Atomic Energy of Canada Limited National Research Universal Reactor Safety System Upgrades and the Canadian Nuclear Safety Commission's Licensing and Oversight Process

V. Licence Condition - NRU Upgrades to be “Fully Operational” by December 31, 2005

V.A. Clarity of Licence Condition 13.1

In November 2005, the CNSC Commission renewed the CRL OL for several months with an expiration of July 31, 2006 [31]. The new OL included condition 13.1, “Licensee shall demonstrate that all 7 NRU upgrades are fully operational by December 31, 2005.” The licence condition offered no further explanation of the seven NRU upgrades.

The AECL Licence Application for Removal of Clause 13.1 Pertaining to NRU Reactor Operation [32] stated that EPS is “to be installed and commissioned but not yet fully operational and ready for connection to the other NRU safety upgrades […] These safety upgrades were placed in service as noted above. The Emergency Power Supply system has been commissioned and an application has been made to the Safety Review Committee and CNSC to place it in service, at which time it will be fully operational and ready for connection of Emergency Power Supply power to the other NRU safety upgrade […] All the safety upgrades are seismically and environmentally qualified. They are all designed to modern codes and standards”. The licence application stated that “additional information on these safety upgrades is provided in” an AECL Interim Report on the Plant Life Management Program for the NRU Reactor” [33]. The Interim Report stated "The last two upgrades (NECC and EPS) are now installed, commissioned, and ready for connection of EPS to the other NRU Safety Upgrades […] The only remaining Upgrades work of significance is the replacement of the DC Motor Starters for Main Heavy Water Pumps #4 and #5 with seismically qualified units. One of these starter units is currently installed (2005 April) and is undergoing in-service testing on Main Heavy Water Pump #1."

During the hearing process [34] for approving the new OL, a CNSC Commission Member questioned whether the safety upgrades were clearly understood, and whether the expectations regarding the OL condition were specific enough that, in the future, the CNSC Commission would be able to conclude that they were met. AECL and CNSC staff indicated to the CNSC Commission Members that they both understood and agreed on the short term actions. AECL stated: "No, Madam Chair, in fact we believe the two lists are pretty well aligned." CNSC stated: “From a historical perspective, that terminology, "seven upgrades" has been recognized through streams of numerous licensing correspondence and Commission documentation. So from my perspective it's explicitly clear."

As indicated by the timeline in Appendix D of this report, there were many documents that discussed the NRU upgrades, in general, and the EPS tie-in to the MHWPs, in particular. In addition to letters of correspondence (2/96 & 12/04), there were transmittals of Annual Safety Reviews (3/98 & 3/05), EPS First Safety Notes (4/97, 11/98), EPS Final Safety Notes (9/02 3/05, & 7/05), Design Requirements (3/05) and Design Descriptions (8/00 & 4/05). AECL documents beginning with the AECL Project Upgrades Plan in April, 1993 [35] through Revision 2 of the EPS Final Safety Note in July, 2005 [36], consistently stated that hazards-qualified back-up power was to be supplied to the MHWPs from the EPS Upgrade.

V.B. Installation of NRU Safety Upgrades Delayed Many Times

The NRU upgrades, including the EPS tie-in to the MHWPs were originally planned for completion in 1997. In April, 1997, AECL's First Safety Note [37] stated that EPS will provide hazards-qualified power for the MHWPs essential for core cooling in 1998. In May, 1998, AECL apprised CNSC in a meeting [38] that the EPS upgrade was scheduled for installation in September 2000. In October 1998, the NRU OL included Licence Condition 27a that the NRU upgrades described in the 1997 NRU Annual Safety Review [18] were to be completed by October 31, 2000. In July 2000, the CNSC Commission was apprised in a CMD [39] that EPS would not be implemented by October 31, 2000, and NRU would not be in conformance with Licence Condition 27a of the then current OL.

In August 2004, AECL stated in a letter to CNSC [40] that the NRU upgrades would be completed by the end of the fiscal year. In April 2005, CNSC, in a letter to AECL [41], acknowledged AECL's agreement that EPS and NECC were to have been completed by March 2005 and that the deadline had not been achieved. AECL apprised CNSC that the EPS and NECC upgrades would be in service in April/May 2005 and September 2005 respectively. In June 2005, AECL, in a letter to CNSC [42], expressed its understanding that, when the EPS was tied into the Emergency Response Center cabinets, and the tie-ins to the other formally requested upgrades had been made, the commitment to complete the EPS was met. The EPS tie-in to the MHWPs had not been requested and, at that time, was considered by NRU management to no longer be part of the required upgrade.

