2019, Nordion monitored 125 non-NEWs, an increase from previous years. The large increase of monitored non-NEWs is due to construction activities in the medical isotope facility. Nordion reported that the maximum effective dose received by a non-NEW was 0.26 mSv, which is well below the CNSC’s regulatory effective dose limit of 1 mSv in a calendar year for a person who is not a NEW. The average effective dose for non-NEWs in 2019 was 0.03 mSv.

### BTL

At BTL, employees are classified as nuclear energy workers (NEWs) if they are expected to have a reasonable probability of receiving an occupational dose greater than 1 mSv. Doses for employees performing work under the Class IB licence are reported below. Doses for Class II servicing employees are reported separately in the annual compliance reports associated with BTL’s Class II servicing licences. Figure J-8 provides the average and maximum effective doses for NEWs at BTL from 2015 to 2019. In 2019, the maximum effective dose received by a NEW at BTL under the Class IB licence was 1.0 mSv, or approximately 2% of the CNSC’s regulatory effective dose limit of 50 mSv in a 1-year dosimetry period. Over the past 5 years, annual effective doses at BTL have remained stable and very low.

Figure J-8: Effective dose statistics for NEWs, BTL, 2015 to 2019

Description

Figure J-8: Effective dose statistics for nuclear energy workers, BTL, 2015-2019

Dose statistic 2015 2016 2017 2018 2019
Average effective dose (mSv) 0.01 0.03 0.02 0.16 0.04
Maximum effective dose (mSv) 0.20 0.98 0.47 8.65 1.00
Number of nuclear energy workers monitored 62 60 68 68 68

Note: The regulatory limit for effective dose to a nuclear energy worker is 50 mSv/year.

The higher-than-normal maximum effective and equivalent extremity doses in 2018 were due to an event that resulted in an action level exceedance. Table J-12 provides annual average and maximum equivalent extremity dose results from 2015 to 2019. The maximum equivalent extremity dose in 2019 was 2.51 mSv, which is approximately 0.5% of the CNSC’s regulatory equivalent dose limit of 500 mSv. Over the past 5 years, average extremity equivalent doses have remained very low, between approximately 0 mSv and 2 mSv.

Table J-12: Equivalent (extremity) dose statistics for NEWs, BTL, 2015 to 2019

Dose data 2015 2016 2017 2018 2019 Regulatory limit
Average extremity dose (mSv) 0.00 0.09 0.07 1.41 0.22 N/A
Maximum individual extremity dose (mSv) 0.00 1.1 0.5 13.51 2.51 500 mSv/year

mSv = millisievert; N/A = not applicable

Equivalent skin doses are ascertained; however, due to the nature of exposure, they are essentially equal to the effective dose and are not included in this report.

Non-NEWs at BTL

BTL workers identified as non-NEWs, such as administrative staff, are not permitted in controlled areas, and are therefore not occupationally exposed to radiation.

## K. Health and safety data

Table K-1: Lost-time injury statistics, uranium and nuclear substance processing facilities, 2015 to 2019

Facility Statistic 2015 2016 2017 2018 2019

BRR

LTI1 0 0 0 0 0
Severity rate2 0 0 0 0 0
Frequency rate3 0 0 0 0 0

PHCF

LTI 1 4 1 2 0
Severity rate 7.64 2.40 1.67 7.58 0
Frequency rate 0.26 0.80 0.28 0.49 0

CFM

LTI 1 0 0 0 0
Severity rate 0.6 0 0 0 0
Frequency rate 0.6 0 0 0 0

BWXT

LTI 0 0 0 0 0
Severity rate 0 0 0 0 0
Frequency rate 0 0 0 0 0

SRBT

LTI 0 0 3 0 0
Severity rate 0 0 17.7 0 0
Frequency rate 0 0 7.6 0 0

Nordion

LTI 0 3 1 0 2
Severity rate 0 70.04 5.61 0 4.15
Frequency rate 0 2.32 0.93 0 0.69

BTL

LTI 1 3 1 2 2
Severity rate 0.68 37.61 15.04 8.21 5.47
Frequency rate 0.68 2.05 0.68 1.37 1.37

1 An LTI is an injury that takes place at work and results in the worker being unable to return to work for a period of time.

