# Regulatory Oversight Report for Uranium and Nuclear Substance Processing Facilities in Canada: 2017

2017 regulatory oversight report for uranium and nuclear processing facilities (PDF, 175 pages, 4.24 MB)

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## Executive summary

Each year, the Canadian Nuclear Safety Commission (CNSC) presents the Regulatory Oversight Report for Uranium and Nuclear Substance Processing Facilities in Canada to the Commission. The report outlines the safety performance of uranium and nuclear substance processing facilities in Canada for the 2017 calendar year and, where applicable, includes trends and comparisons with results in previous years.

The report focuses on three safety and control areas (SCAs), specifically radiation protection, environmental protection and conventional health and safety, since, taken together, these SCAs provide a meaningful overview of the safety performance of the facilities addressed in this report. The report includes ratings for each of the 14 SCAs and highlights licensees’ public information programs, engagement with Indigenous groups and communities, reportable events, significant facility modifications and areas of increased regulatory focus.

To assess the safety performance of licensees, the CNSC conducts regulatory oversight activities including onsite inspections, reviews of reports submitted by licensees, reviews of events and incidents, and general communication and exchanges of information with licensees. CNSC staff confirm that, in 2017, the uranium and nuclear substance processing facilities in Canada continued to operate safely. With one exception, the performance of all uranium and nuclear substance processing facilities was rated as “satisfactory” or better for all 14 SCAs.

The one exception was a “below expectations” rating for the management system SCA for the Cameco Port Hope Conversion Facility (PHCF), due to deficiencies identified in the PHCF’s management system following a release event in 2017. Over an unspecified time, Cameco failed to verify whether work was being performed correctly and according to approved procedures as outlined in the Cameco PHCF licence conditions handbook. To deter recurrence and promote future compliance, a CNSC designated officer issued an administrative monetary penalty to Cameco.

Overall, CNSC staff’s compliance activities determined that:

• radiation protection programs at all facilities adequately controlled radiation exposures, keeping doses as low as reasonably achievable (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
• programs in support of remaining SCAs required to ensure that the protection of the health and safety of workers, the public and the environment continued to be effectively implemented

Therefore, CNSC staff concluded that, in 2017, the licensees covered in this report made adequate provision for the health and safety of workers as well as the protection of the public and the environment, and for meeting Canada’s international obligations on the peaceful use of nuclear energy.

The full report is available on the CNSC public 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

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## 1 Overview

The Canadian Nuclear Safety Commission (CNSC) regulates the use of nuclear energy and materials to protect health, safety, security and the environment, implements Canada’s international commitments on the peaceful use of nuclear energy, and disseminates 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.

CNSC staff report to the Commission annually on the safety performance of the uranium and nuclear substance processing facilities in Canada regulated by the CNSC in the form of a regulatory oversight report. The 2017 report contains information on the licensees’ compliance with the legal requirements of the Nuclear Safety and Control Act (NSCA) Footnote 1 and its associated regulations made under the NSCA, as well as with each facility’s licence conditions handbook (LCH) and any other applicable standards and regulatory documents.

The information provided in this report covers the 2017 calendar year and, where applicable, includes trends and comparisons with previous years. The report focuses on three SCAs – radiation protection, environmental protection, and conventional health and safety – as they provide a good overview of the safety performance for the facilities. In addition, the document highlights a discussion of licensee’s public information programs, engagement with Indigenous groups and communities, ratings for all 14 SCAs, reportable events and incidents, any significant facility modifications, and areas of increased regulatory focus.

In addition, the report includes a list of references, a list of acronyms and their definitions, a glossary and 11 appendices. Appendices A, B and C provide general information on the CNSC’s regulatory oversight of uranium and nuclear substance processing facilities in Canada, while appendix D presents the financial guarantee amounts for each facility. Appendices E, F, G and H outline the performance data for each facility regarding radiation protection, environmental monitoring and releases, and health and safety data, including annual trends. New to this year’s report is appendix G, which provides the total annual releases of radionuclides for each facility during 2017. Appendix I lists the licensees’ websites and appendix J summarizes any significant changes made to the licences and LCHs in 2017. Appendix K provides a list of all compliance verification inspections conducted during the calendar year for each facility.

### 1.1 Canada’s uranium and nuclear substance processing facilities

This report summarizes the CNSC staff assessment of the safety performance of the following licensees, all of which are located in the province of Ontario:

• Uranium processing facilities
• Cameco Corporation Blind River Refinery (BRR) in Blind River (FFOL-3632.00/2022)
• Cameco Corporation Port Hope Conversion Facility (PHCF) in Port Hope (FFOL-3631.00/2027)
• Cameco Fuel Manufacturing Inc. (CFM) in Port Hope (FFOL-3641.00/2022)
• BWXT Nuclear Energy Canada Inc. (formerly GE Hitachi Nuclear Energy Canada Inc.) in Toronto (BWXT Toronto) (FFOL-3620.01/2020)
• BWXT Nuclear Energy Canada Inc. (formerly GE Hitachi Nuclear Energy Canada Inc.) in Peterborough (BWXT Peterborough) (FFOL-3620.01/2020)
• Nuclear substance processing facilities
• SRB Technologies (Canada) Inc. (SRBT) in Pembroke (NSPFOL-13.00/2022)
• Nordion (Canada) Inc. (Nordion) in Ottawa (NSPFOL-11A.00/2025)
• Best Theratronics Ltd. (BTL) in Ottawa (NSPFOL-14.01/2019)

### 1.2 Regulatory oversight

The CNSC regulates Canada’s uranium and nuclear substance processing facilities through licensing, reporting, verification and enforcement activities. For each facility, CNSC staff conduct onsite inspections, assessments, reviews and evaluations of licensee programs, processes and safety performance reports. The CNSC uses a risk-informed approach when conducting regulatory oversight activities. The purpose is to ensure that resources are appropriately allocated and controls are applied based on the complexity of the facility, as well as the hazards and magnitude of the potential risks associated with the activities at the facility.

To ensure that each licensee is operating safely, CNSC staff apply a risk-informed approach to the compliance oversight of a facility. CNSC staff establish compliance plans for each facility, determining the type and level of review, inspection and testing to be conducted in a manner that is consistent with the potential risks posed by the regulated activities.

CNSC staff continuously review compliance plans to take into consideration the complexity of the facility, the hazards and magnitude of the potential risks associated with the activities at the facility, events, facility modifications, changes in licensee performance and lessons learned.

In 2017, CNSC staff conducted 29 onsite inspections at uranium and nuclear substance processing facilities in Canada. The inspections covered various aspects of the SCAs. A breakdown of the number of inspections is provided in each industry’s respective section (chapters 2 and 7) and summarized in appendix K.

While some inspections focus on specific SCAs, CNSC inspectors strive to ensure that they cover aspects of the radiation protection, environmental protection, and conventional health and safety SCAs in every inspection. This is done to continually ensure that:

• radiation protection measures are effective and radiation doses to workers remain ALARA, taking into account social and economic factors
• the environmental protection programs are effective and releases are controlled and remain ALARA
• the conventional health and safety programs continue to protect workers from injuries and accidents

CNSC staff also verify compliance through desktop reviews of reports and licensee programs. They further supplement compliance verification activities through presentations, facility visits and meetings with the licensees.

### 1.3 Safety and Control Area Framework

CNSC staff use the SCA Framework in evaluating the safety performance of each licensee. The framework includes 14 SCAs, each subdivided into specific areas that define its key components. Appendix A lists all the SCAs and specific areas used in this report.

CNSC staff assess licensee performance in each applicable SCA according to the following four ratings:

• fully satisfactory (FS)
• satisfactory (SA)
• below expectations (BE)
• unacceptable (UA)

Full definitions of the four ratings are provided in appendix B. Ratings are listed for each applicable SCA. The ratings are derived from the compliance activities that CNSC staff conduct in the various SCAs.

A licensee’s performance is measured by its ability to minimize all risks posed by the licensed activity and to comply with all regulatory requirements. CNSC staff continually assess performance in each SCA. It is important to understand that each SCA is evaluated individually and every facility has different inputs into the annual rating for a specific SCA. For example, a rating may not have an input from onsite inspections if no onsite inspections were conducted for that SCA during the year. In these cases, the CNSC staff rating input consists of the information provided in CNSC staff’s desktop review and evaluation of licensees’ annual compliance reports.

The three SCAs focused on in this report – radiation protection, environmental protection, and conventional health and safety – include key metrics to demonstrate a 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).

### 1.4 CNSC Independent Environmental Monitoring Program

Under the NSCA, the CNSC stipulates that the licensee of each nuclear facility shall develop, implement and maintain an environmental monitoring program to demonstrate that the public and the environment are protected from emissions due to the licensee’s licensed activities. The licensees submit the results of these monitoring programs to the CNSC to ensure compliance with applicable guidelines and limits, as set out in the applicable regulations.

The CNSC implements its Independent Environmental Monitoring Program (IEMP) to verify that the public and the environment around licensed nuclear facilities are protected. The IEMP is a regulatory tool that complements the CNSC’s ongoing compliance verification program. The IEMP involves taking samples from public areas around the facilities, then measuring and analyzing the amounts of radioactive and hazardous substances in those samples and comparing the results against relevant guidelines, limits and objectives.

In 2017, CNSC staff conducted independent environmental monitoring at BRR, PHCF and CFM. The 2017 IEMP results, which are posted on the CNSC’s IEMP Web page, demonstrate that the public and the environment around these facilities are protected, and that there are no expected adverse environmental or health effects as a result of site operations.

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.

### 1.5 Indigenous and community engagement

The CNSC is committed to ongoing engagement and relationship building with interested Indigenous communities. In this regard, Indigenous communities with interest in Canada’s uranium and nuclear substance processing facilities were provided a copy of this report. Through its Participant Funding Program (PFP), the CNSC also made available financial support for participation in the review of this report. In addition, during 2017, CNSC staff provided interested Indigenous communities with updates on sampling campaigns under the IEMP at uranium and nuclear substance processing operations.

In 2017, uranium and nuclear processing facility licensees began, continued, or strengthened communications and engagement activities with Indigenous communities and organizations interested in their facilities. Activities included meetings with Indigenous leaders, facility tours, financial and volunteer support for sporting and cultural events, and community forum invites. CNSC staff and licensees also responded in writing to issues of interest or concern raised by the Algonquins of Ontario (AOO) in their intervention to the Commission in relation to the Regulatory Oversight Report for Uranium and Nuclear Substance Processing Facilities in Canada: 2016. The AOO was the only Indigenous group that submitted an intervention.

CNSC staff continue to ensure that each licensee’s communications and engagement activities with Indigenous communities are consistent and appropriate. CNSC staff also continue to develop a structured, formalized approach to ensure routine engagement and information sharing with all interested Indigenous communities and organizations in relation to the CNSC-regulated facilities.

More detailed information on the licensees’ activities relating to Indigenous communities and organizations can be found in the facility-specific performance sections.

### 1.6 Overall conclusions

CNSC staff concluded that uranium processing facilities and nuclear substance processing facilities in Canada operated safely during the 2017 calendar year. This assessment is based on CNSC staff’s verification of licensee activities that included onsite inspections, reviews of reports submitted by licensees, and reviews of events and incidents, supported by follow-up and ongoing communications with the licensees.

In 2017, the performance ratings in all 14 SCAs for the facilities were as follows:

• with the exception of a “below expectations” rating for the management system SCA for the PHCF, uranium processing facilities were rated as “satisfactory” or better
• nuclear substance processing facilities were rated as “satisfactory” or better

CNSC staff’s compliance 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

Through their regulatory oversight activities, CNSC staff confirmed that Canada’s uranium and nuclear substance processing facilities continued to operate safely throughout 2017. Appendix B includes a definition of the rating methodology and ratings.

CNSC staff concluded that, in 2017, the licensees covered in this report made adequate provision for the health and safety of workers as well as 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.

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# Part I: Uranium processing facilities

## 2 Overview

This part of the report focuses on the five uranium processing facilities in Canada, all of which are located in the province of Ontario:

• Cameco Corporation Blind River Refinery (BRR) in Blind River
• Cameco Corporation Port Hope Conversion Facility (PHCF) in Port Hope
• Cameco Fuel Manufacturing Inc. (CFM) in Port Hope
• BWXT Nuclear Energy Canada Inc. facility in Toronto (BWXT Toronto)
• BWXT Nuclear Energy Canada Inc. facility in Peterborough (BWXT Peterborough)

All five facilities are shown in figure 2-1. Cameco’s PHCF operating licence was renewed in March 2017 and expires in February 2027. The licences for the BRR and CFM facilities were issued in March 2012 and will expire in February 2022. The two BWXT facilities operate under a combined licence that was issued in December 2016 and expires in December 2020.

Figure 2-1: Location of uranium processing facilities in Ontario, Canada

CNSC staff conducted risk-informed regulatory oversight activities at Canada’s uranium processing facilities in 2017. Table 2-1 presents the licensing and compliance efforts from CNSC staff for these facilities throughout 2017.

Table 2-1: CNSC regulatory oversight licensing and compliance activities, uranium processing facilities, 2017
Facility Number of onsite inspections Person-days for compliance Person-days for licensing activities
BRR 4 223 16
PHCF 5 301 23
CFM 4 295 11
BWXT Toronto and Peterborough 5 214 78

In 2017, CNSC staff performed 18 onsite inspections at Canada’s uranium processing facilities. All the findings resulting from these onsite inspections were provided to the licensees in detailed inspection reports. All resulting regulatory enforcement actions were recorded in the CNSC Regulatory Information Bank to ensure that they are tracked to completion. Appendix K lists the CNSC inspections conducted for each facility in 2017.

In accordance with the licence and respective LCH, all uranium processing facility licensees must submit annual compliance reports on the operations of their respective facilities by March31 every year. These reports to the CNSC must contain facility performance information, such as annual production volumes; improvements to programs in all SCAs; and details related to environmental, radiological and safety performance, including any events and associated corrective actions. CNSC staff review these reports as part of routine regulatory compliance oversight (for example, desktop reviews) to verify that licensees are complying with regulatory requirements and are operating safely. The full versions of these reports are available on the licensees’ websites, as listed in appendix I of this report.

Table 2-2 presents the SCA performance ratings for the uranium processing facilities. For 2017, CNSC staff rated all but two of the SCAs as “satisfactory”. The exceptions were:

• BRR’s performance in the conventional health and safety SCA, which was rated as “fully satisfactory”
• PHCF’s performance in the management systems SCA, which was rated as “below expectations”

Additional information about these SCA ratings can be found in the facility-specific sections. Appendix C contains the SCA ratings from 2013 to 2017 for each facility.

Table 2-2: SCA performance ratings, uranium processing facilities, 2017
SCA BRR PHCF CFM BWXT Toronto and Peterborough
Management system SA BE SA SA
Human performance management SA SA SA SA
Operating performance SA SA SA SA
Safety analysis SA SA SA SA
Physical design SA SA SA SA
Fitness for service SA SA SA SA
Radiation protection SA SA SA SA
Conventional health and safety FS SA SA SA
Environmental protection SA SA SA SA
Emergency management and fire protection SA SA SA SA
Waste management SA SA SA SA
Security SA SA SA SA
Safeguards and non-proliferation SA SA SA SA
Packaging and transport SA SA SA SA

FS = fully satisfactory; BE = below expectations; SA = satisfactory

The CNSC requires licensees to develop and maintain preliminary decommissioning plan for each of their respective facilities, which CNSC staff review and approve. Each plan is accompanied by a financial guarantee that provides the necessary funding to complete the future decommissioning work. In accordance with the NSCA, the financial guarantees must be acceptable to the Commission. Appendix D lists the current financial guarantee amounts for each facility discussed in this report.

The radiation protection SCA covers the implementation of a radiation protection program in accordance with the Radiation Protection Regulations Footnote 2 . The program must ensure that contamination levels and radiation doses received by individuals are monitored, controlled and maintained ALARA.

This SCA encompasses the following specific areas:

• application of ALARA
• worker dose control
• estimated dose to the public

Based on regulatory oversight activities, CNSC staff rated the performance of the uranium processing facilities for the radiation protection SCA as “satisfactory” in 2017, unchanged from the previous year.