V.C. Reasons why AECL did not make EPS connections to MHWPs per Licence Condition 13.1

While AECL actions to comply with Licence Condition 13.1 of the November 2005 OL and make the seven upgrades fully operational by December 31, 2005 were substantial, they were not completely effective, for the following reasons:

1. The NRU reactor OL conditions issued in 2005 and 2006 were not clear, and did not specify in detail exactly which NRU safety upgrades were to be installed. Installation of safety upgrades was part of the information relied on by the CNSC Commission in making its decision to renew the CRL OL in 2006, and was a licensee commitment even though it was not a specific licence condition.
2. The connection of the MHWPs to the EPS required the installation of seismically-qualified DC Motor Starters, but these had not yet been installed because NRU reactor management did not believe there was a licensing requirement to install them.
3. The NRU commitment tracking system was not effective in tracking and monitoring the EPS connections to the MHWPs. Despite the fact that these connections were part of the EPS safety upgrades that were planned by AECL, by 2007, this safety upgrade was not being tracked in the NRU commitment tracking system.
4. Similar to the CNSC regulatory oversight program, AECL NRU upgrades were managed more from an “expert based” approach than a “process oriented” one. AECL, in its internal root cause analysis, found that the NRU staff had made a decision to track the EPS connections to DC motors for MHWPs P-104 and P-105 as a separate work package, outside the scope of the EPS upgrade. The Talisman Team found that the mindset to consider the EPS connections to the MHWPs as being outside the planned upgrades was shared by key project and plant personnel, even though the decision was not formally incorporated into the project plan, the facility modification, the design change package, or communicated to either the AECL Safety Review Committee (SRC) (who had been providing high-level oversight of the upgrades) or to the CNSC. In fact, the Talisman Team found no written document which provided the basis or rationale for this position. In 2005, when NRU management separated the planned connection of the EPS to the MHWP from the EPS safety upgrade activities, some CNSC staff members became aware of the change, but CNSC management was not informed by CNSC staff or AECL and did not have the opportunity to challenge this decision. CNSC management continued to believe, based on earlier documentation, that the planned safety upgrades included the hazards-qualified EPS provided to MHWPs.
5. The original approach for connecting EPS to the MHWPs involved qualifying the existing, installed DC motor starters. The project was not able to qualify the existing motor starters, and the search for a supplier and qualification of new motor starters took considerable time and effort.
6. When the new motor starters were installed in the plant and connected to the non-essential MHWP for testing, a problem was discovered with starting current. The motor starter manufacturer did not develop a technical solution, so the burden fell on the NRU electrical design engineers, who already had a very heavy workload. While the NRU engineers did come up with a remedy, this took considerable time and delayed the months-long proof test of the motor starters on non-essential pumps. The NRU operations staff wanted these tests performed, in order to demonstrate reliable operation prior to making the connections to MHWPs P-104 and P-105.
7. The NRU operations and facility managers did not share the safety significance of the tie-in of EPS to the MHWP. The safety benefit of implementing the modification to connect the MHWPs to the EPS was not agreed upon, or well understood, by NRU site management. The operators had a lot of confidence in the existing configuration, which included powering the MHWP from the off-site power grid, normal Class IV power, normal Class III diesels, and Class I batteries. They perceived the upgrade as potentially introducing new failure modes while addressing a very improbable external event (design basis earthquake). The operators and plant managers were reluctant to change the power supply configuration and did not drive completion of the EPS tie-in.
8. The AECL SRC was a supporter of the upgrades and considered the tie-in of the EPS to the MHWP to be of high safety significance. However, the SRC was not successful in convincing the NRU staff of its benefits, or influencing its expedited installation.
9. As reported during the interviews, there was a recurring problem implementing long-term projects. Frequently, the projects were said to be adequately funded and provided with sufficient dedicated project resources, but the NRU staff necessary to execute or support key project activities was unable to do so because of its normal day-to-day plant duties, emergent issues, maintenance outage work and other responsibilities.