2 The accident severity rate measures the total number of days lost to injury for every 200,000 person-hours worked at the site. Severity = [(# of days lost in last 12 months) / (# of hours worked in last 12 months)] x 200,000.

3 The accident frequency rate measuring the number of LTIs for every 200,000 person-hours worked at the site. Frequency = [(# of injuries in last 12 months) / (# of hours worked in last 12 months)] x 200,000.

Table K-2: LTIs, Nordion, 2019

LTI Action taken by licensee
An employee sustained a low back injury when trying to open double lead doors on cell 34. The employee was pulling the doors with force on several attempts and the door would not open (issue with doors). The injury resulted in 5 days’ lost time. Nordion investigated the incident and determined that the door status was in a “fault condition” which would not allow the door to open. Technicians are now required to verify the status of cell doors before attempting to open them.
An employee incurred lower back pain when removing wood bracing from the ground of a sea crate container. This was a routine task. The injury resulted in 7 days’ lost time. Nordion will no longer be removing the blocking and bracing from the ocean containers. Blocking and bracing materials will remain in the containers once the Nordion flasks are removed, with the trucking company now responsible for removing the blocking and bracing materials.

Table K-3: LTIs, BTL, 2019

LTI Action taken by licensee
A worker strained their back when physically moving wooden ramps to a loading dock instead of using the overhead crane. The individual was reminded to not lift the loading ramps without the use of the overhead crane.
A worker cut their hand while working on a product that was not deburred. The individual was reminded to deburr all sharp edges prior to working on them.

## L. List of identified Indigenous groups with an interest in uranium and nuclear substance processing facilities

Blind River area (Cameco Blind River Refinery (BRR))

• Atikameksheng Anishnawbek First Nation
• Mississauga First Nation (MFN)
• Sagamok Anishnawbek Nation (SAN)
• Serpent River First Nation (SRFN)
• Thessalon First Nation (TFN)
• Métis Nation of Ontario (MNO) (Region 4)

Facilities in Port Hope, Toronto and Peterborough areas (Cameco Port Hope Conversion Facility (PHCF), Cameco Fuel Manufacturing facility (CFM), and BWXT Nuclear Energy Canada Inc. facilities in Toronto and Peterborough)

• Williams Treaties First Nations (WTFN), which include Alderville First Nation (AFN), Curve Lake First Nation (CLFN), Hiawatha First Nation (HFN), the Mississaugas of Scugog Island First Nation (MSIFN), the Chippewas of Beausoleil First Nation (CBFN), the Chippewas of Georgina Island First Nation (CGIFN) and the Chippewas of Rama First Nation (CRFN)
• Mississaugas of the Credit First Nation (MCFN)
• Métis Nation of Ontario (MNO) (Region 8)
• Mohawks of the Bay of Quinte (MBQ)

Ottawa Valley facilities (SRB Technologies Inc. (SRBT), Nordion Canada Inc., and Best Theratronics Limited (BTL))

• Algonquins of Ontario (AOO)
• Algonquins of Pikwàkanagàn First Nation (APFN)
• Kitigan Zibi Anishinabeg
• Algonquin Anishinabeg Nation Tribal Council (AANTC)
• Kebaowek First Nation
• The Algonquin Nation Secretariat
• Métis Nation of Ontario (MNO) (Regions 5 and 6)

## M. Fact sheet – Licensed Limits for Releases to the Environment

### Licensed Limits for Releases to the Environment

July 2020

What are licensed limits?

