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From: Canadian Nuclear Safety Commission
April 13, 2022
I would like to begin by acknowledging that we are meeting here today in the unceded traditional territory of the Algonquin Anishinabeg peoples.
Thank you, Mark, for that introduction, and thank you everyone for welcoming me here today.
2020 was the last time we met together in person, so I’m thrilled to be here this year with all of you. I hope we will all capitalize on the opportunities to connect and exchange in ways that simply are not possible virtually.
The question before us today is: How can the nuclear sector help Canada achieve net zero by 2050?
SMRs are an important part of the answer. They present an opportunity to Canada and the world in the drive for climate change solutions.
As Last week’s federal budget made clear, the federal government is supporting SMRs as part of Canada’s low-carbon energy transition. This includes significant funding in Budget 2022 to ensure that the CNSC has the capacity and capability to regulate SMRs.
The Darlington New Nuclear Project makes Canada the first among G7 nations to embark on deploying a grid-scale SMR, and the CNSC the first regulator to review a licence application for one. Jurisdictions across Canada and the world will be watching to see if the project can be delivered on time, on budget, and – above all else – safely. In the interest of the planet and future generations, we cannot fail.
As the regulator, we do not want to be an impediment to the successful deployment of SMRs. We want to be an enabler, and we are doing everything we can to be ready to licence and oversee the introduction of SMRs in Canada. But success will require a collective effort between industry, the regulator, governments, local communities, Indigenous Nations, and many others. The SMR Action Plan Leadership Table – which held its inaugural meeting yesterday – was an excellent step.
We are a strong and independent regulator – but that does not mean we operate as an island. We are part of the larger nuclear landscape.
Today, I want to speak to you about 3 key areas of focus that I believe are critical for the successful deployment of SMRs in Canada:
At the CNSC, we have a role to play in all of these areas – but success won’t be realized without actions from all of you.
On March 28th, the governments of Ontario, Saskatchewan, New Brunswick and Alberta agreed to a joint strategic plan outlining their path forward on SMRs. One of their 5 key priority areas was “promoting a strong nuclear regulatory framework that focuses on the health and safety of the public and the environment while ensuring reasonable costs and timelines.”
In reading the provinces’ plan, I was pleased to note that what they are calling for aligns perfectly with the CNSC’s approach to regulating SMRs.
At the CNSC, safety will always be our number one priority.
But we know we have an important role to play in ensuring the regulatory process is effective and efficient to enable not only the safe, but also the timely and cost-effective, deployment of innovations in nuclear – such as SMRs.
So what have we been doing to ensure this?
Today, our regulatory framework is the foundation of our effectiveness. It is modern, robust and flexible, and is aligned with international standards and best practices; our international peers have confirmed this.
To ensure our regulatory framework remains appropriate for SMRs, we are looking to provide greater flexibility through our performance-based requirements and graded approach. However, this means that details will not always be in our regulatory documents.
We recognize that it is important to provide as much clarity as possible, and we are exploring alternate options to express technical positions and interpretations of existing requirements.
To be an effective and efficient regulator we also need to have the right people working on the right activities. As part of our SMR readiness efforts, we recently created a new directorate focused exclusively on advanced reactor technologies – DART.
We also recently established an Innovation and Research Division, which allows the CNSC to stay ahead of the technology curve through internal and external discussions on innovation and research in Canada’s nuclear sector.
We are investing now to grow the specific talents and skill sets needed for the demands that lie ahead – I will speak more on this a little later.
VDRs and administrative protocols
Regulatory predictability is important for an efficient regulatory process. For our part, we are undertaking pre-licensing activities to enhance predictability. This includes our vendor design reviews, or VDRs, and administrative protocols.
VDRs give our staff an early familiarity with designs and enable us to get a jump-start on exploring issues requiring long lead times before formal applications are submitted. Our VDR process is in demand, so going forward we will be prioritizing our reviews to those technologies that are proposed for deployment in Canada or that are under serious consideration for deployment here. This will allow our staff to focus efforts where they matter most.
We learned through the refurbishment projects the importance of establishing administrative protocols between CNSC staff and project proponents. These protocols guide interactions on project reviews and establish clear timelines and lines of communication. This again helps to bring greater predictability to the process, and we will be doing the same for SMR projects.
For me, one of the most important areas of work for SMR regulatory readiness is on strengthening international collaboration and harmonization. This work is critical for 2 reasons.
First, collaborating with our international colleagues will improve the effectiveness and efficiency of our regulatory reviews at home. Let me give you an example.
As we all know, OPG has selected GE Hitachi’s BWRX-300 technology for the proposed Darlington New Nuclear Project. This technology has been going through our VDR process and the United States Nuclear Regulatory Commission’s, or U.S. NRC’s, pre-application activities at the same time.