Ratings for the radiation protection SCA, uranium processing facilities, 2017
BRR PHCF CFM BWXT Toronto and Peterborough
SA SA SA SA

SA = satisfactory

#### Application of ALARA

During 2017, all uranium 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 and the expected magnitude of doses received by workers. Taking into consideration the inherent differences in the design of radiation protection programs among licensees, the dose statistics provided in this report are primarily for NEWs. Additional information on the total number of monitored persons, including workers, contractors and visitors, is provided in the facility-specific sections.

The maximum and average effective doses for NEWs at uranium processing facilities are shown in figure 2-2. In 2017, the maximum individual effective dose received by a NEW at all facilities ranged from 3.3 millisieverts (mSv) to 8.5mSv, which is well below the regulatory dose limit set at 50 mSv in any one year and 100 mSv in five consecutive years for a NEW. These results are further discussed in the respective sections for each facility.

Description
Figure 2-2: Average and maximum effective doses to NEWs, uranium processing facilities, 2017
Cameco BRR Cameco PHCF CFM BWXT Peterborough BWXT Toronto
Average effective dose (mSv) 0.9 0.4 0.7 1.0 1.6
Maximum effective dose (mSv) 3.3 3.9 6.4 5.1 8.5

During 2017, all licensees of uranium 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. 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, since radiological hazards differ across these facilities due to complex and varying work environments.

CNSC staff conducted regulatory oversight activities at all uranium processing facilities during 2017 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 action to restore the effectiveness of the radiation protection program. It is important to note that occasional 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 which 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.

In 2017, there were two radiological action level exceedances across all uranium processing facility licensees. The exceedances were at the BRR and CFM facilities, and are further discussed in sections 3.2 and 5.2. Cameco reported the action level exceedances to the CNSC, investigated the exceedances and established corrective actions to the satisfaction of CNSC staff.

CNSC staff verified that, in 2017, all uranium 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. All these licensees continued to implement their workplace monitoring programs to protect workers. The licensees have also demonstrated that levels of radioactive contamination were controlled within their facilities throughout the year.

#### Estimated dose to the public

The maximum dose to the public from licensed activities at each uranium processing facility is calculated by using monitoring results from air emissions, liquid effluent releases and fenceline gamma monitoring. The CNSC’s requirement to apply the ALARA principle ensures that licensees monitor their facilities and keep doses to the public below the annual public dose limit of 1 mSv/year.

Table 2-3 compares estimated public doses from 2013 to 2017 for the uranium processing facility licensees. Estimated doses to the public from all these licensees continued to be well below the regulatory annual public dose limit of 1mSv/year.

Table 2-3: Public dose comparison table (mSv), uranium processing facilities, 2013–17
Facility 2013 2014 2015 2016 2017 Regulatory Limit
BRR 0.012 0.005 0.005 0.005 0.005 1 mSv/year
PHCF 0.021 0.012 0.006 0.020 0.153*
CFM 0.013 0.018 0.025 0.023 0.022
BWXT Toronto 0.0006 0.0055** 0.010 0.0007 0.0175
BWXT Peterborough <0.001 <0.001 <0.001 <0.001 <0.001

*In 2016, the 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 look higher than in previous years’, but there has not been an actual increase in emissions/dose from the PHCF. The results actually represent a much more conservative estimate of dose to the public. This is because gamma monitoring at the facility fenceline has now been added to the calculations. As such, the results beginning in 2017 cannot be compared with previous years’ results. See section 4.2 for more information.

**In 2014, GE Hitachi Nuclear Energy Canada Inc. (GEH-C) (now BWXT) Toronto started to use licensed dosimeters to monitor environmental gamma exposure and to include this result in its estimated annual public dose.

CNSC staff concluded that, in 2017, the uranium processing facility licensees effectively implemented and maintained their radiation protection programs, to ensure the health and safety of persons working in their facilities.

### 2.2 Environmental protection

The environmental protection SCA covers programs that identify, control and monitor all releases of radioactive and hazardous substances and the effects on the environment from facilities or as a result of licensed activities.

It encompasses the following specific areas:

• effluent and emissions control (releases)
• environmental management system (EMS)
• assessment and monitoring
• protection of the public
• environmental risk assessment

Based on regulatory oversight activities, CNSC staff rated the performance of all the uranium processing facilities for the environmental protection SCA as “satisfactory” in 2017, unchanged from the previous year.

Ratings for the environmental protection SCA, uranium processing facilities, 2017
BRR PHCF CFM BWXT Toronto and Peterborough
SA SA SA SA

SA=satisfactory

#### Effluent and emissions control (releases)

To control the release of radioactive and hazardous substances into the environment, CNSC licensees are required to develop and implement policies, programs and procedures that comply with all applicable federal and provincial environmental protection regulations. Licensees are also expected to have trained and qualified personnel to effectively develop, implement and maintain their environmental protection programs.

The CNSC imposes licence limits on controlled releases to the environment to demonstrate respect for the principle of pollution prevention and to ensure protection of the public and environment. Exceedance of a licence limit is a non-compliance and considered to represent a loss of control of part of the licensee’s program(s) and/or control measure(s). Exceedance does not necessarily indicate harm to health or the environment. This is because limits are often established at levels well below those expected to cause harm. There were no licence limit exceedances in 2017 in the uranium fuel processing sector. Information on the total annual release of relevant facility-specific radionuclides in emissions to the atmosphere and in effluent released to surface waters is provided in appendix G.

#### Action levels

Further controls on releases of radioactive and hazardous substances at licensed facilities involve the use of action levels. These specific doses of radiation and other parameters that make up the action levels are proposed by the licensee for each facility and approved by the CNSC. These levels are used to ensure that licensees demonstrate adequate control and oversight of each of their facilities based on the CNSC-approved facility design and environmental protection programs.

Action levels serve to provide assurance that licence limits, described in the previous subsection, will not be exceeded. If an action level is exceeded by a facility, this provides early indication of a potential reduction in effectiveness of the program(s) and/or control measure(s) and may indicate a deviation from normal operation. An exceedance also triggers a requirement for notification to the CNSC and specific action to be taken as outlined in the licensee’s environmental protection program.

Exceeding an action level does not mean non-compliance. Indeed, the exceedance of an action level and the successful implementation of the required follow-up activities (notification, investigation and implementation of any applicable corrective actions) clearly demonstrate due diligence and a well-maintained and well-managed environmental protection program(s) and/or control measure(s). However, failure to inform the CNSC, complete an investigation or implement any applicable corrective actions would be a non-compliance.

Action level exceedances and their resulting investigation are discussed within the facility-specific sections of this report. These were all appropriately reported, evaluated and addressed to the satisfaction of CNSC staff.

#### 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 and targets. Licensees conduct internal audits of their programs at least once a year. CNSC staff, as part of their compliance verification activities, review and assess these objectives, goals and targets. CNSC staff determined that, in 2017, the uranium processing facility licensees established and implemented EMSs in compliance with the CNSC regulatory requirements.

#### Assessment and monitoring

Each uranium processing facility licensee has environmental monitoring programs at each of its facilities to monitor releases of radioactive and hazardous substances, and to characterize the quality of the environment associated with the licensed facility. These programs include the monitoring of uranium in ambient air and uranium in soil, described below.

##### Uranium in ambient air

Licensees measure uranium in ambient air to confirm the effectiveness of emission abatement systems and to monitor the impact of uranium emissions on the environment. The three Cameco facilities and BWXT Toronto operate high-volume air samplers at the perimeter of their facilities. BWXT Peterborough does not use fenceline air samplers, as stack emissions at the point of release already meet the Ontario Ministry of the Environment, Conservation and Parks (MECP) annual air standard for uranium, which is equal to 0.03 micrograms per cubic metre (µg/m3).

The results from the high-volume air samplers with the highest values near a facility (maximum annual average) for 2013 through 2017 are shown in figure 2-3. These values are measured as the total suspended particulate representing the total amount of uranium in air. As shown in figure 2-3, the maximum annual average concentration of uranium in ambient air is well below the MECP annual air standard for uranium, which took effect in 2016.

Description
Figure 2-3: Uranium concentration in ambient air (maximum annual average), uranium processing facilities, 2013–17
Cameco BRR Cameco PHCF CFM BWXT Toronto
2013 0.0017 0.0020 0.0011 0.0007
2014 0.0020 0.0020 0.0007 0.0006
2015 0.0031 0.0030 0.0011 0.0010
2016 0.0039 0.0040 0.0019 0.0010
2017 0.0017 0.0020 0.0009 0.0000
##### Uranium in soil

The three Cameco facilities and BWXT Toronto have soil monitoring programs to monitor the long-term effects of air emissions and to determine whether there is accumulation of uranium in soil around the facility. Sampling takes place every three years at the CFM facility and annually at the other facilities. The uranium in the soil at the CFM facility is a result of historic uranium contamination, which is common to the Port Hope area.

BWXT Peterborough does not conduct uranium-in-soil monitoring. This is because uranium releases from its facility are negligible: the fuel pellets received from the Toronto facility are in solid form and uranium releases to air are very low. As described in the previous subsection, BWXT monitors the stack to confirm that releases to air remain low.

CNSC staff evaluated the results of licensees’ soil sampling programs for 2017 and compared them with those of previous years. The results continue to indicate that there is no accumulation of uranium in surrounding soil resulting from current uranium emissions from the uranium processing facilities.

Figure 2-4 provides the annual average uranium concentrations in soil results for 2013 through 2017. In Ontario, natural background concentrations of uranium in soil for rural and urban parkland are generally between 1.9 and 2.1 micrograms per gram (µg/g). The annual average concentrations of uranium in soil at uranium processing facilities are similar to natural background levels and well below the applicable guideline value for the land-use type of 23 µg/g, as described by the Canadian Council of Ministers of the Environment (CCME) soil quality guideline for residential and parkland use.

*N/A indicates that a value is not available. CFM collects soil measurements once every three years.

Description
Figure 2-4: Uranium concentration in soil (annual average), uranium processing facilities, 2013–17
Cameco BRR Cameco PHCF CFM* BWXT Toronto
2013 4.3 1.0 3.7 3.9
2014 2.7 1.4 N/A 5.0
2015 3.8 1.0 N/A 2.9
2016 1.5 1.2 2.5 2.7
2017 1.6 0.8 N/A 3.0

#### Protection of the public

The CNSC requires licensees to demonstrate that the health and safety of the public are protected from exposures to hazardous 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 through reporting requirements outlined in the licence and the LCH. Based on reviews of the programs at the uranium processing facilities, CNSC staff concluded that the public continues to be protected from facility emissions of hazardous substances.

#### Environmental risk assessment

Environmental risk assessments (ERAs) are used to analyze the risks associated with contaminants in the environment as a result of licensed activities. ERAs provide the basis for the scope and complexity of environmental monitoring programs at the uranium processing facilities. The uranium processing facility licensees currently have acceptable environmental programs in place to ensure the protection of the public and the environment.

In 2014, CNSC staff requested that the uranium processing facilities implement CSA standard N288.6-12 Environmental risk assessments at Class I nuclear facilities and uranium mines and mills Footnote 3 , in order to align with the design, implementation and management of an ERA program that incorporates best practices used in Canada and internationally. CSA N288.6-12 has now been implemented at all uranium processing facilities.

As outlined in REGDOC-3.2.1, Public Information and Disclosure, published in May 2018, if a licensee is required to conduct an ERA, the ERA must be posted on the licensee’s website. Licensees are developing implementation plans for uranium processing facilities, which will include the date by which the regulatory document must be implemented. Section 2.4 provides more details on the implementation status of regulatory documents for the uranium processing facilities.

#### Conclusion on environmental protection

CNSC staff concluded that the uranium processing facility licensees implemented their environmental protection programs satisfactorily during 2017. The licensees’ programs are effective in protecting the health and safety of the public and the environment.

### 2.3 Conventional health and safety

The conventional health and safety SCA covers the implementation of a program to manage workplace safety hazards and to protect personnel and equipment.

It encompasses the following specific areas:

• performance
• practices
• awareness

Based on regulatory oversight activities, CNSC staff rated the performance for the conventional health and safety SCA as “satisfactory” in 2017 for all but one of the uranium processing facilities. The exception was the BRR facility, which was given a “fully satisfactory” rating. These ratings are unchanged from the previous year.

Ratings for the conventional health and safety SCA, uranium processing facilities, 2017
BRR PHCF CFM BWXT Toronto and Peterborough
FS SA SA SA

FS= fully satisfactory; SA= satisfactory

#### Performance

Employment and Social Development Canada (ESDC) and the CNSC regulate conventional health and safety programs at uranium processing facilities. Licensees submit hazardous-occurrence investigation reports to both ESDC and the CNSC, in accordance with their respective reporting requirements.

Licensees are required to report unsafe occurrences 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. The number of recordable LTIs reported by all facilities has remained low over the past five years, as summarized in table 2-4. Further information is provided in facility-specific sections, as well as in appendixH, which lists all LTIs reported in 2017 and the actions taken.

Table 2-4: LTIs at uranium processing facilities, 2013–17
Facility 2013 2014 2015 2016 2017
BRR 0 0 0 0 0
PHCF 0 1 2 3 1
CFM 0 0 1 0 0
BWXT Toronto and Peterborough 0 1 0 0 0

#### 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 processing facilities during 2017 to verify compliance of the licensees’ conventional health and safety programs with regulatory requirements. Through these regulatory oversight activities, CNSC staff determined 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.

Through conducting onsite inspections, CNSC staff are able to verify that workers are trained to identify hazards at the facilities. CNSC staff confirmed that the uranium 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 processing facility licensees implemented their conventional health and safety programs satisfactorily during 2017. Their programs are effective in protecting the health and safety of persons working in the facilities.

### 2.4 Regulatory developments

In 2017, Cameco’s operating licence for the PHCF was renewed by the Commission through a public hearing for a 10-year period expiring in February 2027. No amendments were made to the BRR, CFM or BWXT licences, and CNSC staff continued to modernize the regulatory framework with the REGDOC series of regulatory and guidance documents.

Table 2-5 lists the updates made since 2016 to the CNSC regulatory documents that apply to the uranium processing facilities licensees and includes the implementation status.

Table 2-5: Regulatory documents applicable to uranium processing facilities
Regulatory document Version PHCF BRR CFM BWXT
REGDOC-2.10.1, Nuclear Emergency Preparedness and Response, Version2 February 2016 Implemented

Implementation expected by April 2019

Implementation expected by December 2018

Implemented

REGDOC-2.2.2, Personnel Training, Version 2

December 2016 Implemented Implemented Implemented Implemented

REGDOC-3.1.2, Reporting Requirements, Volume I: Non-Power Reactor Class I Nuclear Facilities and Uranium Mines and Mills

January 2018

Implementation expected by January 2019

Implementation expected by January 2019

Implementation expected by January 2019

Implementation expected by February 2019

REGDOC-2.13.1, Safeguards and Nuclear Material Accountancy February 2018

Implementation expected by September 2019

Implementation expected by September 2019

Implementation expected by September 2019

Implementation expected by January 2019

REGDOC-3.2.1, Public Information and Disclosure

May 2018

Implementation plans expected in 2019

Implementation plans expected in 2019

Implementation plans expected in 2019

Implementation plans expected in 2019

CNSC staff are updating the LCHs for each uranium processing facility to reflect these regulatory documents and standards, taking into consideration licensees’ implementation plans. CNSC staff verify the implementation as part of ongoing compliance verification activities.

### 2.5 Public information and outreach

Uranium processing facility licensees are required to maintain and implement public information and disclosure programs, in accordance with regulatory document REGDOC-3.2.1, Public Information and Disclosure Footnote 6 (which replaced regulatory/guidance document RD/GD-99.3 in 2018). These programs are supported by disclosure protocols that outline what type of facility information must be shared with the public (e.g., incidents, major changes to operations or periodic environmental performance reports), as well as details on how that information will be shared. This ensures that timely information is effectively communicated about the health, safety and security of persons and the environment, and about other issues associated with the lifecycle of the nuclear facilities.

In 2017, CNSC staff evaluated licensees’ implementation of their public information and disclosure programs by reviewing communications activities such as public information sessions, facility tours, newsletters, and website and social media updates, and licensees’ direct outreach to stakeholders in the community. CNSC staff determined that all uranium processing facility licensees were in compliance with REGDOC-3.1.2, Reporting Requirements, Volume I: Non-Power Reactor Class I Nuclear Facilities and Uranium Mines and Mills.