A licensed limit is a value or condition that, if exceeded, indicates that the licensee is operating outside of its licensing basis during normal operations and is not in compliance. The licensing basis is the set of requirements and documents for a regulated facility or activity, including:

• the regulatory requirements
• the safety and control measures described in the facility’s or activity’s licence and the documents referenced in that licence
• the safety and control measures described in the licence application and the supporting documents

Licensed limits for releases to the environment are one such requirement.

What are licensed limits for releases?

The Canadian Nuclear Safety Commission (CNSC) ensures that licensed limits for releases are included in CNSC licences, in order to protect human health and the environment, confirm that pollution prevention and control technologies are implemented, drive continuous improvement and verify that the licensee is operating within its approved licensing basis. Two types of licensed limits for releases are implemented at CNSC-regulated facilities: exposure-based and technology-based. Exposure-based limits ensure that releases do not exceed levels that are protective of people and the environment. Technology-based limits ensure that licensees are implementing the best available pollution prevention technologies and techniques.

Do CNSC staff review and accept licensed limits for releases?

CNSC staff provide guidance to licensees on how to derive licensed limits for releases and how to determine which contaminants require them. Before these limits for releases become part of the licensing basis, CNSC staff review them to verify that they are protective of human health and the environment.

Furthermore, as stipulated in some licences, certain licensees are required to periodically update their licensed limits. This update can be triggered by new scientific information, operational changes or new regulatory/licence requirements. CNSC staff also review and approve updated licensed limits for releases.

How do CNSC staff verify that licensees are in compliance with their licensed limits for releases?

Licensees of Class I nuclear facilities are required to submit data, in their quarterly and/or annual compliance reports, for both radiological and hazardous (non-radiological) releases to the environment. CNSC staff review these results and verify that the corresponding licensed limits have not been exceeded. CNSC staff also perform environment-focused inspections at nuclear facilities and review effluent data to ensure that the licensees are in compliance with their licensed limits for releases.

As part of section 29(1)(c) of the General Nuclear Safety and Control Regulations, licensees are required to immediately submit a preliminary report once they become aware of a release into the environment of a nuclear substance that is above the licensed limit.

How are licensed limits for releases determined?

Exposure-based licensed limits for releases are established with the objective of ensuring that releases to the receiving environment do not exceed levels that are protective of people and the environment. For example, a derived release limit (DRL) is determined using site-specific information to calculate the level of a nuclear or hazardous substance that would be harmful. This limit ensures that this level is not exceeded. (See next section for more details on DRLs.)

Technology-based licensed limits for releases are based on what is achievable by the best available pollution prevention technologies and techniques. A technology-based licensed limit can be sector specific (based on pollution prevention technology and best practices common in an industry sector) or case specific (based on the pollution prevention technology and administrative practices in place at a specified facility).

The licensee proposes which of the approaches it will use to calculate its licensed limits for releases. For either approach, the licensee must demonstrate that these proposed licensed limits respect the regulatory public dose limit and are protective of human health or the environment.

What are derived release limits?

For nuclear substances released from Class I nuclear facilities, the CNSC’s licensed limits are DRLs. A DRL is an exposure-based licensed limit that ensures members of the public do not receive radiation doses that would be harmful. For most facilities, the DRL is based on a most-exposed person receiving a radiological dose of 1 mSv/yr from radiological releases of a facility during normal operations. This most-exposed person is a person who would have a higher dose than the average member of the public due to a combination of factors, such as location, lifestyle and food consumption. This person is determined from site-specific surveys and can be based on an actual or hypothetical person. The dose of 1 mSv/yr is the annual dose limit established in the Radiation Protection Regulations.

Some facilities use a lower radiological dose, known as a dose constraint, to determine a DRL. A dose constraint is still an estimate of the dose received by a most‑exposed person, but based on a dose that is less than 1 mSv/yr. If the most-exposed person’s dose is below that limit, then all members of the public will also have doses below it. The purpose of a dose constraint is to ensure that the sum of all doses from multiple nuclear activities in a region is less than 1 mSv/yr. This means that the DRL itself would be based on a dose that is less than 1 mSv/yr.

