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CNSC's Uranium Mines and Mills Division: Management Response

The Uranium Mines and Mills Division (UMMD) and the Directorate of Nuclear Cycles and Facilities Regulation (DNCFR) management team have acknowledged these opportunities for improvement, developed an action plan to address them, and indicated a strong commitment to their implementation.

In the audit team’s view, carrying through with the action plan provided in this report will increase the effectiveness and adequacy of the management control framework of UMMD and better position UMMD to meet future challenges.

Action Plan

Acronyms used in the Action Plan:
UMMD: Uranium Mines and Mills Division
DNFCR: Directorate of Nuclear Cycles and Facilities Regulation
I3P: Integrated Improvements Initiatives Programme (internal mangement system action plan)
LMS: Learning Management System

1.  The UMMD, in consultation with its Director General, should establish a performance measurement system that includes an expanded set of measurable performance targets and indicators to gauge the achievement of UMMD’s mandate.  Accountability mechanisms should be included in this system to ensure that it is implemented in a sustainable manner, monitored at an appropriate level and tied to any evaluations of UMMD’s performance.

 

Unit Responsible

Management Response

Timeline

 

UMMD
DNCFR
Operations Branch
I3P

Under the CNSC Management System, the Licensing, Compliance and Integrated Planning and Performance Management (IPPM) Projects under I3P are aimed at establishing a formal performance management framework that DNCFR and UMMD will eventually use. In the interim period, DNCFR will capture the currently undocumented process and criteria used to identify risks for priority setting, planning of work, executing work and performance management.

Management System Sub-processes and procedures for Licensing, Compliance and IPPM: December 2008

Interim documented DNCFR process: March 2008

2. UMMD, DNCFR, Operations Branch and Corporate Services Branch should work together to develop strategies to attract needed qualified staff, as well as to retain its experienced personnel.

 

Unit Responsible

Management Response

Timeline

 

UMMD
DNCFR
Operations Branch
Corporate Services
Quality Council

The Recruitment and Retention Initiative was developed by the Human Resources Directorate in the fall of 2006 and is currently being implemented. 

This endeavor is built on 5 pillars (Internal Assessment; General Recruitment; International Recruitment; University Partnerships; and, Employee Retention) and focuses on a range of challenges and activities (outreach, competitive salaries and benefits, university campaigns, international recruitment, etc.).

Retention efforts focus on clear roles and responsibilities (as outlined in the CNSC Management System Manual), orientation, training of current and future leaders, career progression, mobility, job satisfaction, etc.

Staff and managers work together to develop individual learning plans using the tools available to them (e.g. LMS). It is important to ensure learning/ training opportunities are linked to the required competencies so employees will be able to take an active role in identifying their professional development needs and working towards their career goals. 

Corporate recruitment and retention - Ongoing
Mgt System Manual target date: September 1, 2007

Orientation: formal launch of program in Fall 2007

Training: ongoing (future leaders, leaders – program in development)

3.  UMMD, DNCFR and Operations Branch should work together to ensure that the DNCFR Licensing Process is up-to-date and accurately reflects the environment and related processes at the CNSC.

 

Unit Responsible

Management Response

Timeline

 

UMMD
DNCFR
Operations Branch
I3P
Secretariat
Corporate Services

The DNCFR Licensing Process (a level 3 process) is being superseded by the work of the Licensing Project under the I3P in support of the CNSC Management System – as such, the high level licensing process maps (levels 0, 1, 2 & 3), common across Operations Branch and linked to Secretariat and Corporate Services processes, will replace the DNCFR Licensing Process.

As the licensing process maps are developed to lower levels (procedures and work instructions), there will be some need to customize at the directorate and division level. The CNSC Management System will identify “process owners” who will be responsible for updating their respective processes (and supporting procedures) to ensure that changes in the environment are considered on a continuous improvement basis.

Level 0, 1 & 2 process maps: in draft (to be finalized in June 2007)

Level 3 process map: Fall 2007

Level 4/5 procedures: 2007/2008 (detailed schedule to be determined)
Management System Manual: September 2007

4.  In conjunction with its ongoing quality initiatives, UMMD, DNCFR and Operations Branch should establish a framework for its verification activities that includes a policy, procedures, guidance and tools.  This framework should communicate what role each of the various types of inspections and reviews play in the broader verification program.  Operations Branch should establish guidance or procedures for each type of review and inspection and establish minimum documentation and reporting standards for each.