CNSC staff concluded that, in 2017, licensees operating uranium processing facilities implemented their public information programs satisfactorily and issued information in accordance with their public disclosure protocols. Their programs are effective at communicating information about the health, safety and security of persons and the environment, and other issues associated with the facilities. Furthermore, all licensees publish their annual compliance reports on their websites.

More detailed engagement activities and information shared with the public with respect to each facility are outlined in the licensee-specific performance sections.

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## 3 Cameco Blind River Refinery

Cameco Corporation owns and operates the Blind River Refinery (BRR) facility in Blind River, Ontario, under an operating licence that expires in February 2022. The BRR facility is located about 5 km west of the town of Blind River, as shown in figure3‑1.

Figure 3-1: Aerial view of the BRR facility

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 PHCF. Figure 3-2 shows shipping totes that are used to transfer UO3 from the BRR facility to the PHCF.

Figure 3-2: Shipping totes used to transfer UO3 from the BRR facility to the PHCF

### 3.1 Overall performance

For 2017, CNSC staff rated the BRR facility’s performance as “satisfactory” in all but one of the SCAs. The exception was conventional health and safety, which was rated as “fully satisfactory”. The performance ratings for the BRR facility from 2013 to 2017 are shown in table C-1 of appendix C.

Cameco continued to operate the BRR facility safely throughout 2017. The facility underwent two planned shutdowns during the year to conduct routine maintenance activities and implement facility upgrades. Cameco ensured that the BRR site was maintained according to the facility’s licensing basis.

The BRR facility experienced four events that were reported to CNSC staff in 2017, in accordance with Cameco’s regulatory reporting requirements.

Three of the four events were related to transport, while the fourth was a CNSC radiological action level exceedance. Two of the transport events involved damage to drums coming to the BRR facility from a foreign producer. There was no loss of material from any of the damaged drums. The third transport event involved damage to one drum going from the BRR facility to Cameco’s Key Lake Mine.

While there was a small release of calcined product onto the floor of the truck trailer, there was no effect on the environment or the health and safety of persons. The fourth event, exceedance of a CNSC radiological action level, is discussed in section 3.2.

For each event, Cameco completed an investigation and established corrective actions. CNSC staff reviewed this information to ensure that Cameco’s corrective actions were effective to prevent recurrence.

In 2017, CNSC staff conducted four onsite inspections at the BRR facility to ensure compliance with the NSCA Footnote 1 and its associated regulations, Cameco’s operating licence and the programs used to meet regulatory requirements. A list of these inspections can be found in table K-1 in appendix K. The inspections focused on the following SCAs: management system, human performance management, operating performance, fitness for service, radiation protection, conventional health and safety, and security. Seven enforcement actions were raised as a result of the inspections. The findings from these inspections posed a low safety significance to the achievement of regulatory objectives and CNSC expectations.

CNSC staff note that Cameco, in relation to the BRR facility, provided information and engaged with Indigenous communities and organizations with an interest in the BRR site activities in 2017, including meetings with the Chief of the Mississauga First Nation (MFN) and tours for representatives of the Métis Nation of Ontario and the Sagamok First Nation. In the interest of reconciliation and relationship-building based on openness and trust with Indigenous peoples in Canada, CNSC staff continue to ensure that all issues of interest or concern in relation to the BRR facility are identified, recorded, considered and addressed, where appropriate.

Cameco continued to communicate with all target audiences about its facility in 2017 and regularly updates its website with safety and environmental information about its licensed activities. Cameco posts a safety report on its website, along with waste management information and quarterly compliance reports. The licensee meets yearly with community leaders and Indigenous groups and also conducts meetings with public stakeholders interested in the facility. Cameco is in compliance with RD/GD-99.3, the predecessor of REGDOC-3.2.1, Public Information and Disclosure Footnote 7 , and implementation plans for REGDOC-3.2.1 are expected to be completed in 2019.

Compliance ratings for the radiation protection SCA, BRR facility, 2013–17
2013 2014 2015 2016 2017
SA SA SA SA SA

For 2017, CNSC staff continued to rate the radiation protection SCA at the BRR facility as “satisfactory”. Cameco has implemented and maintained a radiation protection program as required by the Radiation Protection Regulations Footnote 2 . At the BRR facility, workers handle natural uranium compounds in the production of uranium trioxide (UO3). This activity presents external radiological hazards to the whole body and internal radiological hazards from inhalation, ingestion or absorption through the skin. Radiological hazards were effectively controlled at the BRR facility. As a result, radiation doses to workers and members of the public were kept well below the CNSC regulatory dose limits.

SA= satisfactory

#### Application of ALARA

Cameco established radiation protection objectives and targets at the BRR facility in 2017 that focused on initiatives to reduce worker doses and airborne uranium concentrations. Cameco’s objectives included improvements to the respiratory protection program and gamma spectroscopy equipment. Cameco’s site management team reviewed the status of the radiation protection objectives and targets and allocated resources accordingly in order to achieve them. Cameco also continued to use an ALARA Committee that is responsible for making recommendations for improving radiation protection at the BRR facility.

#### Worker dose control

Radiation exposures at the BRR facility are monitored to ensure compliance with the CNSC’s regulatory dose limits and to keep radiation doses ALARA. In 2017, radiation exposures at the BRR facility were well below the CNSC regulatory dose limits.

Cameco ascertains external doses by using whole-body and extremity dosimetry. For internal radiological exposures, Cameco’s Fuel Services Division holds a CNSC dosimetry service licence, which authorizes Cameco to provide in-house internal dosimetry services at the BRR facility. Internal dose is assessed and assigned at the BRR facility through two programs: urine analysis and lung counting, a method in which a radiation detector is used to measure radiation emitted from radioactive material collected in a person’s lung.

All Cameco employees at the BRR facility are identified as NEWs. BRR contractors may also be identified as NEWs depending on the nature of their work activities. In 2017, total effective dose was assessed for 145 NEWs at the BRR facility, consisting of 130 Cameco employees and 15 contractors. The maximum effective dose received by a NEW in 2017 was 3.3 mSv, which is approximately 7% of the CNSC regulatory effective dose limit of 50 mSv in a one-year dosimetry period.

Figure 3-3 provides the average and maximum effective doses to NEWs at the BRR facility from 2013 to 2017. The average and maximum total effective doses in 2017 are the lowest over this five-year period.

Description
Figure 3-3: Average and maximum effective doses to NEWs, BRR facility, 2013–17
2013 2014 2015 2016 2017
Average effective dose (mSv) 3.3 3.3 1.7 1.5 0.9
Maximum effective dose (mSv) 12.1 8.2 7.4 6.1 3.3
Number of NEWs monitored 171 162 154 154 145

Annual average and maximum equivalent (extremity) and equivalent (skin) dose results from 2013 to 2017 are shown in tables E-1 and E-7 in appendix E. In 2017, the maximum individual skin dose received by a NEW at the BRR facility was 16.2 mSv, which is approximately 3% of the CNSC regulatory equivalent dose limit of 500 mSv in a one-year dosimetry period. The maximum individual extremity dose received by a NEW at the BRR facility was 13.6 mSv, which is approximately 3% of the CNSC regulatory equivalent dose limit of 500 mSv in a one-year dosimetry period. The average and maximum equivalent doses have been relatively steady over this five-year period.

Site visitors and contractors who are not considered as NEWs are issued dosimeters to monitor their radiological exposures while at the BRR facility. In 2017, the maximum individual effective dose received by a site visitor/contractor who was not a NEW was 0.1 mSv, which is well below the CNSC regulatory dose limit of 1 mSv/year for a person who is not a NEW.

In 2017, CNSC staff assessed the performance of Cameco’s radiation protection program at the BRR facility through various CNSC staff compliance activities. Overall, Cameco’s compliance with the Radiation Protection Regulations Footnote 2 and the CNSC licence requirements at the BRR facility was found to be acceptable.

Action levels for radiological exposures are established as part of the radiation protection program. If an action level is reached, Cameco staff must establish the cause, notify the CNSC and, if applicable, restore the effectiveness of the program. In 2017, there was one exceedance of the BRR facility’s action level for whole-body dose reported to the CNSC. Cameco’s investigation revealed that the reported exposure was non-personal in nature. Cameco requested that a correction be made to the official dose of record in the National Dose Registry for the employee, in accordance with the CNSC-established process. The dose change request was reviewed by CNSC staff and approved in December 2017.

Cameco has radiation and contamination control programs at the BRR facility to control and minimize radiological hazards and the spread of radioactive contamination. Methods of control include radiation zone controls and monitoring to confirm the effectiveness of the programs. Cameco staff at the BRR facility conducted in-plant air monitoring, contamination monitoring and radiation dose rate surveys in 2017, and did not identify any adverse trends.

#### Estimated dose to the public

The maximum dose to the public from licensed activities at the BRR facility is calculated by using monitoring results of air emissions, water discharges and gamma radiation. Table 3-1 shows the 2013 to 2017 maximum effective doses to a member of the public. Doses to the public remain well below the CNSC regulatory dose limit of 1 mSv/year.

Table 3-1: Maximum effective dose to a member of the public, BRR facility, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory dose limit
Maximum effective dose (mSv) 0.012 0.005 0.005 0.005 0.005 1 mSv/year

### 3.3 Environmental protection

Compliance ratings for the environmental protection SCA, BRR, 2013–17
2013 2014 2015 2016 2017
SA SA SA SA SA

For 2017, CNSC staff continued to rate the environmental protection SCA at Cameco’s BRR facility as “satisfactory”. Uranium releases to the environment continue to be effectively controlled and monitored in compliance with the conditions of the operating licence and regulatory requirements. The releases of hazardous substances from the facility to the environment are controlled in accordance with the MECP applicable regulations and certificates of approval. The measured releases to the environment in 2017 were well below regulatory limits. Groundwater monitoring, surface water monitoring, soil sampling and ambient air data indicate that the public and the environment continue to be protected from facility releases.

SA = satisfactory

#### Effluent and emissions control (releases)

##### Atmospheric emissions

Cameco monitors uranium, nitrogen oxides (NOx), nitric acid (HNO3) and particulates released from the facility stacks. The monitoring data in table 3-2 demonstrate that atmospheric emissions from the facility continued to be effectively controlled, as they remained consistently well below their respective licence limits from 2013 to 2017.

Table 3-2: Air emissions monitoring results (annual averages), BRR facility, 2013–17
Parameter 2013 2014 2015 2016 2017 Licence limit
Dust collection and exhaust ventilation stack: uranium (kg/h) 0.00004 0.00005 0.00005 0.00005 0.00004 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) 3.4 2.0 2.5 1.6 1.7 56.0
Particulate (kg/h) 0.014 0.009 0.006 0.006 0.008 11.0

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

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

In addition to licence limits, the BRR facility implemented action levels that are used to provide assurance that licence limits will not be exceeded. No action levels for atmospheric emissions were exceeded at any time in 2017.

##### Liquid effluent

There are three 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, before discharge into Lake Huron. Cameco monitors uranium, radium-226, nitrates and pH levels in liquid effluents to demonstrate compliance with their respective licence limits.

Table 3‑3 summarizes the average monitoring results from 2013 to 2017. For 2017, the liquid discharges from the facility continued to be below their respective licence limits.

Table 3-3: Liquid effluent monitoring results (annual averages), BRR facility, 2013–17
Parameter 2013 2014 2015 2016 2017 Licence limit
Uranium (mg/L) 0.01 0.02 0.02 0.01 0.01 2
Nitrates (mg/L) 26 17 13 11 14 1,000
Radium-226 (Bq/L) 0.01 0.01 <0.01 0.01 0.01 1
pH (min) 7.1 7.1 7.2 7.3 7.3 Min 6.0
pH (max) 8.4 8.4 8.4 8.6 8.2 Max 9.5

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

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

In addition to licence limits, the BRR facility has action levels that are used to provide assurance that the licence limits will not be exceeded. No action levels for liquid effluents were exceeded at any time in 2017.

#### Environmental management system

Cameco has developed and is maintaining an environmental management system (EMS) that provides a framework for integrated activities for the protection of the environment at the BRR facility. Cameco’s EMS for the BRR facility is described in the facility’s Environmental Management Program Manual.

The EMS includes annual environmental objectives and targets set by Cameco, which are reviewed and assessed by CNSC staff through compliance verification activities. Cameco completed four out of five of its environmental objectives set for 2017. These completed objectives were related to a review of the action levels, reduction of legacy waste on site, review of the storm water lagoon pumping system and assessment of the internal recycling of liquid effluent streams. The fifth objective was to assess an alternate location for the incinerator sampling point. However, Cameco cancelled this objective, after determining that the original sampling point was appropriate and did not require relocation based on current operations.

Cameco holds an annual safety meeting during which environmental protection issues are discussed and documented. CNSC staff, as part of their compliance verification activities, review these documents and follow up with Cameco staff on any outstanding issues. The results of these compliance verification activities demonstrate that Cameco conducted an annual management review in accordance with the CNSC requirements and that identified issues are being properly addressed. CNSC staff are satisfied that Cameco is conducting effective reviews and adequately addressing identified issues.

#### Assessment and monitoring

Cameco’s environmental monitoring programs serve to demonstrate that the BRR site emissions of radioactive and hazardous substances are properly controlled. The program also provides data for estimates of annual radiological doses to the public. This is meant to ensure that the public exposure attributable to Cameco’s BRR operations is well below the annual regulatory public dose limit of 1 mSv and is ALARA. The principal monitoring activities, described below, focus on monitoring air, groundwater, surface water, soil, and gamma radiation around the BRR site.

In addition, the CNSC conducts periodic monitoring under its IEMP to verify that the public and the environment around nuclear facilities are protected.

##### Uranium in ambient air

Cameco’s sampling network around the facility revealed that the concentrations of uranium in the ambient air continued to be low. In 2017, the highest measured annual average concentration (among the sampling stations) of uranium in ambient air was 0.0017 μg/m3, which is well below the MECP annual standard for uranium in ambient air of 0.03 μg/m3.

##### Groundwater monitoring

Cameco has an extensive groundwater monitoring program in place around the facility with a total of 43 monitoring wells: 17 wells located inside the fenceline and 26 outside of it.

Based on the groundwater sampling data presented in Cameco’s annual compliance reports, the BRR operations are not causing any adverse impact to groundwater quality. The average uranium concentration in groundwater decreased in 2017 from 2016. The maximum sampled uranium concentration in the groundwater was 11.0 micrograms per litre (μg/L) in 2017, which is below the maximum acceptable concentration of 20 μg/L in Health Canada’s Guidelines for Canadian Drinking Water Quality (GCDWQ) Footnote 8 . The groundwater in the area is not used for drinking water purposes. Groundwater monitoring results are shown in table F-1 of appendix F.

##### Surface water monitoring

Cameco continues to monitor surface water for uranium, nitrate, radium and pH at the location of the BRR’s outfall diffuser in Lake Huron. The concentrations of uranium, nitrate, radium and the pH levels in the lake remain well below the CCME guidelines. Surface water monitoring results are shown in table F-2 of appendix F.

##### Soil monitoring

Cameco collects soil samples annually to monitor uranium concentrations in an upper layer of surface soil (15 cm) to demonstrate that there are no long-term effects of air emissions on soil quality due to deposition of airborne uranium on soil around the BRR facility. The 2017 soil monitoring results remained consistent with the respective concentrations detected in previous years, as shown in table F-3 of appendixF. The maximum uranium soil concentrations measured near the facility continued to trend downward, with the 2017 result at 2.8μg/g slightly above natural background levels (between 1.9 and 2.1μg/g) at both the MFN and Blind River communities. In addition, the uranium soil concentrations are well below 23μg/g, which is the most restrictive soil quality guideline for uranium (for residential and parkland land use) set by the CCME. Uranium soil concentrations are not increasing in the area surrounding the facility.

These data demonstrate that the current BRR operations do not contribute to accumulation of uranium in surrounding soil. No adverse consequences to human and environmental receptors are expected.