When AECL informed the AECB of its intent to provide Class 1 power to the MHWP, in December 1992, completion was expected in 1995 or 1996, but an integrated resource loaded plan and schedule had not been prepared to ensure that the targeted completion date could be met. A project was authorized and initiated, and the connection of EPS to the MHWP through hazards-qualified equipment was included in the NRU Upgrades Project Plan. However, the scope was not identified as being a CNSC commitment. The subsequent implementation documents (plant modification package, drawings and procedures etc.) also had no reference to a CNSC commitment. The upgrades were incorporated into the OL as part of Licence Condition 13.1 in November 2005, but at that time the NRU Managers did not view the installation of seismically-qualified DC Motor Starters as part of the “original” NRU Upgrades; yet the DC motor starters were required to tie-in the EPS to the MHWPs.

The action tracking system in use at the CRL is known as the Action Item Management System (AIMS). This system has been used CRL-wide for tracking a myriad of issues, including regulatory issues. Although CRL staff has a handbook available from the software vendor, which provides instructions on how to make entries, AECL staff does not have procedural controls for its use. AIMS entry number 1998-NRUU-UPGR-5 was entered in January 1998, and indicated “fully operational” on October 13, 2005. The installation of the new DC motor starters was entered into AIMS in September 2004, as a non-regulatory item in the Environmental Program plan (EnvA-66), with a target date of March 2005. This effectively removed the tracking of this item from close oversight.

The EPS upgrade was commissioned in late 2005, and a letter was written to the CNSC on December 23, 2005 [22], stating that the upgrades were “fully operational.” The basis for that determination or position was that EPS was connected to all the other upgrades, and it was the apparent collective mindset of several NRU managers and key project personnel that the DC motor starters and connection of EPS to the MHWPs were an “enhancement”, not part of the upgrades. While there were internal AECL emails that clearly reflected this belief, the AECL project description documents reviewed by the Talisman Team, governing the planned scope of the upgrade project and the design changes for EPS, did not reflect that change. The Talisman Team has identified no project description or project control documents that supported that position.

Observation (3) - Operating Licence (OL)

The Talisman Team concluded that the November 2005 OL was not clear, in that it did not define the seven NRU upgrades required to be operational by December 31, 2005.

Recommendation

Recommendations C-OL-1 through C-OL-5, as discussed above, address this observation.

Observation (4) - Project Management (PM)

The NRU upgrades project management process did not have sufficient controls, and the existing controls it had were not always effectively implemented. The NRU Upgrades Project Plan included connecting EPS to the MHWPs in its scope description; however, the scope was not identified as a licence commitment. Senior AECL managers took the position that the replacement of the DC motor starters, an essential part of the new hazard-qualified EPS connection to the MHWP DC motors, was outside the scope of the NRU safety upgrades and represented an enhancement. This decision was not consistent with the Project Plan, and AECL submittals to the CNSC, including the EPS First Safety Note, the EPS Final Safety Note, the Design Requirement, and the Design Description. A project procedure required a licensing review of scope changes. The decision to exclude the DC motor starters from the rest of the safety upgrades was not considered to be a scope change, and was not reviewed by licensing. The Talisman Team reviewed the guidance provided to the project managers at the time the NRU Upgrades Project was initiated (mid-1990s), as well as the current guidance. The Talisman Team concluded that the earlier guidance, which is based largely on Project Management Institute guidance, is superior. For example, in 1994, an engineering projects procedure appropriately assigned responsibility for compliance with AECB requirements to the project manager.

Recommendations

AECL should consider the following improvements to the project management process:

A-PM-1: AECL should ensure its project management guidance is based on the Project Management Institute guidance for project management.

AECL Management Response
Since the formation of a consolidated project delivery organization in April 2005, AECL has implemented a project quality program and associated project management procedures that are based on Project Management Institute guidelines (Project Management Book of Knowledge). These project management processes continue to be strengthened based on self-assessments and the auditing process. AECL will review existing procedures and incorporate previous procedures as necessary (see overall recommendation 14).

A-PM-2: AECL should ensure that the responsibility for compliance with commitments is assigned to Project Managers.

AECL Management Response
Accountability statements and position descriptions for project managers will be reviewed and revised if necessary to ensure responsibilities include meeting regulatory commitments (see overall recommendation 14).

A-PM-3: AECL should require Project Managers, by procedure, to include licence commitment references in their project plans, schedules and implementing documents.

AECL Management Response
AECL will ensure that its project management procedures include requirements for Project Managers to include regulatory commitments in project plans, schedules and documents. Existing procedures will be reviewed and revised as necessary to ensure regulatory commitments are incorporated into project planning documents (see overall recommendation 14).