 

Unit Responsible

Management Response

Timeline

 

UMMD
DNCFR
Operations Branch
I3P

Under the CNSC Management System, the Compliance Project under the I3P is aimed at establishing a framework for its verification activities that includes a policy, procedures, guidance and tools. 

Within the framework, the role each of the various types of inspections and reviews will be identified as well as the expectations for documentation and reporting. Currently, DNCFR has a risk matrix and process for establishing the types and frequencies of DNCFR compliance activities. These will be folded into the CNSC Compliance Project.

Compliance policy: Fall 2007

Level 0, 1 & 2 process maps: in draft (to be finalized in June 2007)

Level 3 process map: Fall 2007
Level 4/5 procedures, guidance & tools: 2007/2008 (detailed schedule to be determined)

5.  UMMD or DNCFR should develop enhanced guidance and tools for Project Officers for managing Regulatory Activity Plans and interacting with their FACT members.

 

Unit Responsible

Management Response

Timeline

 

UMMD
DNCFR
Operations Branch
I3P

Under the CNSC Management System, the Licensing and Compliance Projects under I3P are aimed at establishing a framework for these activities, including enhanced guidance and tools for Project Officers for managing the Regulatory Activity Plans. The FACTeam concept is unique to DNCFR and is guided by a Terms of Reference (available on BORIS) however, it is expected that this concept or a similar concept will be adopted across Operations Branch as the above two projects progress. In the interim, DNCFR management will enhance the guidance and tools for DNCFR staff on the FACTeams until a permanent Operations Branch solution is in place.

DNCFR interim guidance and tools: March 2008

Operations Branch solution Level 0, 1 & 2 process maps: in draft (to be finalized in June 2007)

Level 3 process map: Fall 2007
Level 4/5 procedures 2007/2008 (detailed schedule to be determined)

6.  Until such time as more detailed guidance on report writing is available from Operations Branch, UMMD should communicate minimum standards and expectations to the UMMD inspectors who complete Final Type II Inspection reports.

 

Unit Responsible

Management Response

Timeline

 

UMMD
DNCFR

The UMMD Director and Admin Professionals will provide oversight and quality control checks, and training/communication to achieve consistency among the UMMD inspectors. As well, staff group discussions will be undertaken at least semi-annually on inspection protocol and format, during one of the Division’s bi-weekly meetings.

Ongoing, starting May 2007.

7.  UMMD and DNCFR should continue to focus on developing a process and mechanism to centrally track enforcement actions and recommendations.  UMMD Project Officers should ensure that processes are in place to ensue that action notices and recommendations issued by Provincial Inspectors while conducting CNSC Inspections are disposed of in a timely manner.

 

Unit Responsible

Management Response

Timeline

 

UMMD
DNCFR
DNSR
Operations Branch
I3P

Under the I3P in support of the CNSC Management System, there will be a central tool (i.e., Integrated Systems Project) available to track enforcement actions and recommendations. To fill in the gap period, DNCFR has initiated a project with DNSR to investigate the utility of LOUIS to provide this functionality. For oversight of action notices and recommendations by Provincial Inspectors, this would be done under the auspices of the CNSC/Saskatchewan Administrative Agreement.

I3P – 2010
Investigation of use of LOUIS: Dec. 2007

Implementation of interim LOUIS solution: Dec. 2008

Provincial oversight mechanisms: March 2009

8.  DNCFR, in conjunction with the Corporate Security Section, should document and updated processes and record keeping requirements for issuing and managing Inspector Certificates.

 

Unit Responsible

Management Response

Timeline

 

DNCFR
Operations Branch
I3P
Corporate Security
Secretariat

Inspector Certificates are issued under the authority of the Secretary of the Commission. The process for qualifying inspectors is being established in the Compliance Project (training needs) under the auspices of I3P in support of the CNSC Management System. For record keeping and managing Inspector Certificates, Corporate Security Section provides this service as it is equipped to do so. Operations Branch will work with the Corporate Security Section to establish a more robust tracking mechanism that will service the process being developed in the Compliance Project.

Qualification process: December 2008

Updated tracking mechanism: March 2008