# Detailed impact of regulatory amendments

## Table A.1: Provision of information related to emergencies

This provision impacts all active licensees.

Activity Assumptions
Provide additional information to training documentation for radiation protection and new worker orientation (one-time cost) – CNSC estimates
• All 1,570 active licensees are required to provide the information to their NEWs and have emergency procedures and training in place
• Some licensees may need to provide additional risk information to workers in writing
• 10% of licensees (157) may have an average of 5 hours’ work to do

CNSC estimates

• 10% of licensees (157) may have to deliver some training
• 10% of NEWs who received a dose may need training (3,380)

• Deliver 6 minutes of training to 5,000 workers upfront, and 200 new workers each year at $60 per hour •$2000 for development of training materials
• 15 minutes training annually to 300 operations staff and provide 3 minutes training annually to 1,000 new workers

## Table A.2: Provisions related to breastfeeding NEWs

This provision will have the most impact on 450 licensees who are licensed to use unsealed nuclear substances. This group consists mainly of nuclear power plants, uranium processing facilities, and medical and research facilities.

Activity Assumptions
Provide additional information to training documentation for radiation protection and new worker orientation (one-time cost) – CNSC’s estimate
• 95% of licensees will have to update their training documentation, five hours’ work
Deliver and receive training – CNSC’s estimate
• 10% of licensees (157) may have to deliver some training
• 10% of NEWs who received a dose may need training (3,380)
Review radiation hazard assessments (one-time cost) – CNSC’s estimate
• 1,527 out of 93,764 monitored female NEWs received a dose greater than 1 mSv, the public dose limit (2016, NDR)
• 10% of female NEWs who received an equivalent dose of more than 1 mSv in 2016 could require the licensee to make accommodations; therefore, it is expected that approximately 153 licensees will have to review hazard assessments which take one hour each
Modify work assignments (accommodation) – CNSC’s estimate
• The calculation for making accommodations for a female NEW is based on two hours of work
• 153 licensees may need to make accommodations for a breastfeeding NEW. The CNSC believes very few breastfeeding NEWs work in environments that will require accommodation. Some of the work may already be in place, because the licensee would have had to make accommodations when the NEW was pregnant

Revise documents
Two submissions – nuclear power plant licensees’ estimates

• 10 hours of work to develop training materials at $100 per hour • 50 hours of work to develop training materials and technical basis documents, based on a mixed technical group doing the work at$100 per hour

Two submissions – nuclear power plant licensees’ estimates

• Deliver 3 minutes of training to 1,000 new workers each year at $100 per hour • Specific incremental training, goes to all, as role and gender of worker not considered • Deliver 6 minutes of training to 7,000 workers upfront at$60 per hour, and 2,000 new workers each year at $60 per hour Other – respond to individual concerns Nuclear power plant licensees’ estimates • 20 workers each year, 20 minutes per consultation, at$60 per hour
• Radiation health physicist speaking with workers for 20 minutes at $75 per hour Review hazard assessments (one-time cost) – Nuclear power plant licensees’ estimates • Assume it is covered by existing practices for protecting pregnant and breastfeeding workers Modify work assignments (accommodation) – Nuclear power plant licensees’ estimates • No cost, accommodation is already provided • Assume it is covered by existing practices for protecting pregnant and breastfeeding women ## Table A.3: Reduction in the equivalent dose limit for the lens of an eye for a NEW in a one-year dosimetry period This provision will have most impact on 450 licensees who are licensed to use unsealed nuclear substances. This group consists mainly of nuclear power plants, uranium processing facilities, and medical and research facilities. Activity Assumptions Review hazard assessments (one-time cost) – CNSC estimate • All licensees (1570) will have to review the radiation hazards associated with their licensed activities and determine whether the lower dose limit for lens of an eye will impact their radiation protection program. • Licensees have already identified the radiation fields that will be encountered by NEWs as part of their jobs. For example, large facilities such as nuclear power plants and processing facilities regularly assess radiation hazards as part of their radiation protection program. Nuclear medicine departments identify radiation hazards by area in each medicine room. This information is fundamental to planning work involving radiation and the foundation of a licensee’s radiation protection program. • The review of the radiation hazard assessments is estimated to take two hours Provide additional information in training documentation for radiation protection and new worker orientation (one-time cost) – CNSC estimate • Licensees who may need to modify their existing practices based on their licenced activities (650) • 650 licensees may have to update their materials, taking five hours’ work to complete Deliver and receive training – CNSC estimate • 650 licensees may have to deliver some training • 10% of NEWs who received a dose may need training (3,380) Provide safety goggles – capital costs CNSC estimate • 650 licensees may need to purchase 10 additional pairs each year at a cost of$10 per pair.
Cover shipping costs for special eye dosimeters – CNSC estimate
• Based on 170 NEWs received effective doses greater than 10 mSv in 2016.
• Modify dosimetry by adding a lens-of-the-eye dosimeter.
• Assuming 170 licensees may have at least 1 NEW who will require an eye dosimeter. 170 licensees x $230 in shipping costs. Provide dose information from dosimeter reading, 170 licensees each with 1 NEW – CNSC estimate • Modify dosimetry by adding a lens-of-the-eye dosimeter, processing costs. Assuming 170 licensees may have at least 1 NEW who will require an eye dosimeter. (Cost also is based on quarterly reading, less than 10 dosimeters per licensee). Review hazard assessments Two submissions – nuclear power plant licensees’ estimates • Health physicist will take 910 hours and a radiation protection technician 7 hours to review • Three weeks to write report (100 hours) •$8400 for a vendor contract survey.