Observation (5) - Modification Management (MM)

AECL commissioned a facility modification to the EPS, which was not completely installed and tested as required. The back-up EPS power supply to the MHWPs was included in the scope of a plant modification that was commissioned in October 2005, but it was not installed. Completion Assurance Certificates were signed without exception, even though the back-up power to the MHWPs, which was part of the modification, was not installed. The completion assurance process required reviews and sign-offs by all the appropriate functional groups, but completion was signed-off either without verifying all the work was done, or without documenting what work had not been completed in the open items/exceptions list.

The modification was commissioned, and the plant was started up in a configuration other than the one specifically analyzed by the modification package. The current process allows a plant modification to be commissioned with open items, but there is no control over the significance of the open items. In this case, the tie-in of EPS to the MHWPs was not made. The drawings and procedures at that time showed the system as if the entire modification was complete. In addition, the Talisman Team could find no evidence that the operators were trained on the interim configuration, or that there was a safety case that reflected the interim configuration.

The Project Procedure on Commissioning Completion Assurance (RC-2000-109, CWP-27) provides only for completion assurance of the entire modification, and does not allow for commissioning only part of a modification, as was done for the EPS Upgrade. The Procedure does not adequately address activities not completed at the time of commissioning. For those, it requires the activities to be listed as deficiencies, but it does not provide direction regarding the completion of these activities. The Conduct of Operations Procedure [23] requires closure of the modification after ensuring that all deliverables (document revisions) have been completed.

The current modification process also allows construction to make changes without engineering approval, and submit them to engineering to be incorporated into as-built drawings. Until recently, engineering was considered to be a service organization, and was not accountable for configuration management. Recently, engineering was given more of a leadership role in the process.

Recommendations

AECL should consider the following changes to its plant modification procedure and commissioning procedures:

A-MM-1: AECL should ensure the Engineering Change Control procedure requires that, when only part of a modification is commissioned and placed in service, the actual configuration has been reflected in drawings and procedures, that operators have been trained, and the specific configuration being placed in service has been analyzed in a safety evaluation (safety case); it should also require a new stand-alone modification be issued, covering installation and commissioning of the remainder of the modification.

AECL Management Response
AECL's process for commissioning a system and declaring it in-service requires that drawings, procedures, training programs, and safety cases are up-to-date before the declaration is made. AECL's recently-issued engineering change control (ECC) procedure, 145-508120-PRO-001, provides a structured and controlled process for implementing modifications in a staged fashion. Any deviations to the original engineering change package such as partial implementation would invoke the field change process and a subsequent re-evaluation (including a safety evaluation) and re-assessment of the modifications to the original change package. Any significant deviations (such as changes to design intent, requirements, performance, safety case, hazards assessment or pressure boundary) would result in a rejection of the field change and would require a revision to the original change package. A second change package would then have to be issued to complete any outstanding work. The current ECC procedure will be reviewed and revised accordingly to address partial implementation of modifications at the next revision stage (see overall recommendation 14).

A-MM-2: AECL should ensure the Engineering Change Control procedure requires that the as-installed configuration be consistent with the engineering change package.

AECL Management Response
AECL's recently-issued engineering change control procedure, 145-508120-PRO-001, requires that the as-installed configuration be consistent with the engineering change package. Currently the process requires a “fully-operational” declaration (meets the change request requirements) and a “close-out” declaration (all documents are updated and there are no outstanding issues) (see overall recommendation 14).

A-MM-3: AECL should ensure the Engineering Change Control procedure requires that any non-trivial change must have prior Engineering approval.

AECL Management Response
AECL's recently-issued engineering change control procedure, 145-508120-PRO-001, requires Engineering approval for all non-trivial changes. In addition, the field change control procedure (145-508120-PRO-002), currently under revision, describes the requirements to capture changes to approved change packages during implementation (see overall recommendation 14).

A-MM-4: AECL should ensure the Engineering Change Control procedure requires that an independent verification of the physical installation be performed prior to completion acceptance.

AECL Management Response
AECL's recently-issued engineering change control procedure, 145-508120-PRO-001, requires verification of the physical installation prior to completion. Post-installation field walk-downs are included as part of construction completion assurance. In addition AECL will review its current detailed work plan (”route” sheet) process to ensure adequate inspection, verification, “hold” and “witness” points are properly identified during implementation (see overall recommendation 14).

A-MM-5: AECL should ensure the Engineering Change Control procedure requires that for plant modifications done to meet CNSC commitments, a reference to the commitment be included in the applicable documents (drawings, specifications, procedures, etc.).