##### Gamma monitoring

A significant portion of radiological public dose in Blind River that can be attributed to the BRR operations is due to gamma radiation sources. Consequently, monitoring gamma radiation effective dose rates at the fenceline of the BRR main site and at a nearby golf course north of the BRR site is essential to ensuring that levels of potential gamma radiation exposure are safe and maintained ALARA. The land immediately outside the fenceline continues to be owned and controlled by Cameco. The critical receptor location for the gamma component of dose to the public is the neighbouring golf course. Therefore, Cameco sets an action level for gamma dose rates of 1.0 µSv/h (microsieverts per hour) at the north fence only. The effective dose rates for gamma radiation are measured with environmental dosimeters.

In 2017, the monthly average of fenceline gamma measurements at the BRR facility were 0.38µSv/h (east), 0.24 µSv/h (north), 0.43 µSv/h (south) and 1.10µSv/h (west). All north fence results in 2017 were below the action level. These measurements indicate that gamma dose rates are controlled and that the public is protected.

#### CNSC Independent Environmental Monitoring Program

CNSC staff conducted independent environmental monitoring in the Blind River area in 2013, 2014 and 2017. The results are available on the CNSC’s IEMP Web page. The IEMP results indicate that the public and the environment surrounding the BRR site are protected from facility emissions.

Since 2014, CNSC staff and the MFN have been holding regular meetings to discuss Cameco’s licensing and compliance activities for the BRR facility. As a continuation of these meetings, CNSC staff held a meeting with the MFN on February 2, 2016, to discuss the MFN’s air quality sampling program and air monitoring results. Also discussed were the MFN’s concerns regarding previous IEMP sampling locations and the changes to Ontario’s ambient air quality standard for uranium. Following the meeting, CNSC and MFN staff discussed ideas for future sampling campaigns that would include MFN traditional lands. CNSC staff made a commitment to continue the dialogue and explore opportunities with the MFN to inform the sampling campaign and increase the MFN’s understanding of the results.

On July 5, 2016, CNSC staff met with MFN staff to develop an IEMP sampling plan on MFN lands. The CNSC’s PFP provided financial support to the MFN for all these meetings. A sampling plan meeting both the IEMP objectives and the MFN objectives was subsequently developed and executed in October 2017. The CNSC shared the IEMP results with the MFN and indicated that the community is protected from the operations of the facility.

Another IEMP campaign was completed in October 2018 at the BRR facility and, similar to previous years, involved ongoing communications and support from the MFN. The results from the campaign will be made available to the public once the samples have been analyzed by the CNSC’s laboratory.

#### Protection of the public

The CNSC receives reports of discharges to the environment in accordance with the reporting requirements outlined in the BRR facility licence and LCH. CNSC staff’s review of hazardous discharges from the BRR facility to the environment in 2017 indicates that no significant risks to the public or environment occurred during that period.

CNSC staff concluded, based on their review of the environmental monitoring programs at the BRR facility, that the public continues to be protected from facility emissions.

#### Environmental risk assessment

In November 2016, Cameco submitted an ERA for the BRR facility to the CNSC. CNSC staff reviewed Cameco’s responses to staff comments and concluded that the current version of the ERA for the BRR facility is in compliance with CSAN288.6-12, Environmental risk assessments at Class I nuclear facilities and uranium mines and mills Footnote 7 . CNSC staff expect Cameco to address several technical comments before or in the next iteration of the ERA (due in 2021), as appropriate, to improve the quality of the ERA.

ERA conclusions and recommendations, as well as guidance outlined in CSA N288.4-10, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills Footnote 10 , and CSA N288.5-11, Effluent monitoring programs at Class I nuclear facilities and uranium mines and mills Footnote 11 ,have been incorporated into Cameco’s environmental programs for the BRR facility to ensure the protection of the public and the environment.

REGDOC-3.2.1, Public Information and Disclosure, which was published in May 2018, stipulates that if a licensee is required to conduct an ERA, the ERA must be posted on the licensee’s website. Cameco is currently developing implementation plans for its uranium processing facilities, which will include the date by which REGDOC-3.2.1 must be implemented.

### 3.4 Conventional health and safety

Compliance ratings for the conventional health and safety SCA, BRR facility, 2013–17
2013 2014 2015 2016 2017
FS FS FS FS FS

For 2017, CNSC staff continued to rate the conventional health and safety SCA at the BRR facility as “fully satisfactory”. Overall, the compliance verification activities conducted by CNSC staff at the BRR facility confirmed that Cameco continues to view conventional health and safety as an important consideration. Cameco has demonstrated a fully satisfactory ability to keep its workers safe from occupational injuries: No lost-time injuries (LTIs) have occurred at the facility in the past 11 years.

FS = fully satisfactory

#### Performance

Cameco’s performance related to conventional health and safety at the BRR facility is monitored through CNSC staff’s onsite inspections and event reviews. Cameco continues to develop and maintain a comprehensive conventional health and safety management program for the BRR facility. This program at the BRR facility incorporates various elements, including accident reporting and investigation, hazard prevention, preventive maintenance, health and safety committees, training, personal protective equipment, and emergency preparedness and response.

A key performance measure for the conventional health and safety SCA is the number of LTIs that occur per year. Table3-4 shows that the number of LTIs remained at zero in 2017. Cameco has not had an LTI at the BRR facility in the past 11 years.

Table 3-4: LTIs, BRR facility, 2013–17
2013 2014 2015 2016 2017
LTIs 0 0 0 0 0

#### Practices

Cameco’s activities and operations at the BRR facility must comply with the NSCA Footnote 1 and its associated regulations, and with Part II of the Canada Labour Code Footnote 5 . Cameco’s commitment to safety is captured in a safety charter signed by each employee and displayed at the facility’s entrance. Cameco uses audits, inspections, evaluations, reviews, benchmarking, training and employee engagement to evaluate the effectiveness of conventional health and safety practices at the facility.

Cameco has a Facility Health and Safety Committee that inspects the workplace and meets monthly to resolve and track any safety issues. All reported conventional health and safety incidents are tracked and managed through the Cameco Incident Reporting System database. CNSC staff review the committee meeting minutes and any associated corrective actions to verify that issues are promptly resolved.

#### Awareness

Workers are made aware of the conventional health and safety program, as well as workplace hazards, through training and ongoing internal communications with Cameco. Cameco holds monthly safety meetings for all employees at the BRR facility on various safety topics, including radiation protection, environmental protection and fire protection. Attendance is tracked at the safety meetings as an indicator for safety performance. Cameco workers at the BRR facility also attend daily toolbox meetings where they are notified of any concerns or ongoing maintenance in their area. Cameco also undertook a safety initiative in 2017, in which it held a “safety stand-down” for the workers upon return to work after the summer and Christmas shutdown periods.

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## 4 Cameco Port Hope Conversion Facility

Cameco Corporation owns and operates the Port Hope Conversion Facility (PHCF), which is located in Port Hope, Ontario, situated on the north shore of Lake Ontario, approximately 100 km east of Toronto. The PHCF is located at two sites in the Municipality of Port Hope, as seen in figure 4-1. Aerial photographs of the two PHCF sites (Site 1 and Site 2) are shown in figure 4-2 and figure 4-3.

Figure 4-1: PHCF Site 1 and Site 2 properties, located in the Municipality of Port Hope, ON

Figure 4-2: Aerial view of Site 1 of the PHCF

Figure 4-3: Aerial view of Site 2 of the PHCF

The PHCF converts uranium trioxide (UO3) powder produced by Cameco’s BRR facility into uranium dioxide (UO2) and uranium hexafluoride (UF6). UO2 is used to manufacture Canada Deuterium Uranium (CANDU) reactor fuel, while UF6 is exported for further processing before being converted into fuel for light-water reactors.

Vision in Motion (VIM) is the name of Cameco’s project to clean up legacy waste inherited from historic operations and to renew the PHCF. The project is being carried out under Cameco’s operating licence for the facility. In 2017, Cameco’s work included repackaging legacy waste to further prepare conditions for cleanup and remediation expected to start in 2018.

In 2017, the Commission renewed Cameco’s operating licence via a public hearing. Cameco’s PHCF licence covers 10 years, expiring on February 28, 2027.

### 4.1 Overall performance

For 2017, CNSC staff rated the PHCF’s performance as “satisfactory” in all but one of the SCAs. The exception was the management system, which received a rating of “below satisfactory”. The performance ratings for the PHCF from 2013 to 2017 are shown in table C-2 of appendix C.

In 2017, Cameco ensured that the PHCF site was maintained according to the PHCF’s licensing basis. During the summer of 2017, the UO2 and UF6 plants underwent scheduled shutdowns to allow for planned maintenance activities.

On May 5, 2017, Cameco reported a small release of hydrogen fluoride (HF) at its UF6 plant. During the night shift, an employee was performing maintenance work and HF gas was released. The emergency ventilation system was activated by a local HF detector. Upon arriving to the affected area, Cameco’s emergency response team secured the connection to the impulse line. The employee was directed to Cameco’s medical department where he received precautionary medical attention due to exposure to HF. The worker was not injured and there were no environmental impacts as a result of this event.

In accordance with the CNSC reporting regulatory requirement, Cameco reported the incident to the CNSC duty officer and carried out a detailed investigation of this reportable event. Cameco submitted a final report for review by CNSC staff. Based on Cameco’s investigation into the event, CNSC staff determined that the required work clearance and permits had not been obtained by the junior technician before the start of the maintenance work. Furthermore, Cameco determined that the junior and senior technicians had been performing this maintenance activity for an unspecified period of time without the necessary work clearances and permits.

This practice was known to the UF6 production supervisor. CNSC staff had previously identified non-adherence to this procedure in a 2014 inspection and noted non-compliance with Cameco’s management system since 2014. CNSC staff assessed the release event and Cameco’s compliance history with respect to procedural adherence and determined that Cameco had failed to verify whether work was being performed correctly and according to approved procedures, as required by Cameco’s management system.

An administrative monetary penalty (AMP) was issued to Cameco by a CNSC designated officer on September 6, 2017, in accordance with section 6(1)(b) of the Canadian Nuclear Safety Commission’s Administrative Monetary Penalties Regulations Footnote 9 . Specifically, it was issued because Cameco had failed to comply with licence condition 2.1, that “licensees shall implement and maintain a management system” in accordance with paragraph48(c) of the NSCA. The purpose of issuing the AMP was to promote compliance with Cameco’s licensing basis documents, which are part of its management system, and to deter future violations.

Cameco requested a review of the AMP by the Commission. The review was held in March 2018 and the Commission rendered its decision in May 2018, determining that Cameco had committed the violation. Additional details on the AMP are provided on the CNSC website.

In 2017, Cameco reported nine events at the PHCF to the CNSC. Cameco reported these events in accordance with its regulatory reporting requirements and, of the nine events, one was an LTI notification. All the events are further discussed in section 4.4.

In 2017, CNSC staff conducted five onsite inspections at the PHCF to verify compliance with the NSCA Footnote 1 , its associated regulations, Cameco’s operating licence and the programs used to meet regulatory requirements. A list of these inspections can be found in table K-2 of appendix K. These planned onsite inspections focused on the following SCAs: radiation protection, conventional health and safety, packaging and transport, physical design, management system, fitness for service, emergency management, and human performance management. CNSC staff raised 22 enforcement actions as a result of the inspections. The findings were of low safety significance and did not affect the health and safety of workers, the public or the environment, or the safe operation of the facility.

CNSC staff noted that Cameco, in relation to the PHCF, invited Indigenous communities and organizations with a potential interest in its activities to public forums in 2017. In the interest of reconciliation and relationship-building based on openness and trust with Indigenous peoples in Canada, CNSC staff continue to ensure that all issues of interest or concern to Indigenous communities and organizations in relation to the PHCF are identified, recorded, considered and addressed, where appropriate.

Cameco maintained the commitments of its public information program in 2017 by holding a joint community forum for stakeholders and key audiences on the PHCF and CFM activities, and by hosting two media events. The media events announced Cameco’s involvement in the world’s supply of cobalt-60 to produce medical isotopes. Local media covered these events, which were attended by federal and provincial parliamentary representatives, as well as the mayors of Port Hope and Cobourg, and other dignitaries.

Cameco gave facility tours to the public, students and industry organizations at the PHCF. Cameco also updated health and safety information on its website, and conducted public opinion polling in accordance with its public information program. The licensee is in compliance with RD/GD-99.3, the predecessor of REGDOC-3.2.1, Public Information and Disclosure Footnote 7 , and implementation plans for REGDOC-3.2.1 are expected to be completed in 2019.

Compliance ratings for the radiation protection SCA, PHCF, 2013–17
2013 2014 2015 2016 2017
SA SA SA SA SA

For 2017, CNSC staff continued to rate the radiation protection SCA at PHCF as “satisfactory”. Cameco has implemented and maintained a radiation protection program as required by the Radiation Protection Regulations Footnote 2 . At PHCF, workers handle natural uranium in the production of uranium dioxide (UO2) and uranium hexafluoride (UF6). This activity presents external radiological hazards to the whole body and internal radiological hazards from inhalation, ingestion or absorption through the skin. Radiological hazards were effectively controlled at PHCF. As a result, radiation doses to workers and members of the public were kept well below the CNSC regulatory dose limits.

SA= satisfactory

#### Application of ALARA

Cameco established radiation protection objectives and ALARA targets at the PHCF for parameters such as radiation doses, radiation protection training and contamination monitoring. All ALARA targets for radiation doses were met in 2017. The radiation protection subcommittee of the Conversion Safety Steering Committee also continued to provide support for radiation protection improvement initiatives at the PHCF.

#### Worker dose control

Radiation exposures at the PHCF are monitored to ensure compliance with the CNSC regulatory dose limits and to keep radiation doses ALARA. In 2017, radiation exposures at the PHCF were well below the CNSC regulatory dose limits.

Cameco ascertains external doses by using whole-body dosimetry. For internal radiological exposures, Cameco’s Fuel Services Division holds a CNSC dosimetry service licence, which authorizes Cameco to provide in-house internal dosimetry services at the PHCF. Internal dose is assessed and assigned at the PHCF through two programs: urine analysis and lung counting, a method in which a radiation detector is used to measure radiation emitted from radioactive material collected in a person’s lung.

Workers (including contractors) who conduct work activities that present a reasonable probability of receiving an annual occupational dose greater than 1 mSv are identified as NEWs at the PHCF. In 2017, total effective dose was assessed for 808 NEWs, consisting of 444 employees and 364contractors, at the PHCF. The maximum individual effective dose received by a NEW in 2017 was 3.9 mSv, which is approximately 8% of the CNSC regulatory effective dose limit of 50 mSv in a one-year dosimetry period.

Figure 4-4 provides the average and maximum effective doses to NEWs at Cameco’s PHCF from 2013 to 2017. The average total effective doses over this five-year period have been stable, and the maximum individual total effective dose is the lowest over this five-year period.

Description
Figure 4-4: Average and maximum effective doses to NEWs, PHCF, 2013–17
2013 2014 2015 2016 2017
Average effective dose (mSv) 0.8 0.8 0.6 0.6 0.4
Maximum effective dose (mSv) 6.6 5.4 7.0 5.6 3.9
Number of NEWs monitored 793 780 862 830 808

Annual average and maximum equivalent (skin) dose results from 2013 to 2017 are shown in table E-8 of appendix E. In 2017, the maximum individual skin dose received by a NEW at the PHCF was 13.7 mSv, which is approximately 3% of the CNSC regulatory equivalent dose limit of 500 mSv in a one-year dosimetry period. Average skin doses have been steady since 2013, and the maximum individual skin dose is the lowest it has been since 2015.

Site visitors and those contractors who are not considered as NEWs are issued dosimeters to monitor their radiological exposures while at the PHCF. In 2017, the maximum individual effective dose received by a site visitor/contactor who was not a NEW was 0.2 mSv, which is well below the CNSC regulatory dose limit of 1mSv/year for a member of the public.

In 2017, CNSC staff assessed the performance of Cameco’s radiation protection program at the PHCF through various CNSC staff compliance activities. Overall, Cameco’s compliance with the Radiation Protection Regulations Footnote 2 and the CNSC licence requirements at the PHCF was found to be acceptable.

Action levels for radiological exposures are established as part of the radiation protection program implemented at the PHCF. In 2017, there were no instances at the PHCF where an action level was reached.