Under our Memorandum of Cooperation with the U.S. NRC, we have been working together to leverage our knowledge and experience in joint evaluations. We just put out our third report on joint evaluations – this one on GE Hitachi’s containment evaluation methodology.
While we have always worked well with the U.S. NRC, we have entered a whole new level of collaboration with the MoC, and we are continuing to set the groundwork for doing things differently, with even greater collaboration, as we move towards the licensing phase.
The second reason international collaboration and harmonization is critical is to ensure the safe and successful widespread deployment of SMRs globally.
At the CNSC, we have been leading by example on this front through our collaborations with like-minded regulators and by calling for greater action on regulatory harmonization – and our efforts are showing returns.
Director General Grossi of the International Atomic Energy Agency recently launched a Nuclear Harmonization and Standardization Initiative.
It is very much in line with the direction I have been proposing and includes 2 separate tracks – one regulatory and one industry – that will leverage the leadership and expertise of governments, regulators, designers, operators and many others to advance standardization and harmonization.
I am very excited by the prospects of this initiative and applaud DG Grossi on his leadership in this.
Expectations of others
As I mentioned at the start of my remarks, success will require efforts from all parties, and this is true for regulatory readiness.
For industry, there are several things you can do to help further enhance the effectiveness and efficiency of the regulatory process.
First, I can’t stress enough how important it is to engage us early and often.
That includes engagement on any and all uncertainties, including fuel qualification, shutdown systems, or even what a fleet licensing approach could look like in Canada. In these areas, proponents need to provide clear justification for their technical approach.
Second is to make sure a design has high reliability. By this we mean that as the design evolves, the safety case must remain robust – significant changes to the safety case after an application has been submitted will result in a cascade of changes that will impact timelines and costs.
Third, get the sequencing right.
We are talking about first-of-a-kind reactors in Canada that are unlike the CANDU designs we are all so accustomed to. There will be time to consider how we transform regulatory decisions from first of a kind to nth of a kind, and for industry to do the same in supporting subsequent safety cases, but the first ones need to be done right.
For provincial governments, if projects are to be delivered on time and on budget, it will mean putting forward realistic time frames for success. If designs are being selected that will require significant federal policy and regulatory considerations, this work must be factored into the timelines.
At the federal level, it is very difficult for regulators to operate if there are gaps or perceived gaps in policy. From radioactive waste management to fuel fabrication, clear policies are a necessity.
I want to turn now to one of the most important areas that everyone in this room can and must play a role in – and that is building trust.
On March 3rd, I had just finished appearing before a parliamentary committee – where I was providing an overview of our regulation of radioactive waste and seeking to dispel myths and false information – when word came that Russian troops were firing on Europe’s largest nuclear power plant in Ukraine and a fire had broken out.
I am sure many of us had a sleepless night that night.
At the CNSC, we took immediate steps to start communicating with our international colleagues, other federal departments, and perhaps most importantly – with Canadians.
I remember when Fukushima happened. I was not with the CNSC at the time. And I remember watching the news and an anti-nuclear activist who was being interviewed calling for KI pills to be issued to all Canadians. The lesson was clear – if we are not proactively providing validated information to Canadians, other voices will fill the void, potentially creating unwarranted fears and concerns. We need to be out there providing timely and dependable information – to be the trusted source of information on nuclear safety–related matters.
This lesson holds true for SMRs and other related and important files like radioactive waste management. Proactive information sharing is one of the steps we need to continue to take to build and sustain trust in the CNSC as a competent and objective regulator.
To build trust, it is also imperative that we build long-term and meaningful relationships with those directly impacted by nuclear projects – in particular with Indigenous Nations and communities. In line with the rest of the Government of Canada, we are shifting from engaging primarily during licensing processes to a more holistic engagement approach that occurs early and throughout the entire lifecycle of projects and facilities.
In 2020, the CNSC developed an Indigenous Reconciliation Strategy. We have been making good progress, including the establishment of an Indigenous Employees Network, the finalization of an Indigenous knowledge policy framework, and initial steps to establish a CNSC‑specific Indigenous Advisory Committee.
To support long-term relationship building, the CNSC has been working hard to formalize many of our existing relationships with Indigenous Nations and communities. We have signed 5 terms of reference that provide structured fora for dialogue on CNSC-regulated facilities within traditional and treaty territories – and we are currently working on 13 more.
At the end of the day though, it is the proponents who are responsible for earning social acceptance for their projects. If nuclear is to be part of the net zero solution – let me be clear – the CNSC’s regulatory processes and engagement efforts are not a surrogate for engagement activities and relationship building by the proponents.