AECL Management Response
See response to A-CM-5. In addition, all change requests include the type of regulatory commitment (REG-C, M or I) and the CNSC commitment date.

A-MM-6: AECL should ensure the Engineering Change Control procedure requires specific LCOs, with their detailed bases, to be in effect when modifications are approved and required to be functional by the CNSC.

AECL Management Response
AECL will ensure that LCOs are available in the form of a revised FA when seeking approval to operate a new or revised system (see J-OL-2).

Observation (6) - Work Management (WM)

AECL did not implement a facility modification which was part of the planned safety upgrades and viewed as a significant improvement to safety in a timely manner, since the installation was still not completed in November 2007.

Recommendations

AECL should strengthen its Work Management Process as follows:

A-WM-1: AECL should strengthen the long-term planning process (including programs and processes for budgeting and resource allocation, work prioritization, and work planning and control) such that it is aligned with the nuclear industry's best practices. Long-term plans should include resource-loaded schedules for major projects, which reflect the amount of support required and availability of the plant staff. Ensure that all functional departments understand the scope, priority and schedule for regulatory projects. The commitment date and project schedule should be based on plant staff resource requirements and availability, plant operating and shutdown schedules, and safety significance.

AECL Management Response
AECL is implementing improvement work management practises that are based on industry best practises. A 13-week rolling schedule has been implemented, and work is underway on a 52-week rolling schedule. Included in the work management process is the identification of regulatory commitments to ensure they are accorded appropriate oversight and priority (see overall recommendations 10 and 14).

A-WM-2: AECL should include long-term project work in the recently implemented cyclic work planning process, so that is given appropriate priority and can be completed on schedule. Long-term project work can be planned and staged in advance with routine plant work, such that it can be smoothly executed during a “work week”.

AECL Management Response
The next stage of AECL's work management improvements that is underway is the rollout a 52-week schedule that includes project work.

Observation (7) - Modification Management (MM) and Work Management (WM)

The Talisman Team identified several AECL NRU processes that appeared to have been “overridden” (or not followed) because of the mindset of the NRU management and upgrade experts. Had any one of these processes been sufficiently robust and implemented properly, it should have challenged or prevented the mindset that the installation of the seismically-qualified motor starters and connecting them to EPS was not part of the planned safety upgrade project. The Talisman Team reviewed the applicable AECL processes and their implementation, and identified areas that needed to be further assessed in order to identify specific enhancements. At Talisman's request, AECL formed a team to support the Talisman Team. The AECL Team reviewed Configuration Controls, including Modification Management, Work Control, and Quality Control processes and procedures.

Recommendations

A-MM-7: AECL should continue its self-assessment of the NRU Configuration Control Processes, including Modification Management processes and procedures.

AECL Management Response
AECL will complete the assessment of NRU processes as part of an upcoming PINO (Performance Improvement and Nuclear Oversight) performance-based audit (see A-RC-1).

A-WM-3: AECL should continue its self-assessment of the NRU Configuration Control Processes, including Work Control and Quality Control processes and procedures.

AECL Management Response
AECL will complete the assessment of NRU processes as part of an upcoming PINO performance-based audit (see A-RC-1).

Observation (8) - Commitment Management (CM)

AECL's commitment management process was not effective in ensuring that the commitment made to CNSC to install hazards-qualified back-up EPS Class 1 power to the DC motors of MHWPs was completed by December 31, 2005. If a formal licensing tracking system and the inspection tracking system had been in place, it should have clearly included entries that indicated that the EPS hazard qualified connections had not been completed. This would also have helped to highlight outstanding issues during routine inspections as well as during licensing briefings to the Commission.

Recommendations

J-CM-1: AECL and CNSC should identify all of the open regulatory commitments, and reach an agreement that these open items will adequately cover the licensing requirements.

CNSC Management Response
CNSC will work with AECL to review all open regulatory commitments, including any remaining commitments specified in the Licensing Strategy document, to ensure they are clear, that they adequately address the licensing requirements and that both CNSC and AECL are clear on the necessary actions and timelines to meet the commitment. These will be reviewed by legal counsel for clarity and enforceability. This will be completed by October 31, 2008.

AECL Management Response
AECL has started a process to identify open regulatory commitments (see overall recommendations 2 and 13), and will work with CNSC staff to achieve agreement on the set of commitments that adequately cover licensing requirements.

