Virtual Canadian Nuclear Safety Commission (CNSC) Inspections—A Licensee Perspective
As the pandemic continues, Canadian Nuclear Safety Commission (CNSC) licensees are becoming familiar with virtual inspections. In this issue of the Bulletin, two licensees share their experiences. A few common themes about the process have emerged:
- Taking extra time to prepare is important.
- Real-time virtual facility tours allow for feedback and questions in much the same way as the in-person versions.
- Ensuring the security of information provided virtually (as opposed to giving it to inspectors while they are on site) presents new challenges.
Overall, the licensees’ insights demonstrate that virtual inspections do have their benefits. It will be interesting to see how the process continues to evolve once the pandemic is over.
About the authors:
- Debbie Frattinger is the safety and compliance officer with the Sylvia Fedoruk Canadian Centre for Nuclear Innovation (Fedoruk Centre) in Saskatoon. Debbie has been a CRPA member since 1994, is certified as a CRPA(R), and served on the CRPA board of directors and as a member of numerous CRPA committees.
- Mike Stoicescu is a health physicist in the compliance and licensing group at Cameco. Mike has been a CRPA member since 2012, is certified as a CRPA(R), and is currently serving as the CRPA director of communications.
By Debbie Frattinger, safety and compliance officer
When the COVID-19 pandemic was declared in Canada, it impacted how we performed our work at the Fedoruk Centre. We were able to postpone some projects; for others we had to develop new methods to obtain the same results. This was similar for CNSC. How would they continue with audits and inspections?
The first CNSC Type I inspection performed using remote means was at the Fedoruk Centre from August 10 to 13, 2020. The purpose of the inspection was to verify compliance with the Nuclear Safety and Control Act, the regulations made pursuant to the act, and the conditions on the licence.
CNSC contacted me four weeks before the date they wanted the inspection to be complete. After our first online meeting to discuss logistics and the outline, it was evident four weeks was not sufficient time for a licensee to collect all the requested documents. An additional two weeks were added and a new date was set in August.
There were two main hurdles to overcome. First was how to securely provide a large volume of records to CNSC in advance. What worked best for us was using in-house programs that both organizations were familiar with and were readily available. I shared a folder in OneDrive with CNSC that housed all the requested documents and videos. It was secure and easy for CNSC to use.
The second hurdle was selecting software for meetings and interviews. Again, we used something we were both familiar with, Microsoft Teams, and I scheduled all the meetings. Videos and live streams were made using my cellphone.
Giving a tour with my cellphone was not as awkward as I thought it would be. If CNSC had a question, they would ask and have me “zoom in” to the area they wanted to see closer up. Certain procedures were recorded ahead of time and stored in the OneDrive folder, then discussed during the inspection.
The time change affected the length of our day. Because we were in different time zones (we are in Saskatchewan and CNSC was two hours ahead in Ontario), we conducted morning sessions as much as possible. This would not have been an issue if they were on site.
Overall, the inspection went very well. The schedule of meeting with the radiation safety officer (RSO) during the first and last parts of the day, asking questions regarding documentation, virtual tours, and interviews were all typical of a Type I inspection from our perspective. Some staff said they felt more relaxed being interviewed over the internet versus in person.
I would say the biggest challenge of a remote inspection was the length of time spent scanning hard copies for CNSC. When it was not possible to scan five years of hard copies, I selected the documents I wanted to share with CNSC, which was not such a negative.
I really appreciated CNSC’s patience with the whole inspection. It was a learning curve for both of us.
By Mike Stoicescu, health physicist
CNSC inspections at uranium mines and mills follow the same process as inspections at any other large industrial facility:
- Document review
- Site inspection
- Closing meeting
Over the past year, CNSC has conducted virtual inspections that follow this same trajectory and have resulted in efficiencies in certain regards. However, virtual inspections have also created more work and take more time.
My two main take-aways from this past year that will help reduce the administrative burden are as follows:
- Preparation: Thoroughly prepare documents and the communication system (i.e., appoint a single point of contact for the inspection if possible) for the inspectors.
- Inspection tour: If possible, take the time to conduct a real-time tour using live video as opposed to providing individual pictures.
Following is some elaboration on both of these points.
Prior to the inspection start date, the inspector should provide their criteria along with a request for documents. The first lesson of the past year was that spending some time preparing documents in advance makes for a smoother inspection. Furthermore, the logistics of document inspection lends itself well to the virtual format—documents and records can be gathered in advance and then labelled using the inspection protocols. Changing a document’s file name to include the specific inspection protocol number allows inspectors to easily check off inspection items without inefficient back and forth.
Preparing these documents is important, but equally important is how they are shared. Documents provided to address inspection protocols are not considered submissions but are provided as transitory documents for the purposes of the inspection. We treat virtual inspections just like an in-person inspection in terms of the rules governing documents with respect to their confidentiality. The logistics of sharing these documents also needs to be set up in advance. A common method of file sharing such as Dropbox, Microsoft Teams, or similar is ideal for this.
The second area where trial and error has helped determine the most efficient process is with the site inspection. A typical method of providing information to the inspector has been to take pictures throughout the facility as directed by the inspector. Experience with this method has shown this approach to be extremely time-consuming and inefficient, largely due to additional trips to the field to address follow-up questions with further pictures.
The more efficient process has proven to be a virtual walking tour with the inspector via video feed and addressing questions in real time. In this way, we were able to resolve any concerns in the moment instead of a back-and-forth information-gathering exercise.
These were a couple of key areas where we were able to improve over the year and find some efficiencies within the virtual inspection process. As a result, our experience has been that the virtual inspection process requires more upfront work and time than in-person inspections, yet it does come with its benefits. Decreased requirements for on-site personnel and focused meetings were realized while providing a thorough, productive inspection process.