Proponents must engage early with every community that could be impacted and work to build meaningful relationships. You will never convince everyone to support a project – we have all seen with other resource projects and even the COVID pandemic that unanimity on any issue is next to impossible. But proponents need to understand the issues of interest and concern that are related to their proposed projects, consider them sincerely, and make every effort to address those that are within scope.
Radioactive waste management
Nowhere is trust building perhaps more difficult than when it comes to radioactive waste management projects. Radioactive waste has been managed safely in Canada for decades – but for many people, radioactive waste still conjures false images, like the opening of the Simpsons TV show with green radioactive ooze seeping out of barrels.
For SMRs to be part of the net zero solution, we need to collectively build confidence with Canadians and Indigenous Nations and communities that radioactive waste from existing and future projects will continue to be handled, transported and stored safely for all time.
There is a lot of attention and lots happening on radioactive waste this year.
As I mentioned earlier, I, along with a number of others in this room, appeared last month before the House of Commons Committee on Environment and Sustainable Development. The committee is conducting a study on the governance of radioactive waste in Canada, and the report is likely to be tabled in Parliament shortly.
The Commissioner of the Environment and Sustainable Development – part of the Office of the Auditor General – is also currently conducting a performance audit of nuclear waste management.
Natural Resources Canada is finalizing its review of Canada’s Radioactive Waste Management Policy Framework.
And the CNSC is currently in the middle of hearings on Canadian Nuclear Laboratories’ proposed near surface disposal facility for low-level waste at the Chalk River site.
With the NWMO anticipating making a decision on a host community for the high-level waste deep geological repository next year, it has never been more pressing for all of us to get it right on radioactive waste.
Getting it right means more than arriving at solutions that are safe, inclusive, supported by the facts, and aligned with international best practices.
It requires building relationships to understand interests and concerns and trying to address them as best as possible, including by clearly communicating the facts through effective channels.
During COVID, I have seen a lot of similarities between vaccine hesitancy and nuclear concerns. I am not talking about those who are firmly anti-vaccine, or for that matter those who are firmly anti-nuclear – their minds are unlikely to change, ever. But there are many people out there who are hesitant about vaccines for a variety of reasons – including a lack of understanding about vaccines and a lack of understanding about the regulatory approval process.
There are opportunities for us to learn from the various strategies deployed to combat vaccine hesitancy – such as establishing community ambassadors – and from the wealth of research being conducted on effective ways to communicate the facts.
And for radioactive waste, the facts are clear.
It has been strongly regulated and managed safely in Canada for decades, it is tracked and monitored unlike any other waste stream, and its long-term management is fully funded.
International peer reviews have confirmed the appropriateness of Canada’s approach.
Transportation containers are very robust, and there has never been a serious injury or fatality related to radioactive waste management in Canada. Ever.
It is incumbent on all of us to push back against misinformation so that the facts are front and centre.
Opportunities at the CNSC
I have touched on some of the big files that we are focused on this year at the CNSC. And I have to say this is an incredibly exciting time to be in the nuclear sector. I cannot remember a time when so much was happening and there was so much anticipation about what is heading our way.
I noted earlier that we are investing now to grow the specific talents and skill sets needed for the demands that lie ahead.
In fact, we’re looking for all levels of talent for different disciplines, from new graduates, to specialists with expertise ranging from nuclear reactor and fuel cycle regulation to cybersecurity and safeguards.
Helping Canada reach net zero by ensuring the safe deployment and operation of nuclear technologies is critical work. And that is why we put so much emphasis on making sure the CNSC attracts top talent and that our employees enjoy fulfilling, rewarding careers. Let me mention 2 examples of this.
Before COVID-19, our staff worked either in offices or on site. But when COVID struck, we did what so many others did: we built a system for everyone to work from home. We watched with pride as our staff met the challenge and showed just how effective they are working this way. So, we’ve decided to continue that arrangement and give them the flexibility to decide with their manager and teams whether to work at home, in the office, or a combination of the two.
We also strongly believe that equity, diversity and inclusiveness, or EDI, leads to superior results by allowing us to encounter, consider and embrace the greatest range of ideas. Because the CNSC truly puts EDI into practice, no matter who you are or how you self-identify, if your skill set and aspirations match our needs, we welcome your expertise and encourage your participation.
Today we are talking about getting to net zero by 2050. We are setting forth to work through exciting times on novel technologies, and Canada looks set to lead the world on this. Our sector will need the broadest thinking to ensure the best ideas come forward to help. We’re doing our part to ensure that happens.
Let me conclude by reiterating how pleased I am to be back in person with all of you again.
This conference is very timely, for it will take effort from all of us if nuclear is to be part of the solution to meeting our net zero targets – and it is crucial for us to have opportunities like this to connect with one another.
At the CNSC, we are doing our part to be ready to regulate the innovative technologies coming our way, and I welcome your questions, thoughts and feedback throughout the rest of the conference.
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