Cameco has radiation and contamination control programs at the PHCF to control and minimize radiological hazards and the spread of radioactive contamination. Methods of control include the use of radiation zone controls and monitoring to confirm the effectiveness of the programs. Cameco staff at the PHCF conducted in-plant air monitoring, contamination monitoring and radiation dose-rate surveys in 2017 and did not identify any adverse trends.

#### Estimated dose to the public

The operating release level (ORL) is based on the releases of uranium and external gamma radiation to the environment that ensure the dose to the public from the PHCF is below 0.3 mSv/year, with the air and water components each being less than 0.05 mSv/year and gamma component being less than 0.3 mSv/year. This ensures that the dose to the public remains well below the CNSC regulatory dose limit for a member of the public of 1 mSv/year.

An ORL equation was developed to account for all public dose exposure pathways: gamma, air and water. In 2016, the PHCF updated the dose calculations related to releases to water and the fenceline gamma locations used for reporting the dose to the public.

These changes included calculating dose to the public from facility discharges to the sanitary sewer. They also included a fenceline monitoring location closer to the operating facility than previously used. Also new were calculations for two estimated doses for members of the public: one for a resident near Site 1 and the other for a resident near Site 2. These revisions came into effect in 2017. The amounts in 2017 look higher than in previous years’, but there has not been an actual increase in emissions/dose from the PHCH. The results actually represent a much more conservative estimate of dose to the public. This is because gamma monitoring at the facility fenceline has now been added to the calculations. Due to these significant changes, the results beginning in 2017 cannot be compared with those of previous years.

Table 4-1 shows the 2013 to 2017 maximum effective doses to a member of the public. Table 4-2 shows the 2017 doses to a member of the public for Sites 1 and 2. Doses to the public are well below the ORL of 0.3 mSv/year and the CNSC regulatory dose limit for a member of the public of 1 mSv/year.

Table 4-1: Maximum effective dose to a member of the public, PHCF, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory dose limit
Maximum effective dose (mSv) 0.021 0.012 0.006 0.020 0.153 1 mSv/year
Dose data Air Water Gamma – Site 1 Gamma – Site 2 Total dose – Site 1 Total dose –Site 2 Public dose exposure pathway (mSv) Dose to public (mSv) 2017 0.001 0.001 0.109 0.152 0.110 0.153

### 4.3 Environmental protection

Compliance ratings for the environmental protection SCA, PHCF, 2013–17
2013 2014 2015 2016 2017
SA SA SA SA SA

For 2017, CNSC staff continued to rate the environmental protection SCA at the PHCF as “satisfactory”. Uranium releases to the environment continue to be controlled and monitored to comply with the conditions of the operating licence and regulatory requirements. The releases of hazardous substances from the facility to the environment are controlled in accordance with the MECP applicable requirements. Measured releases to the environment in 2017 were well below regulatory limits. Fenceline gamma measurements, groundwater monitoring, soil sampling, vegetation and ambient air data indicate that the public and the environment continue to be protected from facility releases.

SA = satisfactory

#### Effluent and emissions control (releases)

##### Atmospheric emissions

Cameco monitors uranium, fluorides and ammonia released from stacks at the PHCF. The monitoring data in table 4-3 demonstrate that the atmospheric emissions from the facility continued to be effectively controlled, as they remained consistently below their respective licence limits from 2013 to 2017.

Table 4-3: Air emissions monitoring results (annual averages), PHCF, 2013–17
Location Parameter 2013 2014 2015 2016 2017 Licence limit
UF6 plant Uranium (kg/h) 0.0051 0.0012 0.0017 0.0012 0.0011 0.280
Fluorides (kg/h) 0.0190 0.0130 0.0170 0.0100 0.0210 0.650
UO2 plant Uranium (kg/h) 0.0013 0.0012 0.0012 0.0010 0.0005 0.240
Ammonia (kg/h) 2.0 2.2 2.4 1.7 1.4 58

UO2 = uranium dioxide; UF6 = uranium hexafluoride

In addition to the licence limits, Cameco has action levels at the PHCF that are used to provide assurance that the licence limits will not be exceeded. No action levels for air emissions were exceeded at any time in 2017.

##### Liquid effluent

Cameco’s operating licence does not allow the discharge of any process waste water effluent from the PHCF. In 2017, there were no process liquid discharges from the 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 the 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 relicensing process, a daily sanitary sewage discharge action level of 100 µg/L and a monthly average licence limit of 275 µg/L were developed and accepted. The sanitary sewage action level was exceeded on multiple occasions between May and October 2017. This was attributed to the unusually high Lake Ontario water elevations and associated groundwater infiltration into the sanitary sewer system due to significant precipitation.

Cameco has implemented corrective actions in relation to the action level exceedances. Investigation work is underway at the UO2 and UF6 plants to determine whether infiltration exists, and the sewer system will be upgraded as part of the Vision in Motion project. CNSC staff concluded that, in 2017, Cameco met its licence requirement not to discharge process waste water effluent and that the sanitary sewer discharges were below their respective licence limit.

#### Environmental management system

Cameco has developed and is maintaining an environmental management system (EMS) that provides a framework for integrated activities for the protection of the environment at the PHCF site. The EMS is described in Cameco’s Environmental Management Program Manual. It includes annual environmental objectives and targets set by Cameco, which are reviewed and assessed by CNSC staff through compliance verification activities. Cameco implemented

• CSA N288.4-10, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills Footnote 10
• CSA N288.5-11, Effluent monitoring programs at Class I nuclear facilities and uranium mines and millsFootnote 11
• CSA N292.0-14, General principles for the management of radioactive waste and irradiated fuel Footnote 12
• CSA N292.3-14, Management of low and intermediate radioactive waste Footnote 13

Cameco also met its objective related to the deployment of waste management projects to dispose of contaminated materials at licensed hazardous facilities.

The EMS is verified through the licensee’s annual management review, where minutes and follow-up to outstanding issues are documented. CNSC staff, as part of their compliance verification activities, review these documents and follow up with Cameco staff on any outstanding issues as appropriate.

The results of these compliance verification activities demonstrate that, in 2017, Cameco conducted an annual management review in accordance with the CNSC requirements and addressed identified issues properly.

#### Assessment and monitoring

Cameco’s environmental monitoring program serves to demonstrate that the PHCF site emissions of radioactive and hazardous substances are properly controlled. The program also provides data for estimates of the annual radiological dose to the public. This is meant to ensure that the public exposure resulting from Cameco’s PHCF operations is below the annual regulatory public dose limit of 1 mSv and is ALARA. The principal monitoring activities, described below, focus on monitoring the air, groundwater, surface water, soil, vegetation and gamma radiation around the PHCF site.

In addition, the CNSC conducts periodic monitoring under its IEMP to verify that the public and the environment around nuclear facilities are protected.

##### Uranium in ambient air

Cameco measures uranium in the ambient air at several locations around the PHCF site to confirm the effectiveness of emission abatement systems and monitor the impact of the facility on the environment. For 2017, the measurements showed that the highest annual average uranium concentration in ambient air (as suspended particulate) among the sampling stations was 0.002μg/m3, well below the MECP annual standard for uranium in ambient air of 0.03μg/m3.

##### Groundwater monitoring

Currently, the groundwater quality at the PHCF is assessed with the use of samples from:

• 12 active pumping wells on a monthly basis
• 66 monitoring wells in the overburden (soil) on a quarterly basis
• 15 monitoring wells in the bedrock on an annual basis

CNSC staff found that the groundwater monitoring program, including the pump-and-treat wells, has been performing as expected. The pump-and-treat wells have been significantly reducing the mass of contaminants reaching the harbour, as shown in table F-4 of appendix F.

##### 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.

Surface water is sampled at two depths (just below the water surface and just above the harbour sediment layer), at each of the 13 locations in the harbour. Annual average and maximum concentrations of uranium, fluoride, nitrate and ammonia monitored in the harbour water from 2013 to 2017 are shown in tableF-5 of appendix F.

Surface water concentrations continue to be stable, protective of human health and generally below CCME water quality guidelines for the protection of aquatic life.

##### Soil monitoring

Cameco’s soil monitoring program consists of five monitoring locations beyond the facilities’ fenceline in Port Hope. Three of these locations are within a 0 to 500m radius zone from the facility, while the remaining two are within the 500 to 1,000 m and 1,000 to 1,500 m radius. This includes one location (waterworks side yard) remediated with clean soil to avoid interference from historic uranium soil contamination. Samples are taken annually at various depths within the soil profile to determine whether the concentration of uranium varies compared with previous sample results.

The measured average uranium-in-soil concentrations in 2017 resulting from the current PHCF operations have remained similar to past years, without increasing. This suggests that uranium emissions from the current PHCF operations do not contribute to accumulation of uranium in soil. Soil sampling results are shown in table F-6 of appendix F. The results have been well below the most restrictive CCME soil quality guidelines for the protection of environmental and human health for residential and parkland land use (23 μg/g) and within the range of the natural background levels for Ontario (between 1.9 and 2.1 μg/g).

Cameco has made a commitment to maintain the existing five soil monitoring locations and report results to the CNSC annually. 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.

##### Fluoride monitoring

The impact of fluoride emissions from the PHCF on the environment is determined each growing season (April 15 to October 15). At that time, samples of fluoride-sensitive vegetation are collected and then analyzed for fluoride content. In 2017, the vegetation sampling program was modified and included the standardization of sampling locations, where tree clusters were sampled as composite samples as opposed to single location sampling. The results in 2017 continued to be well below the MECP’s Upper Limit of Normal Guideline of 35 parts per million (ppm). Details are provided in table F-7 of appendix F.

##### Gamma monitoring

A significant portion of the low radiological public dose in Port Hope resulting from the PHCF operations is due to gamma radiation sources. Consequently, monitoring gamma radiation effective dose rates at the fenceline of the two PHCF sites is essential to ensuring that levels of potential gamma radiation exposure are safe and maintained ALARA. The gamma radiation effective dose rates for both sites are measured with environmental dosimeters supplied by a licensed dosimeter service. In accordance with the 2016 ORL, dose to the public is calculated for both Sites 1 and 2 at 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 updates to the ORL, see the subsection “Estimated dose to the public” in section 4.2 above.

The specific gamma fenceline monitoring locations used included results from station 2 (Site 1 and Site 2), station 13 (Site 1) and station 21 (Site 2). Table F-9 in appendix F includes the results from the gamma fenceline monitoring.

The 2013 to 2017 annual averages of public doses for gamma are shown in table F-8 of appendix F, and the 2017 maximum monthly public dose for gamma is shown in table F-9. These measurements indicate that gamma dose rates are controlled and the public is protected.

##### CNSC Independent Environmental Monitoring Program

CNSC staff conducted independent environmental monitoring in the Port Hope area in 2014, 2015 and 2017. The results are available on the CNSC’s IEMP Web page. The IEMP results indicate that the public and the environment surrounding the PHCF site are protected. The next IEMP campaign at the PHCF is scheduled for 2020.

#### Protection of the public

The CNSC receives reports of discharges to the environment in accordance with the reporting requirements outlined in the PHCF licence and LCH. CNSC staff’s review of Cameco’s reports of hazardous discharges from the PHCF to the environment in 2017 indicated that no significant risks to the public or environment occurred during that period.

CNSC staff concluded, based on their review of the environmental monitoring programs at the PHCF, that the public continues to be protected from facility emissions.

#### Environmental risk assessment

In January 2016, Cameco submitted the revised ERA for the PHCF for CNSC staff’s review. CNSC staff reviewed the ERA and concluded that it is in compliance with CSA N288.6-12, Environmental risk assessments at Class I nuclear facilities and uranium mines and mills Footnote 3 . CNSC staff recommendations on the ERA, as well as guidance outlined in CSA N288.4-10, Environmental monitoring programs at Class I nuclear facilities and uranium mines and millsFootnote 10 , and CSA N288.5-11, Effluent monitoring programs at Class I nuclear facilities and uranium mines and mills Footnote 11 ,have been incorporated into Cameco’s environmental programs for the PHCF to ensure the protection of the public and the environment.

### 4.4 Conventional health and safety

Compliance ratings for the conventional health and safety SCA, PHCF, 2013–17
2013 2014 2015 2016 2017
SA SA SA SA SA

For 2017, CNSC staff continued to rate the conventional health and safety SCA at the PHCF as “satisfactory”. Overall, compliance verification activities conducted by CNSC staff at the facility confirmed that Cameco continues to view conventional health and safety as an important consideration. Cameco has demonstrated a satisfactory ability to keep its workers safe from occupational injuries.

SA = satisfactory

#### Performance

Cameco’s performance related to conventional health and safety at the PHCF is monitored through CNSC staff’s onsite inspections and event reviews. Cameco continues to develop and maintain a comprehensive occupational health and safety management program for the PHCF. This program at the PHCF incorporates various elements, including accident reporting and investigation, hazard prevention, preventive maintenance, health and safety committees, training, personal protective equipment, and emergency preparedness and response.

A key performance measure for the conventional health and safety SCA is the number of LTIs that occur per year. Table 4-3 outlines the number of LTIs over the past five years at the PHCF.

Cameco reported one LTI in 2017. An employee sustained a muscle injury while removing a drum from a conveyor in the UO2 plant. The drum weighed approximately 17 kg. It was lifted off the conveyor, at shin height, and over a safety cable, at waist height, before being placed on the floor. After the event, the employee continued to work, but with restrictions, and received surgery in July. Doctors instructed the employee to take time off after the surgery, resulting in six days lost time.

Cameco conducted an investigation and implemented corrective actions. One action was to instruct its employees to convey drums around the conveying system to the designated drum removal location without lifting the drums. Employees were also instructed to remove/relocate two obstructing buttons and shorten the safety cable, in order to provide an opening for drum removal without lifting. CNSC staff reviewed the corrective actions and were satisfied with the actions taken by Cameco to prevent recurrence.

Table 4-3: LTIs, PHCF, 2013–17
2013 2014 2015 2016 2017
LTIs 0 1 2 3 1

#### Practices

Cameco’s activities and operations at the PHCF must comply with the NSCAFootnote 1 and its associated regulations, and with Part II of the Canada Labour Code Footnote 5 . Cameco uses audits, inspections, evaluations, reviews, benchmarking, training, and employee engagement to evaluate the effectiveness of conventional health and safety practices at the PHCF.

The Conversion Safety Steering Committee supports conventional health and safety efforts at the PHCF. This joint committee, created in 2013, conducts monthly workplace inspections and meets three times per month to improve the safety performance of the site through review of issues, increasing employee involvement in safety, and development of new processes to follow up on injuries, among other activities. In addition, the committee promotes continuous improvement.

All reported conventional health and safety incidents are tracked and managed as part of the Cameco Incident Reporting System database. CNSC staff review health and safety documentation to verify that any issues raised are promptly resolved.

#### Awareness

Workers are made aware of the conventional health and safety program, as well as workplace hazards, through training and ongoing internal communications with Cameco. Cameco holds monthly safety meetings for all employees at the PHCF on various safety topics, including radiation protection, environmental protection and fire protection. Attendance is tracked at the safety meetings as an indicator for safety performance. Cameco workers at the PHCF also attend daily “toolbox meetings” where they are notified of any concerns or ongoing maintenance in their area.

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## 5 Cameco Fuel Manufacturing Inc.

The Cameco Fuel Manufacturing Inc. (CFM) facility is a wholly owned subsidiary of the Cameco Corporation. CFM operates two facilities: a nuclear fuel fabricating facility licensed by the CNSC in Port Hope, Ontario; and a metals manufacturing facility in Cobourg, Ontario, which manufactures zircaloy tubes (non-nuclear activity). This latter facility is not licensed by the CNSC and is not discussed further in this report. Figure 5-1 shows an aerial view of the CFM facility in Port Hope.

Figure 5-1: Aerial view of the CFM facility

The CFM facility in Port Hope operates under a CNSC licence that expires in February 2022. The facility manufactures nuclear reactor fuel bundles from uranium dioxide (UO2) and zircaloy tubes. The finished fuel bundles are primarily shipped to Canadian nuclear power reactors.

The risks associated with the licensed activities at this Class IB facility are mainly due to conventional industrial hazards and radiological hazards of UO2.