Based on recommendations from the Integrated Regulatory Review Service (IRRS), CNSC staff will be adding dose constraints to radiological releases. More information on dose constraints will be documented in draft REGDOC-2.9.2, Controlling Releases to the Environment from Nuclear Facilities, which is scheduled for public consultation in late 2020.

How are DRLs calculated?

The DRL is derived using the methodology and calculations published in CSA N288.1, Guidelines for Calculating Derived Release Limits for Radioactive Material in Airborne and Liquid Effluents for Normal Operation of Nuclear Facilities. CSA N288.1 is a model that describes the transfer of radioactive materials through the environment to humans. DRLs are calculated separately for releases to air and to surface water.

The first step in the process is to identify all of the radionuclides released in air and liquid. Then, the exposure pathways and most-exposed person(s) are identified from site-specific surveys. An exposure pathway is a route by which a person can be exposed to radiation. Examples of exposure pathways include ingestion and inhalation. The DRL for a radionuclide is calculated by dividing the annual dose limit to the public of 1 mSv/yr (or the dose constraint) by the sum of all doses from that radionuclide through the exposure pathways. For airborne releases, an atmospheric dispersion model is used to determine how much radioactivity from the source radionuclide is transferred to a most-exposed person through the atmosphere. For releases to surface water, an aquatic dispersion model is used to determine how much radioactivity from the source radionuclide is transferred to a most-exposed person through water. DRLs are calculated for all of the identified most-exposed person(s) and are calculated separately for different age classes (e.g., infant, child and adult).

What other types of licensed limits for releases exist?

There are other federal, provincial and territorial limits for releases to the environment. Federally, the Metal and Diamond Mining Effluent Regulations and Wastewater Systems Effluent Regulations apply to uranium mines. Provincially and territorially, there are permits or approvals for releases to the environment. Municipalities have sewer bylaws. Licensees are required to meet all of these regulations, approvals and/or bylaws that apply to their operations.

When establishing licensed limits for releases, the CNSC recommends that licensees harmonize with available federal, provincial, territorial and/or municipal requirements that the CNSC considers adequately protective of the environment. For example, for the uranium mines and mills, the CNSC adopted authorized effluent discharge limits from Schedule 4 of the Metal and Diamond Mining Effluent Regulations that are established under the Fisheries Act. These limits are technology-based release limits that were derived considering the best available pollution prevention technologies and techniques economically achievable at the time. These limits are specific to the metal mining industry.

What happens if a licensed limit is exceeded? Is there any risk to the public or to the environment?

Exceeding a licensed limit represents a loss of control of part of the licensee’s programs or control measures. Hence, it is an indication that the licensee is operating outside of its licensing basis during normal operations. However, it does not necessarily imply an unreasonable risk to the environment, to the health and safety of persons or to national security; that is, it does not mean that actual harm will come about.

Most technology-based release limits and exposure-based release limits are set below levels required to protect human health and the environment. For this reason, exceeding a limit does not necessarily imply that either the health of the public or an ecosystem is at risk, but the exceedance triggers a requirement for the licensee to take specific actions, such as mitigation measures, to restore the effectiveness of the program, and increase downstream monitoring to demonstrate that the environment is protected. An exceedance of a DRL indicates that the facility has exposed a member of the public to a dose greater than the regulatory annual dose limit and will be subject to regulatory action.

Quick facts

• The CNSC establishes licensed limits for releases to the environment to protect human health and the environment
• Effluent monitoring programs are implemented at CNSC-licensed facilities to ensure that releases to the environment are below licensed limits
• CNSC staff review licensed limits before they are accepted in a licence, to verify that they are protective of human health and the environment
• A derived release limit (DRL) is a sub-type of licensed limit that applies to radiological substances and is based on an individual receiving a dose of 1 millisievert (mSv) per year
• The CNSC recommends that licensees harmonize licensed limits for releases with those from other federal/provincial/territorial requirements that the CNSC considers protective
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