J-CM-2: AECL and CNSC should develop and implement a formal tracking system to clearly identify those licensee commitments and statements, as well as track any open inspection or audit findings. As new items are identified by AECL or CNSC, those new items should be entered into the AECL and CNSC commitment action tracking system.

CNSC Management Response
CNSC will work with AECL to review and update the AECL's existing commitment tracking system to identify licensing and compliance commitments that are considered of greater risk significance and higher priority. AECL will carry out an effectiveness review of this system by September 30, 2008. In addition, the CNSC will introduce its own simplified tracking system for licensing and compliance commitments that are considered of greater risk significance and higher priority. This tracking system will be developed and implemented by September 30, 2008.

AECL Management Response
AECL will work with CNSC staff to agree on a tracking system for licensing and regulatory obligations, for inspection and audit findings, and for licensee commitments (see overall recommendation 2).

AECL needs to strengthen its commitment management process as follows:

A-CM-1: AECL should require by procedure that commitments only be made by authorized individuals, in writing, with a clear description of scope and schedule. Prior to making the commitment, a resource loaded plan and schedule must be developed, to ensure that the commitment can be met.

AECL Management Response
AECL's regulatory commitment procedure, CW-508760-PRO-246, requires that commitments can only be made by authorized staff, and that schedules and resources are agreed to by line management before the commitment is made. AECL is undertaking an effectiveness review for the commitment procedure to ensure there are no impediments to proper implementation (see overall recommendation 2).

A-CM-2: AECL should prioritize existing and future regulatory commitments and initiatives by safety significance, cost, schedule, and plant availability.

AECL Management Response
AECL will include in its commitment tracking system a prioritization scheme based on safety, cost and business impact (see overall recommendations 2 and 11). In addition, initiatives will be prioritized on the basis of risk benefit as determined with risk assessment tools (see overall recommendation 6).

A-CM-3: AECL should track all commitments in a central database, managed by the licensing group, and reference the licensing commitment number in the implementation plans and execution documents, in order to ensure that no scope or schedule changes are made without a licensing assessment.

AECL Management Response
AECL has a database for commitments, and is in the process of making improvements (see overall recommendation 2). Also, commitments are referenced in project management documentation to ensure changes are only made after a proper assessment (see overall recommendation 14).

A-CM-4: AECL should include in the Commitment Management Procedure a step that once a committed action has been completed and verified, the commitment may be closed and CNSC informed in writing.

AECL Management Response
AECL will ensure that closure of commitments is addressed in its commitment management procedure (see overall recommendation 2).

A-CM-5: AECL should reflect reference to the commitment in implementation documents such as drawings and procedures, to ensure that the commitment is not inadvertently “undone” at a later date.

AECL Management Response
AECL will include references to commitments and obligations in licensing bases documents to ensure they are not superseded (see overall recommendation 13, and A-OL-1 and A-CM-3).

Observation (9) - CNSC Commitment Management (CM)

CNSC does not have an effective formal system for tracking inspection and licensing issues.

The lack of a formal commitment tracking system for both licensing and inspection issues hinders management oversight to ensure proper resolution and closure. Throughout the last 15 years, during which the NRU upgrades were being proposed, implemented, and added to the OL, CNSC experienced considerable staff turnover and established a resident inspector office. The CNSC staff does not have a formal tracking system, to ensure follow-up to commitments and inspection findings when staff changes are made. Outstanding inspection issues, as well as outstanding licensing issues, were not clear to the new CNSC staff during and after turnover of responsibilities.

Recommendations

C-CM-1: CNSC should develop a formal CNSC tracking system, and use it to monitor outstanding licensing and inspection issues. CNSC should share this with the licensee, to help ensure that both CNSC management and the AECL management have a current understanding of the outstanding regulatory issues. The tracking system should include licensing issues, inspection findings, licensee commitments and action items. This should be used to provide continuity as regulator and licensee staff change over time. It should also be used to assist any new project managers - or inspectors - in knowing the current licence commitments and inspection follow-up status.

CNSC Management Response
CNSC will work with AECL to review and update the AECL's existing commitment tracking system to identify licensing and compliance commitments that are considered of greater risk significance and higher priority. AECL will carry out an effectiveness review of this system by September 30, 2008. In addition, the CNSC will introduce its own simplified tracking system for licensing and compliance commitments that are considered of greater risk significance and higher priority. This tracking system will be developed and implemented by September 30, 2008 (same as J-CM-2).