### 5.1 Overall performance

For 2017, CNSC staff rated Cameco’s performance at the CFM facility as “satisfactory” in all SCAs. The performance ratings for the CFM facility from 2013 to 2017 are shown in table C-3 of appendixC.

Cameco continued to operate the CFM facility safely throughout 2017. The facility underwent two planned shutdowns during the year to conduct routine maintenance activities and implement facility upgrades. Cameco ensured that the CFM site was maintained according to the CFM licensing basis.

### 10.1 Overall performance

For 2017, CNSC staff rated BTL’s performance as “satisfactory” in all SCAs. The performance ratings for BTL from 2015 to 2017 are shown in table C-7 of appendix C.

In 2017, CNSC staff conducted four onsite inspections at the BTL facility to verify compliance with the NSCA Footnote 1 and its associated regulations, BTL’s operating licence and the programs used to meet regulatory requirements. A list of these inspections can be found in table K-7 of appendix K. The inspections focused on management systems, security, emergency management, and packaging and transport SCAs. As a result of the inspections, 12 enforcement actions were raised. The findings from these inspections posed a low safety significance to the achievement of regulatory objectives and CNSC expectations.

There were no reportable action level exceedances in 2017. There was one LTI in 2017.

CNSC and BTL staff responded to the issues and concerns raised in the AOO’s intervention by the Algonquins of Ontario (AOO) to the Commission on the Uranium and Nuclear Processing Facilities Regulatory Oversight Report: 2016. Issues of concern or interest raised by the AOO included:

• fulfillment of regulatory standards to maintain environmental protection
• establishment of communication protocols
• meaningful engagement and participation by the AOO in environmental monitoring and protection programs
• reporting of dose exceedances or abnormalities
• archaeological assessment
• Indigenous knowledge, land use and occupancy study
• accessibility of compliance verification and enforcement program information
• radiation exposure from transportation accidents and spills

CNSC staff are aware of BTL’s commitment to the AOO for ongoing communication and engagement with respect to BTL’s facility and related activities and remain committed to working with the AOO to address any remaining issues of interest or concern.

In the interest of reconciliation and relationships based on openness and trust with Indigenous peoples in Canada, CNSC staff will continue to ensure that all issues of interest or concern to Indigenous communities and organizations in relation to BTL’s facility are identified, recorded, considered and addressed, where appropriate.

BTL strives to be open and transparent with its stakeholders. BTL provides material on its website related to its licensed activities, discloses its annual compliance report online, and offers facility tours on a regular basis to local, national and international stakeholders. The licensee is in compliance with RD/GD-99.3, the predecessor of REGDOC-3.2.1, Public Information and Disclosure Footnote 7 , and implementation plans for REGDOC-3.2.1 are expected to be completed in 2019.

Compliance ratings for the radiation protection SCA, BTL, 2013–17
2013 2014 2015 2016 2017
SA SA SA SA SA

For 2017, CNSC staff continued to rate the radiation protection SCA at BTL as “satisfactory”. BTL has implemented and maintained a radiation protection program as required by the Radiation Protection Regulations Footnote 2 . Workers at BTL work with sealed sources of radiation, which present external radiological hazards to the whole body and to the extremities. Radiological hazards were effectively controlled at BTL. As a result, radiation doses to workers were kept well below the CNSC regulatory dose limits. Activities at the BTL facility have no impact on doses to members of the public.

SA = satisfactory

#### Application of ALARA

In 2017, BTL continued to implement radiation protection measures to keep radiation exposures and doses to persons ALARA. BTL has documented expectations for its ALARA program, including a clear substantiation for the existence of the program, clearly delineated management control over work practices, and provisions for dose trend analysis.

#### Worker dose control

Radiation exposures are monitored to ensure compliance with the CNSC’s regulatory dose limits and to keep radiation doses ALARA. Dose data in 2017 include the doses received by manufacturing workers performing activities under the Class IB licence only. Before 2017, BTL’s annual compliance report related to this licence included doses for both the manufacturing workers and service technicians performing work activities under a separate Class II servicing licence. In 2017, radiation exposures at BTL were well below the CNSC regulatory dose limits.

BTL workers are exposed externally to sealed sources of radiation. External whole-body and equivalent doses are ascertained with the use of dosimeters.

At BTL, employees are classified as NEWs if they are expected to have a reasonable probability of receiving an annual occupational dose greater than 1mSv. Such workers include service technicians and source handlers. In 2017, the maximum effective dose received by a NEW at BTL was 0.47 mSv, or approximately 1% of the regulatory limit for the effective dose of 50 mSv in a one-year dosimetry period.

Figure 10-3 provides the average and maximum effective doses for NEWs at BTL from 2013 to 2017.

Description
Figure 10-3: Average and maximum effective doses to NEWs, BTL, 2013–17
2013 2014 2015 2016 2017
Average effective dose (mSv) 0.01 0.00 0.01 0.03 0.02
Maximum effective dose (mSv) 0.33 0.11 0.20 0.98 0.47
Number of NEWs monitored 58 61 62 60 68

Annual average and maximum equivalent dose results from 2013 to 2017 are shown in table E-6 of appendix E. The maximum equivalent extremity dose for 2017 was 0.50 mSv. Over the past five years, average extremity equivalent doses have been relatively stable, between approximately 0 mSv and 6.1 mSv. Equivalent skin doses are also ascertained, but due to the nature of exposure, they are essentially equal to the effective dose and are not included in the report.

BTL workers identified as non-NEWs, such as administrative staff, are restricted from accessing controlled areas where radioactive material is stored or areas where the public annual dose limit of 1 mSv may be exceeded. In 2017, non-NEWs did not receive any reportable doses.

Radiation protection program performance at BTL was assessed in 2017 through various CNSC staff compliance activities and desktop reviews. CNSC staff found that BTL’s compliance with the Radiation Protection Regulations Footnote 2 and the CNSC licence requirements was acceptable.

Action levels for effective dose for various categories of workers have been established to alert BTL management of a potential loss of control of the radiation protection program. In 2017, there were no action level exceedances at BTL.

BTL’s radiation protection program ensures that measures are in place to monitor and control radiological hazards. This includes contamination and radiation dose rate monitoring and controls.

The majority of the radioisotopes in use at BTL are sealed sources; therefore, the potential for contamination is very low. Nonetheless, the licensee has implemented a thorough surface contamination monitoring procedure to monitor any potential contamination at its facility. Contamination checks are performed monthly in designated areas where radioactive materials may be handled, and following work where the potential for contamination exists. Over the last five years, there has been no indication of the presence of contamination from routine contamination swipes at the BTL facility.

Monthly dose rate measurements are also performed in all radiation areas. In addition, fixed dose rate monitors are in place with set alarm thresholds in a variety of designated locations within the BTL facility. These measurements and alarm thresholds help to ensure a safe work place.

#### Estimated dose to the public

No activities occur inside the BTL facility that result in the release of radioactive material to the environment. In addition, gamma radiation is kept ALARA to protect staff within the BTL facility. Consequently, the dose impact to members of the public attributable to BTL’s licensed activities is insignificant and/or too low to be measured.

### 10.3 Environmental protection

Compliance ratings for the environmental protection SCA, BTL, 2013–17
2014 2015 2016 2017
SA SA SA SA

For 2017, CNSC staff continued to rate the environmental protection SCA at the BTL facility as “satisfactory”. BTL does not have identified radioactive releases to the environment. Therefore, the risk of radiation exposure to members of the public from normal operations is very low. In 2017, there were no releases of hazardous substances to the environment that would pose a risk to the public or the environment. Environmental monitoring is not conducted around the facility. BTL has implemented an EMS to conform to CNSC REGDOC-2.9.1, Environmental Protection Policies, Programs and ProceduresFootnote 20 .

SA = satisfactory

#### Effluent and emissions control (releases)

There are no radioactive releases (liquid or airborne) at the BTL facility that require controls or monitoring. The radioactive material used at the facility is limited to sealed sources and to depleted uranium that is used as shielding for the sealed sources.

There are no hazardous liquid releases that require controls. Hazardous liquid effluents from routine operations are collected, temporarily stored onsite and removed for disposal by a certified third-party contractor.

Airborne hazardous 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.

#### Environmental management system

In 2015, BTL implemented a new environmental management system (EMS) to conform to REGDOC-2.9.1, Environmental Protection Policies, Programs and Procedures Footnote 20 , a requirement of its Class IB licence. CNSC staff have verified that BTL continues to meet the requirements outlined in this regulatory document. BTL’s EMS considers environmental impacts from its activities with a commitment to pollution prevention and continuous improvement. If environmental issues are identified they are monitored, interpreted and acted upon to protect the environment and the health and safety of persons.

#### Assessment and monitoring

Since BTL manufacturing operations do not produce airborne or liquid radiological releases to the environment that require controls or monitoring, BTL does not conduct environmental monitoring around its facility.

#### Protection of the public

Since the BTL facility uses only sealed sources, the risk of radiation exposure to members of the public from normal operations is very low. CNSC staff concluded that the public continues to be protected from facility emissions.

#### Environmental risk assessment

BTL included an ERA in its application for a Class IB licence in 2014, which included mitigation measures for identified risks such as filtration and ventilation for airborne hazardous emissions. CNSC staff reviewed BTL’s submission and are satisfied with the measures BTL has put in place for the protection of the public and the environment.

In 2013, BTL contracted a third party to conduct modelling to support its Environmental Compliance Approval application to the MECP. The results indicated that emissions from the facility would not result in changes to local air quality that would affect the health and safety of the public or the environment.

### 10.4 Conventional health and safety

Compliance ratings for the conventional health and safety SCA, BTL, 2014–17
2014 2015 2016 2017
SA SA SA SA

For 2017, CNSC staff continued to rate the conventional health and safety SCA at BTL as “satisfactory”. The compliance verification activities conducted by CNSC staff confirmed that BTL views conventional health and safety as an important consideration. BTL has demonstrated that it implements an effective occupational health and safety management program, which has resulted in the ability to keep its workers safe from occupational injuries.

SA = satisfactory

#### Performance

BTL’s performance related to conventional health and safety is monitored through CNSC staff’s onsite inspections and event reviews. BTL continues to develop and maintain a comprehensive occupational health and safety management program for its facility. Its program incorporates various elements, including accident reporting and investigation, hazard prevention, preventive maintenance, health and safety committees, training, personal protective equipment, and emergency preparedness and response.

A key performance measure for this SCA is the number of LTIs that occur per year. As indicated in table 10-1, there was one LTI reported at the BTL facility in 2017. The LTI was due an injured finger when an employee cut their thumb on a sawmill when they moved a piece of material from the machine. The accident resulted in 22 days of lost time. For that LTI, BTL conducted an investigation and implemented corrective actions (which are summarized in tableH-3 of appendixH). CNSC staff reviewed the corrective actions and are satisfied with the actions taken by BTL to prevent recurrence.

Table 10-1: LTIs, BTL, 2014–17
2014 2015 2016 2017
LTIs 1 1 3 1

#### Practices

BTL’s activities and operations must comply with the NSCA Footnote 1 and its associated regulations, and with Part II of the Canada Labour Code Footnote 5 . BTL has a Health and Safety Committee that inspects the workplace and meets monthly to resolve and track any safety issues. CNSC staff review the monthly meeting minutes of this committee and any associated corrective actions to ensure that issues had been promptly resolved. CNSC staff have confirmed that when issues have been raised through BTL’s workplace health and safety inspections, BTL addresses the issues and takes corrective actions.

#### Awareness

BTL continues to develop and maintain a comprehensive occupational health and safety management program for its facility. Workers are made aware of the conventional health and safety program, and workplace hazards, through training and ongoing internal communications with BTL.

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## 11 Overall conclusions

CNSC staff concluded that uranium processing facilities and nuclear substance processing facilities in Canada operated safely during the 2017 calendar year. This assessment is based on CNSC staff’s verification of licensee activities that included onsite inspections, reviews of reports submitted by licensees, and reviews of events and incidents, supported by follow-up and general communication activities with the licensees.

In 2017, the performance ratings in all 14 SCAs for the facilities were as follows:

• with the exception of a “below expectations” rating for the management system SCA for Cameco’s PHCF, uranium processing facilities were rated as “satisfactory” or better
• nuclear substance processing facilities were rated as “satisfactory” or better

CNSC staff’s compliance activities confirmed that:

• 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

Through their regulatory oversight activities, CNSC staff confirmed that Canada’s uranium and nuclear substance processing facilities continued to operate safely throughout 2017, despite the “below expectations” rating discussed above.

CNSC staff concluded that, in 2017, the licensees discussed in this report made adequate provision for the health and safety of workers as well as 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.

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## References

Footnote 1

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

Footnote 2

Footnote 3

CSA Group, CSA N288.6-12, Environmental risk assessments at Class I nuclear facilities and uranium mines and mills, 2012.

Footnote 4

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

Footnote 5

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

Footnote 6

CNSC, RD/GD-99.3, Public Information and Disclosure, Ottawa, Canada, 2012.

Footnote 7

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

Footnote 8

Footnote 9

Footnote 10

CSA Group, CSA N288.4-10, Environmental monitoring programs at Class I nuclear facilities and uranium mines and mills, 2010.

Footnote 11

CSA Group, CSA N288.5-11, Effluent monitoring programs at Class I nuclear facilities and uranium mines and mills, 2011.

Footnote 12

CSA Group, CSA N292.0-14, General principles for the management of radioactive waste and irradiated fuel, 2014.

Footnote 13

CSA Group, CSA N292.3-14, Management of low and intermediate radioactive waste, 2014.

Footnote 14

Footnote 15

CNSC, G-206, Financial Guarantees for the Decommissioning of Licensed Activities, Ottawa, Canada, June 2000.

Footnote 16

CNSC, Notice of Hearing, Cameco Fuel Manufacturing Facility Financial Guarantee, September 25, 2017.

Footnote 17

CNSC, Record of Decision, In the Matter of Cameco Fuel Manufacturing Inc., Financial Guarantee for the Future Decommissioning of the Cameco Fuel Manufacturing Inc. Port Hope Facility, November 17, 2017.

Footnote 18

CNSC, REGDOC-2.10.1, Nuclear Emergency Preparedness and Response, Ottawa, Canada, 2016.

Footnote 19

CNSC, Record of Proceedings, including Reasons for Decision, In the Matter of SRB Technologies (Canada) Inc., Application to Renew the Class IB Nuclear Substance Processing Facility Operating Licence for the Gaseous Tritium Light Source Facility in Pembroke, Ontario, June 29, 2015.

Footnote 20

CNSC, REGDOC-2.9.1, Environmental Protection Policies, Programs and Procedures, Ottawa, Canada, 2016.

Footnote 21

CSA Group, CSA N288.7-15, Groundwater protection programs at Class I nuclear facilities and uranium mines and mills, 2015.

Footnote 22

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, 2014.

Footnote 23

CNSC, Record of Proceedings, Including Reasons for Decision, In the Matter of Best Theratronics Ltd., Review by the Commission of the Designated Officer Order Issued on August 24, 2015, September 28, 2015.

Footnote 24

CNSC, Record of Proceedings, Including Reasons for Decision, In the Matter of Best Theratronics Ltd., Redetermination, under subsection 43(3) of the Nuclear Safety and Control Act, of the Order issued by the Commission on September 28, 2015, February 29, 2016.

Footnote 25

CNSC, Record of Decision, In the Matter of Best Theratronics Ltd., Amendment under Section 25 of the Nuclear Safety and Control Act and Request for Acceptance of the Financial Guarantee, July 14, 2017.

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## Acronyms and abbreviations

ALARA
as low as reasonably achievable, taking into account social and economic factors
AMP
AOO
Algonquins of Ontario
BE
below expectations
Bq
becquerel
BRR
Blind River Refinery
BTL
Best Theratronics Ltd.
BWXT
Cameco
Cameco Corporation
CANDU
CCAB
CCME
Canadian Council of Ministers of the Environment
CFM
Cameco Fuel Manufacturing Inc.
Ci
curie
cm
centimetre
CMD
Commission member document
CNSC
CSA
Canadian Standards Association (now CSA Group)
CTS
critical-to-safety
DRL
derived release limit
EMS
environmental management system
ERA
environmental risk assessment
ESDC
Employment and Social Development Canada (formerly Human Resources and Skills Development Canada)
FFOL
fuel facility operating licence
FS
fully satisfactory
g
gram
GBq
gigabecquerel
GCDWQ
Guidelines for Canadian Drinking Water Quality
GEH-C
GE Hitachi Nuclear Energy Canada Inc.
GTLS
gaseous tritium light source
h
hour
HF
hydrogen fluoride
HT
tritium gas
HTO
hydrogenated tritium oxide or tritiated water
HNO3
nitric acid
IAEA
International Atomic Energy Agency
ICP-MS
Inductively Coupled Plasma Mass Spectrometry
IEMP
Independent Environmental Monitoring Program
kg
kilogram
L
litre
LCH
licence conditions handbook
LTI
lost-time injury
m3
cubic metres
MBq
megabecquerel
MeV
megaelectronvolt
mg
milligram
mg/L
milligram per litre
MFN
Mississauga First Nation
MECP
Ontario Ministry of Environment, Conversation and Parks
mSv
millisievert
N
nitrogen
NEW
nuclear energy worker
NOx
nitrogen oxides
NO2
nitrogen dioxide
Nordion
NSCA
Nuclear Safety and Control Act
NSPFOL
nuclear substance processing facility operating licence
OEL
occupational exposure limit
ORL
operating release limit
OPEX
operating experience
OPG
Ontario Power Generation
PAR
Progressive Aboriginal Relations
PFP
Participant Funding Program
PHCF
Port Hope Conversion Facility
ppm
parts per million
RP
SA
satisfactory
SAT
systematic approach to training
SCA
safety and control area
SI
International System of Units
SRBT
T2
tritiated gas
TBq
terabecquerel
UA
unacceptable
µg
microgram
µSv
microsievert
UF6
uranium hexafluoride
UO2
uranium dioxide
UO3
uranium trioxide
VIM
Vision in Motion
WHMIS
Workplace Hazardous Material Information System
WSC
Workplace Safety Committee

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Top of page

## A. Safety And Control Area Framework

The CNSC evaluates how well licensees meet regulatory requirements and CNSC expectations for the performance of their programs in 14 SCAs. These SCAs are grouped according to their functional areas of management, facility and equipment, and core control processes. They are further divided into specific areas that define the key components of the SCA. The following table shows the CNSC SCA Framework.

Functional area Safety and control area Definition Specific areas
Management Management system

Covers the framework that establishes the processes and programs required to ensure an organization achieves its safety objectives, continuously monitors its performance against these objectives, and fosters a healthy safety culture.

• Management system
• Organization
• Performance assessment, improvement and management review
• Operating experience (OPEX)
• Change management
• Safety culture
• Configuration management
• Records management
• Management of contractors
Human performance management

Covers activities that enable effective human performance through the development and implementation of processes that ensure a sufficient number of licensee personnel are in all relevant job areas and have the necessary knowledge, skills, procedures and tools in place to safely carry out their duties.

• Human performance program
• Personnel training
• Personnel certification
• Initial certification examinations and requalification tests
• Work organization and job design
• Fitness for duty
Operating performance

Includes an overall review of the conduct of the licensed activities and the activities that enable effective performance.

• Procedures
• Reporting and trending
• Outage management performance
• Safe operating envelope
• Severe accident management and recovery
• Accident management and recovery
Facility and equipment Safety analysis

Covers maintenance of the safety analysis that supports the overall safety case for the facility. Safety analysis is a systematic evaluation of the potential hazards associated with the conduct of a proposed activity or facility and considers the effectiveness ofpreventative measures and strategiesin reducing the effects ofsuch hazards.

• Deterministic safety analysis
• Hazard analysis
• Probabilistic safety analysis
• Criticality safety
• Severe accident analysis
• Management of safety issues (including R&D programs)
Physical design

Relates to activities that impact the ability of structures, systems and components to meet and maintain their design basis given new information arising over time and taking changes in the external environment into account.

• Design governance
• Site characterization
• Facility design
• Structure design
• System design
• Component design
Fitness for service

Covers activities that impact the physical condition of structures, systems and components to ensure that they remain effective over time. This area includes programs that ensure all equipment is available to perform its intended design function when called upon to do so.

• Equipment fitness for service / equipment performance
• Maintenance
• Structural integrity
• Aging management
• Chemistry control
• Periodic inspection and testing

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

• Application of ALARA
• Worker dose control
• Estimated dose to public
Conventional health and safety

Covers the implementation of a program to manage workplace safety hazards and to protect personnel and equipment.

• Performance
• Practices
• Awareness
Environmental protection

Covers programs that identify, control and monitor all releases of radioactive and hazardous substances and effects on the environment from facilities or as the result of licensed activities.

• Effluent and emissions control (releases)
• Environmental management system (EMS)
• Assessment and monitoring
• Protection of the public
• Environmental risk assessment

Emergency management and fire protection

Covers emergency plans and emergency preparedness programs that exist for emergencies and for non-routine conditions. This area also includes any results of participation in exercises.

• Conventional emergency preparedness and response
• Nuclear emergency preparedness and response
• Fire emergency preparedness and response
Waste management

Covers internal waste-related programs that form part of the facility’s operations up to the point where the waste is removed from the facility to a separate waste management facility. This area also covers the planning for decommissioning.

• Waste characterization
• Waste minimization
• Waste management practices
• Decommissioning plans
Security

Covers the programs required to implement and support the security requirements stipulated in the regulations, the licence, orders, or expectations for the facility or activity.

• Facilities and equipment
• Response arrangements
• Security practices
• Drills and exercises
Safeguards and non-proliferation

Covers the programs and activities required for the successful implementation of the obligations arising from the Canada/International Atomic Energy Agency (IAEA) safeguards agreements, as well as all other measures arising from the Treaty on the Non-Proliferation of Nuclear Weapons.

• Nuclear material accountancy and control
• Access and assistance to the IAEA
• Safeguards equipment, containment and surveillance
• Import and export
Packaging and transport

Programs that cover the safe packaging and transport of nuclear substances to and from the licensed facility.

• Package design and maintenance
• Packaging and transport
• Registration for use
Other Matters of Regulatory Interest
• Environmental assessment
• CNSC consultation – Aboriginal
• CNSC consultation – other
• Cost recovery
• Financial guarantees
• Improvement plans and significant future activities
• Nuclear liability insurance

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## B. Rating methodology and definitions

### Fully satisfactory (FS)

Safety and control measures implemented by the licensee are highly effective. In addition, compliance with regulatory requirements is fully satisfactory, and compliance within the safety and control area (SCA) or specific area exceeds requirements and CNSC expectations. Overall, compliance is stable or improving, and any problems or issues that arise are promptly addressed.

### Satisfactory (SA)

Safety and control measures implemented by the licensee are sufficiently effective. In addition, compliance with regulatory requirements is satisfactory. Compliance within the SCA meets requirements and CNSC expectations. Any deviation is minor and any issues are considered to pose a low risk to the achievement of regulatory objectives and CNSC expectations. Appropriate improvements are planned.

### Below expectations (BE)

Safety and control measures implemented by the licensee are marginally ineffective. In addition, compliance with regulatory requirements falls below expectations. Compliance within the SCA deviates from requirements or CNSC expectations to the extent that there is a moderate risk of ultimate failure to comply. Improvements are required to address identified weaknesses. The licensee is taking appropriate corrective action.

### Unacceptable (UA)

Safety and control measures implemented by the licensee are significantly ineffective. In addition, compliance with regulatory requirements is unacceptable and is seriously compromised. Compliance within the SCA is significantly below requirements or CNSC expectations, or there is evidence of overall non-compliance. Without corrective action, there is a high probability that the deficiencies will lead to unreasonable risk. Issues are not being addressed effectively, no appropriate corrective measures have been taken and no alternative plan of action has been provided. Immediate action is required.

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## C. Safety and control area ratings

Table C-1: SCA ratings, BRR facility, 2013–17
SCAs 2013 rating 2014 rating 2015 rating 2016 rating 2017 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 FS
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 C-2: SCA ratings, PHCF, 2013–17
SCAs 2013 rating 2014 rating 2015 rating 2016 rating 2017 rating
Management system SA SA SA SA BE
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 C-3: SCA ratings, CFM, 2013–17
SCAs 2013 rating 2014 rating 2015 rating 2016 rating 2017 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 C-4: SCA ratings, BWXT Toronto and Peterborough, 2013–17
SCAs 2013 rating 2014 rating 2015 rating 2016 rating 2017 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 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 C-5: SCA ratings, SRBT, 2013–17
SCAs 2013 rating 2014 rating 2015 rating 2016 rating 2017 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 FS FS FS FS
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 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 C-6: SCA ratings, Nordion, 2013–17
SCAs 2013 rating 2014 rating 2015 rating 2016 rating 2017 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 SA SA SA SA
Environmental protection FS FS FS FS FS
Emergency management and fire protection SA SA SA SA SA
Waste management SA SA SA SA SA
Security FS FS FS FS FS
Safeguards and non-proliferation SA SA SA SA SA
Packaging and transport SA SA SA SA SA

FS = fully satisfactory; SA = satisfactory

Table C-7: SCA ratings, BTL, 2014–17
SCAs 2014 rating 2015 rating 2016 rating 2017 rating
Management system SA SA SA SA
Human performance management SA SA SA SA
Operating performance SA SA SA SA
Safety analysis SA SA SA SA
Physical design SA SA SA SA
Fitness for service SA SA SA SA
Radiation protection SA SA SA SA
Conventional health and safety SA SA SA SA
Environmental protection SA SA SA SA
Emergency management and fire protection SA BE SA SA
Waste management SA SA SA SA
Security SA SA SA SA
Safeguards and non-proliferation SA SA SA SA
Packaging and transport SA SA SA SA

BE = below expectations; SA = satisfactory

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## D. Financial guarantees

Table D-1: Financial guarantees, uranium processing facilities
BRR $48,000,000 PHCF$128,600,000
CFM $21,000,000 BWXT Toronto$45,568,100
BWXT Peterborough $6,803,500 Table D-2: Financial guarantees, nuclear substance processing facilities Facility Amount (CAD) SRBT$677,676
Nordion $45,124,748 BTL$1,800,000

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## E. Worker dose data

Extremity doses: uranium processing facilities

Table E-1: Equivalent (extremity) dose statistics for NEWs, BRR facility, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average extremity dose (mSv) 14.1 5.4 1.5 1.2 1.0 N/A
Maximum individual extremity dose (mSv) 35.1 48.2 15.3 10.6 13.6 500 mSv/year

mSv = millisievert; N/A = not applicable

Table E-2: Equivalent (extremity) dose statistics for NEWs, CFM, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average extremity dose (mSv) 14.3 15.5 15.5 13.2 10.6 N/A
Maximum individual extremity dose (mSv) 87.6 88.4 87.0 98.4 59.0 500 mSv/year

mSv = millisievert; N/A = not applicable

Table E-3: Equivalent (extremity) dose statistics for NEWs, BWXT Toronto, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average extremity dose (mSv) 32.92 31.96 30.30 27.71 27.36 N/A
Maximum individual extremity dose (mSv) 143.59 102.44 109.62 119.47 115.07 500 mSv/year

mSv = millisievert; N/A = not applicable

Table E-4: Equivalent (extremity) dose statistics for NEWs, BWXT Peterborough, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average extremity dose (mSv) 10.47 18.64 12.61 9.78 13.62 N/A
Maximum individual extremity dose (mSv) 76.03 98.98 39.34 32.84 43.18 500 mSv/year

mSv = millisievert; N/A = not applicable

Extremity doses: nuclear substance processing facilities

Table E-5: Equivalent (extremity) dose statistics for NEWs, Nordion, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average extremity dose (mSv) 0.54 0.73 0.46 0.79 0.53 N/A
Maximum individual extremity dose (mSv) 7.4 9.5 9.3 8.3 16.4 500 mSv/year

mSv = millisievert; N/A = not applicable

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

Table E-6: Equivalent (extremity) dose statistics for NEWs, BTL, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average extremity dose (mSv) 0.34 0.21 0.00 0.09 0.07 N/A
Maximum individual extremity dose (mSv) 6.10 3.70 0.00 1.10 0.50 500 mSv/year

mSv = millisievert; N/A = not applicable

Skin doses: uranium processing facilities

Table E-7: Equivalent (skin) dose statistics for NEWs, BRR facility, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average skin dose (mSv) 6.8 5.4 4.0 3.3 3.1 N/A
Maximum individual skin dose (mSv) 41.4 41.2 28.1 26.0 16.2 500 mSv/year

mSv = millisievert; N/A = not applicable

Table E-8: Equivalent (skin) dose statistics for NEWs, PHCF, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average skin dose (mSv) 1.7 0.6 0.8 0.8 0.6 N/A
Maximum individual skin dose (mSv) 28.6 10.3 23.4 16.9 13.7 500 mSv/year

mSv = millisievert; N/A = not applicable

Table E-9: Equivalent (skin) dose statistics for NEWs, CFM, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average skin dose (mSv) 7.3 8.1 6.3 6.6 5.5 N/A
Maximum individual skin dose (mSv) 88.4 108.4 95.6 95.7 88.1 500 mSv/year

mSv = millisievert; N/A = not applicable

Table E-10: Equivalent (skin) dose statistics for NEWs, BWXT Toronto, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average skin dose (mSv) 10.29 11.08 9.89 10.23 7.85 N/A
Maximum individual skin dose (mSv) 52.84 51.67 54.99 74.26 54.27 500 mSv/year

mSv = millisievert; N/A = not applicable

Table E-11: Equivalent (skin) dose statistics for NEWs, BWXT Peterborough, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average skin dose (mSv) 3.8 4.75 4.1 2.66 2.77 N/A
Maximum individual skin dose (mSv) 31.20 29.91 22.47 21.15 25.14 500 mSv/year

mSv = millisievert; N/A = not applicable

Skin doses: nuclear substance processing facilities

Table E-12: Equivalent (skin) dose statistics for NEWs, Nordion, 2013–17
Dose data 2013 2014 2015 2016 2017 Regulatory limit
Average skin dose (mSv) 0.42 0.46 0.42 0.59 0.42 N/A
Maximum individual skin dose (mSv) 6.39 6.11 5.21 5.20 5.52 500 mSv/year

mSv = millisievert; N/A = not applicable

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## F. Environmental data

Blind River Refinery

Table F-1: Annual groundwater monitoring results, 2013–17
Parameter 2013 2014 2015 2016 2017 GCDWQ*
Average uranium concentration (µg/L) 0.5 0.6 1.7 1.3 1.2 20
Maximum uranium concentration (µg/L) 3.7 8.9 18.5 14.0 11.0 20

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

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

Table F-2: Surface water annual average results at outfall diffuser in Lake Huron, 2013–17
Parameter 2013 2014 2015 2016 2017 CCME guidelines*
Average uranium concentration (µg/L) 0.4 <0.2 0.2 <0.8** <0.8 15
Average nitrate concentration (mg/L as N) 0.3 0.2 0.2 0.2 0.2 13
Average radium-226 concentration (Bq/L) <0.005 <0.005 <0.005 <0.005 <0.005 N/A
Average pH 7.2 7.6 7.3 8.0 7.3 6.5–9.0

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

**The ambient water method detection limit was reassessed by the Blind River Refinery in 2016.

Table F-3: Soil monitoring results, 2013–17
Parameter 2013 2014 2015 2016 2017 CCME guidelines*
Minimum uranium concentration (µg/g) 0.1 0.1 0.1 0.2 0.3 23
Average uranium concentration (µg/g) (within 1,000m, 0–5 cm depth) 4.3 2.7 3.8 1.5 1.6
Maximum uranium concentration (µg/g) 16.4 7.2 9.7 2.9 2.8

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 (for residential/parkland land use)

Port Hope Conversion Facility

Table F-4: Mass (kg) of contaminants removed by pumping wells, 2013–17
Parameter 2013 2014 2015 2016 2017
Uranium 28.9 31.0 25.3 22.8 34.0
Fluoride 51.1 53.0 48.3 36.9 61.0
Ammonia 53.0 75.0 63.7 73.6 70.0
Nitrate 41.0 53.0 44.0 42.6 56.0
Arsenic 2.8 2.5 2.6 1.9 3.0

kg = kilogram

Table F-5: Harbour water quality, 2013–17
Parameter Value 2013 2014 2015 2016 2017 CCME* guidelines
Uranium (µg/L) Average 3.3 3.3 2.9 2.6 3.3 15
Maximum 8.3 7.6 6.6 10 8.8
Fluoride (mg/L) Average 0.10 0.11 0.13 0.15 0.19 0.12
Maximum 0.18 0.39 0.17 0.22 0.29
Nitrate (mg/L) Average 0.84 0.86 0.89 0.85 1.0 13
Maximum 1.6 1.5 1.7 1.6 2.2
Ammonia + Ammonium (mg/L) Average 0.11 0.23 0.20 0.16 0.18 0.3
Maximum 0.35 0.52 0.66 0.58 0.40

CCME = Canadian Council of Ministers of the Environment; mg/L = milligrams per litre

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

Table F-6: Uranium concentrations at waterworks side yard remediated with clean soil (µg/g), 2013–17
Soil depth (cm) 2013 2014 Soil depth (cm) 2015 2016 2017 CCME guidelines*
0–2 1.0 1.4 0–5 1.0 1.2 0.8 23
2–6 0.9 1.2
6–10 1.0 1.1 5–10 1.0 1.1 0.8
10–15 1.0 1.1 10–15 1.2 1.0 0.9
70 cm composite 1.5 1.4

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 (for residential/parkland land use)

Table F-7: Fluoride concentration in local vegetation, 2013–17
Parameter 2013 2014 2015 2016 2017 MECP guidelines*
Fluoride in vegetation (ppm) 5.6 2.6 3.2 3.0 11.0 35

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

*MECP’s Upper Limit of Normal Guidelines

Table F-8: Gamma monitoring results, annual average, 2013–16
Parameter 2013 2014 2015 2016 Licence limit
Site 1 (μSv/h) 0.007 0.003 0.007 0.005 0.14
Site 2 (Dorset Street) (μSv/h) 0.058 0.054 0.044 0.054 0.40

µSv = microsievert

Table F-9: Gamma monitoring results, maximum monthly, 2017
Station number and site 2017 Licence limit
Station 2 – Sites 1 and 2 (µSv/h) 0.25 0.57
Station 13 – Site 1 (µSv/h) 0.03 0.40
Station 21 – Site 2 (µSv/h) 0.08 0.26

Cameco Fuel Manufacturing Inc.

Table F-10: Soil monitoring results*
Parameter 2008 2009 2010 2013 2016 CCME guidelines**
Average uranium concentration (µg/g) 5.4 5.2 4.5 3.7 2.5 23
Maximum uranium concentration (µg/g) 20.8 17.0 21.1 17.4 11.2 23

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

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

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

BWXT Toronto

Table F-11: Air emission and liquid effluent monitoring results, 2013–17
Parameter 2013 2014 2015 2016 2017 Licence limit
Uranium discharged to air (kg/year) 0.0104 0.0109 0.0108 0.0108 0.00744 0.76
Uranium discharged to sewer (kg/year) 0.83 0.72 0.39 0.65 0.941 9,000

kg = kilogram

Note: The values for uranium discharge to air have been corrected from those reported in the Regulatory Oversight Report for Nuclear Processing, Small Research Reactor and Class IB Accelerator Facilities: 2015. The data reflect updated values provided by BWXT Nuclear Energy Canada Inc. to address a discrepancy in monitoring results caused by incorrect use of a flowmeter in 2016 when estimating the furnace exhaust stacks emissions from 2012 to 2015.

Table F-12: Uranium in boundary air monitoring results, 2013–17
Parameter 2013 2014 2015 2016 2017
Average concentration (µg/m3) 0.0007 0.0006 0.0010 0.0010 <0.0001

µg = microgram

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

Table F-13: Uranium in soil monitoring results, BWXT property, 2013–17
Parameter 2013 2014 2015 2016 2017
Number of samples 1 1 1 1 1
Average uranium concentration (µg/g) 2.3 2.3 1.4 1.2 1.7
Maximum uranium concentration (µg/g) 2.3 2.3 1.4 1.2 1.7
CCME guidelines (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

Table F-14: Uranium in soil monitoring results, industrial/commercial lands , 2013 –17
Parameter 2013 2014 2015 2016 2017
Number of samples 24 34 30 34 34
Average uranium concentration (µg/g) 3.9 5.0 2.9 2.7 3.0
Maximum uranium concentration (µg/g) 24.9 22.1 8.7 13.6 20.6
CCME guidelines (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

Table F-15: Uranium in soil monitoring results, residential locations , 2013 –17
Parameter 2013 2014 2015 2016 2017
Number of samples 24 14 18 14 14
Average uranium concentration (µg/g) 1.1 0.6 0.7 0.5 1.0
Maximum uranium concentration (µg/g) 3.1 2.1 2.1 0.7 1.6
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

BWXT Peterborough

Table F-16: Air emissions and liquid effluent monitoring results, 2013–17
Parameter 2013 2014 2015 2016 2017 Licence limit
Uranium discharged to air (kg/year) 0.000013 0.000003 0.000003 0.000004 0.000002 0.55
Uranium discharged to sewer (kg/year) 0.0002 0.0001 0.0001 0.0001 0.00011 760

kg = kilogram

Table F-17: Atmospheric emissions monitoring results, 2013–17
Parameter 2013 2014 2015 2016 2017 Licence limit (TBq/year)
Tritium as tritium oxide (HTO) (TBq/year) 17.82 10.71 11.55 6.29 7.19 67
Total tritium as HTO + HT (TBq/year) 78.88 66.16 56.24 28.95 24.82 448

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

Table F-18: Liquid effluent monitoring results for release to sewer, 2013–17
Parameter 2013 2014 2015 2016 2017 Licence limit (TBq/year)
Tritium-water soluble (TBq/year) 0.009 0.013 0.007 0.005 0.007 0.200

TBq = terabecquerel

Table F-19: Air emissions monitoring results, 2013–17
Parameter 2013 2014 2015 2016 2017 Licence limit (DRL) (GBq/year)
Cobalt-60 0.005 0.005 0.005 0.006 0.0034 70.1
Iodine-125 0.23 0.14 0.12 0.21 0.0012 4,880
Iodine-131 0.39 0.46 0.15 0.35 0.0008 3,790
Xenon-133 30,735 15,018 11,916 7,277 0 61,200,000
Xenon-135 28,193 13,075 8,237 4,299 0 7,660,000
Xenon-135m 43,383 18,170 10,758 5,421 0 4,600,000

DRL = derived release limit; GBq = gigabecquerel

Table F-20: Liquid effluent monitoring results for release to sewer, 2013–17
Parameter 2013 2014 2015 2016 2017 Licence limit (DRL) (GBq/year)
β < 1 MeV 0.288 0.209 0.191 0.222 0.212 66,000
β > 1 MeV 0.065 0.050 0.044 0.051 0.048 210,000
Iodine-125 0.005 0.051 0.111 0.144 0.145 73,600
Iodine-131 0.009 0.006 0.006 0.006 0.006 23,300
Molybdenum-99 0.077 0.055 0.060 0.052 0.049 1,120,000
Cobalt-60 0.022 0.018 0.019 0.026 0.022 155,000
Niobium-95 0.0006 0.0007 0.0010 0.001 0.001 558,000
Zirconium-95 0.0006 0.0005 0.0010 0.0015 0.002 749,000
Cesium-137 0.0005 0.0004 0.0004 0.0007 0.0007 137,000

DRL = derived release limit; GBq = gigabecquerel; MeV = megaelectronvolt

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

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 BRR has direct releases to surface water with the relevant radionuclides being uranium and radium-226.

Table G-1: Total annual load of relevant radionuclides released to atmosphere or surface waters for uranium processing facilities, 2013–17
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)
BRR
2013 4.1 3.6 1.93
2014 1.5 4.0 1.81
2015 1.3 2.6 1.06
2016 1.0 1.2 0.92
2017 0.8 1.9 1.04
PHCF
2013 68.4 N/A N/A
2014 33.4 N/A N/A
2015 38.7 N/A N/A
2016 34.3 N/A N/A
2017 31.5 N/A N/A
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)
CFM
2013 0.51 N/A N/A
2014 0.41 N/A N/A
2015 0.46 N/A N/A
2016 0.73 N/A N/A
2017 0.58 N/A N/A
BWXT Toronto
2013 0.0104 N/A N/A
2014 0.0109 N/A N/A
2015 0.0108 N/A N/A
2016 0.0108 N/A N/A
2017 0.0074 N/A N/A
BWXT Peterborough
2013 0.000013 N/A N/A
2014 0.000003 N/A N/A
2015 0.000003 N/A N/A
2016 0.000004 N/A N/A
2017 0.000002 N/A N/A

N/A = not applicable

Nuclear substance processing facilities

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, 2013–17
Year Hydrogenated tritium oxide (HTO in TBq) Tritium gas (HT in TBq)
2013 17.82 61.06
2014 10.71 55.45
2015 11.55 44.69
2016 6.29 22.66
2017 7.19 17.63

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

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, 2013–17
Year Cobalt-60 (GBq) Iodine-125 (GBq) Iodine-131 (GBq) Xenon-133 (GBq) Xenon-135 (GBq) Xenon-135m (GBq)
2013 0.005 0.23 0.39 30,735 28,193 43,383
2014 0.005 0.14 0.46 15,018 13,075 18,170
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

Best Theratronics Ltd.

BTL does not have any airborne or liquid radiological releases.

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## H. Lost-time injuries in 2017

Table H-1: LTIs, PHCF, 2017
LTI Action taken

An employee injured a muscle in their right bicep while removing a drum from a conveyor in the UO2 plant. The drum weighed approximately 17 kg. It was lifted off the conveyor, at shin height, and over a safety cable, at waist height, before being placed on the floor. After the event, the employee continued to work, but with restrictions, and received surgery in July. Doctors instructed the employee to take time off after the surgery, resulting in six days lost time.

Cameco instructed its employees to stop the practice of lifting drums over the obstructing buttons (tare scale zero button and tare label print button) mounted to the conveyor belt and a safety cable. Instead, employees should convey the unwanted drum around the conveying system to the designated drum removal location.

In addition, Cameco removed two buttons as their function is now supported by a new interface and remote buttons are not required. Cameco also relocated the conveyor index button so it is not an obstacle to lifting the drum. Furthermore, Cameco shortened the safety cable to provide an opening for drum removal without lifting.

Table H-2: LTIs, SRBT, 2017
LTI Action taken

An employee lacerated their hand during an assembly operation in January 2017. The worker received medical attention and required stitches at the Pembroke Regional Hospital. The doctors recommended that the worker take several days off before returning to work. Following an investigation into the event, it became apparent that the worker had not been adequately guarding the blade when changing it. This injury resulted in two days lost time.

SRBT organized a safety stand-down meeting with supervisors to discuss the event and to ensure that expectations when handling sharp items were emphasized with the employees.

SRBT’s Workplace Health and Safety Committee investigated the event and procured alternative tooling in collaboration with the workers, in order to reduce the hazard when the assembly work is being performed.

In August 2017, while kneeling down, an employee attempted to pick up an item on the floor and injured their back. The worker was subsequently transported to the local hospital and missed the following day of work due to the injury, resulting in one day lost time.

Upon returning to the workplace, the employee was advised on the proper methodology for lifting items, including avoiding twisting of the back when bending over.

In October 2017, an employee in the coating department experienced shoulder pain. The worker received medical attention and was advised by SRBT to take the week off work, resulting in four days lost time.

The worker returned to modified duties and SRBT highlighted expectations regarding job rotation to reduce injury risk as a result of repetitive movements.

Table H-4: LTIs, BTL, 2017
LTI Action taken

An employee cut their thumb on a sawmill when moving a piece of material from the machine; this resulted in 22 days lost time.

The employee was retrained on the procedure and reminded of the safety precautions to take when using the machine. The employee has not been scheduled to work at the saw machine since returning to work and is also being monitored to follow safety procedures with all the other tools and machines on the shop floor.

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Cameco BRR cameco.com/fuel_services/blind_river_refinery
Cameco PHCF cameco.com/fuel_services/port_hope_conversion
Cameco CFM cameco.com/fuel_services/fuel_manufacturing
BWXT Toronto and Peterborough nec.bwxt.com
SRBT srbt.com
Nordion nordion.com
BTL theratronics.ca

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## J. Significant changes to licence and licence conditions handbook

Table J-1: Changes to licences by the Commission
Facility Date Facility licence Description of change
PHCF March 2017 FFOL-3631.00/2027

First release of Cameco PHCF’s LCH after the November 2016 relicensing hearing held in Port Hope. The Commission issued the PHCF’s licence on February 27, 2017.

BTL

July 2017

Amended to:

NSPFOL-14.02/2019

The Commission amended licence condition 1.3 to the following:

“The licensee shall maintain a financial guarantee for decommissioning acceptable to the Commission.” For additional details refer to CMD 17-H103.A, Best Theratronics Limited Financial Guarantee.

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## K. CNSC inspections

CNSC inspections: Uranium processing facilities

Table K-1: Inspections, BRR facility, 2017
Inspection title Safety and control areas covered Inspection report sent date

Type II Inspection Human Performance Management CAMECO-BRR-2017-01

Human performance management May 4, 2017

Type II Operating Performance Inspection CAMECO-BRR-2017-02

Operating performance May 26, 2017
Type II Security Inspection CAMECO-BRR-2017-03 Security August 24, 2017
Type II General Inspection CAMECO-BRR-2017-04

Management system, fitness for service, radiation protection, conventional health and safety

November 16, 2017

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

Table K-2: Inspections, PHCF, 2017
Inspection Title Safety and control areas covered Inspection report sent date
CAMECO-PHCF-2017-01 Physical design, packaging and transport April 26, 2017
CAMECO-PHCF-2017-02 Management system May 23, 2017
CAMECO-PHCF-2017-03

Management system, fitness for service, radiation protection, conventional health and safety, packaging and transport

November 24, 2017
CAMECO-PHCF-2017-04 Emergency management January 29, 2018
CAMECO-PHCF-2017-05 Human performance management February 21, 2018
Table K-3: Inspections, CFM, 2017
Inspection title Safety and control areas covered Inspection report sent date

CFM Type II Inspection CAMECO-CFM-2017-01

Management system March 15, 2017

CFM Type II Inspection CAMECO-CFM-2017-02

Human performance management June 28, 2017

CFM Type II Inspection CAMECO-CFM-2017-03

Security July 10, 2017

CFM Type II Inspection CAMECO-CFM-2017-04

Management system, fitness for service, operating performance, radiation protection, environmental protection, conventional Health and safety, emergency management and fire protection

February 16, 2018

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

Table K-4: Inspections, BWXT Toronto and Peterborough, 2017
Inspection title Safety and control areas covered Inspection report sent date
BWXT-2017-01 Security March 3, 2017
BWXT-2017-02 Management system June 6, 2017
BWXT-2017-03 Human performance management July 25, 2017
BWXT-2017-04 Reactive inspection – beryllium OEL January 10, 2018
BWXT-2017-05 Waste management January 26, 2018

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

CNSC inspections: Nuclear substance processing facilities

Table K-5: Inspections, SRBT, 2017
Inspection title Safety and control areas covered Inspection report sent date
SRBT Type II Inspection SRBT-2017-01 Radiation protection April 13, 2017
SRBT Type II Inspection SRBT-2017-02 Management system May 12, 2017
Table K-6: Inspections, Nordion, 2017
Inspection title Safety and control areas covered Inspection report sent date
NORDION-2017-01 Security February 24, 2017
NORDION-2017-02 Radiation protection April 26, 2017
NORDION-2017-03 Environmental protection June 1, 2017
NORDION-2017-04 Human performance management September 26, 2017
NORDION-2017-05

Emergency management and fire protection

January 25, 2018

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

Table K-7: Inspections, BTL, 2017
Inspection title Safety and control areas covered Inspection report sent date

Security Inspection BT-2017-01

Security August 14, 2017

Management Systems Inspection BT-2017-02

Management systems August 11, 2017

Emergency Management Inspection BT-2017-03

Emergency management December 14, 2017

Transport Inspection BT-2017-04

Packaging and transport January 4 , 2018

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

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