Three submissions – nuclear power plant licensees’ estimates

• No additional cost for training, since change is minor and doesn’t add additional time to training
• All workers will need incremental training:
• Approximately 7,000 energy workers to receive training @ 12 minutes @ $60 per hour average over the work force and 500 technical staff to receive training @ 12 minutes @$70 per hour
• Approximately 2,000 new workers to receive training @ 12 minutes @ $75 per hour average over the work force and assuming new workers need the training • 2300 workers given .4 hours training @$62.50 per hour

Provide safety goggles – capital costs
Three submissions – nuclear power plant licensees’ estimates

• Estimated cost is $0 if we are able to use the glasses we have. Since a certain thickness is required to block beta radiation, custom-made glasses may be needed. Assuming only 10% of the total number of monitored workers (2,300/10 because of reusability). Unit cost varies depending on brand and website, ranging from$7–$30. Conservatively choose$10

Other capital costs
Three submissions – nuclear power plant licensees’ estimates

• New dosimeters: $465,000. It is not yet known whether more accurate dosimeters will be required. Greater accuracy may be required if MCR workers receive doses that are close to the lens-of-an-eye dose limit. If required, dosimetry enhancements include: change to head TLD badge case (design ~$10,000; cost per case $20 each plus$65 each for Extrad chip = $85 each x 2,100 badges =$180,000), modification of equipment for readout ($75,000) and type test report ($200,000)
• In-house beta-spectrometer development for proper characterization of hazards. Currently only beta fields are well-defined.
• Survey instruments for the field, upfront costs
• Based on dose data from the last 5 years, between 43 and 137 NEWs will require eye dosimeters. Two possible implementation approaches: 1) Mandatory eye dosimeters required for open system work; and/or when WB effective >=1.5 rem, and 2) Eye dosimeters are to be worn every time a head and trunk pack is worn This is the more conservative approach, as it will capture everybody, but cost is expected to be higher. Costs reflect this second option. An estimated 1,000 dosimeters will need to be purchased.
• Survey instruments: upfront purchase of 5 new survey meters at $2,500 each; modification of 10 meters at$20 each; annual calibration and maintenance of 15 meters at $125 each • Survey instruments, annual calibration Labour costs for dosimetry Three submissions – nuclear power plant licensees’ estimates • Additional processing time for HP techs:$65 per hour x 600 h (2,400 badges for lens of an eye and approximately 0.25 h processing time for each)
• Additional processing time for HP techs:  $65 per hour x 600 h (2,400 badges for lens of an eye and approximately 0.25 h processing time for each) • Assuming 100 dosimeter packs are analysed each year, each taking .25 hours. Revision of dosimetry service documentation Two submissions – nuclear power plant licensees’ estimates • 5 weeks to revise documentation; labour includes health physics technician as well as health physicist and management review –$65/h x 150 h
• Assuming 40 hours needed to revise each procedure and approximately 12 procedures and 3 forms need to be revised, plus other updates

Three submissions – nuclear power plant licensees’ estimates

• Input training change request and support subject matter expert for training development
• Train 3 technicians, $65 per hour for 4 hours • Communications roll-out, preparing communications packages (40 hours), staff meetings (30 hours) Modification of dosimetry software Three submissions – nuclear power plant licensees’ estimates • RIS: vendor support ($120 per hour x 200 hours)
• Lab software changes – estimate
• RIS:  HP support ($100 per hour x 200 hours) • In-house (dosimetry lab) algorithm development$65,000 ($100 per hour x 650 hours) • One time cost includes: 2 persons working on the project for 8 weeks, 40 hours/week and$300 (rate of a database administrator)
• On-going maintenance: 2 hours/week for 50 weeks and hourly rate of $62.50 Additional staff required during maintenance outages One submission – nuclear power plant licensee’s estimate • Because new eye dose limits are more restrictive (down to 50 mSv from 100 mSv), the ECL will have to be lowered to ensure dose limits are not exceeded. Only 7 workers have received beta exposures between 15 and 20 mSv over the past 11 years. Since the lens of an eye dose is 1.3 times higher than the whole body dose, the proposed changes to the lens of an eye dose limit will impact only 7 workers. It is unlikely that more than two workers per year will have dose levels greater than 15 mSv. Replacement staff may be required during maintenance outages: 2 workers, 1 outage per year, 6 weeks x 60 at a rate of$62.50

Other costs
Two submissions – nuclear power plant licensees’ estimates

• Due diligence – request licence amendment, type test report, letters to the CNSC, respond to dosimetry service licence only
• Third party testing: independent and performance testing fees from third party
• Potential cost for administrative issues (eye examinations, WSIB, etc.)

Continue to monitor dosimetry and modify as necessary – Direct compliance, labour
One submission – nuclear power plant licensee’s estimate

• Manage eye dose, from in-processing, through field activities, to final dose – this excludes dosimetry service lab technician

Continue to monitor dosimetry and modify as necessary – Further revision of dosimetry documentation and training
Two submissions – nuclear power plant licensees’ estimates

• 5 weeks to revise dosimetry documentation, $1,000 incremental cost (not specified), and revise 20 high-hazard (8 hours) and 30 low-hazard (6 hours) REPs • Revise 20 high-hazard and 30 low-hazard REPS • Procedures for in-processing of workers, dose management, exposure control, etc., not lab procedures • Dosimetry training, 3 technicians, 4 hours at$65/hour

Continue to monitor dosimetry and modify as necessary – Other costs
Two submissions – nuclear power plant licensees’ estimates

• Modify IT software: changes to RIS and RDS, not lab software
• Due diligence – respond to CNSC inspections
• Due diligence, workplace surveys – includes follow-up on lower-level notifications, assuming 25 hours per inspection, per month

## Table A.4: For all new requirements

This provision impacts all active licensees (1,570).

Activity Assumptions
Make documentation available for inspection – CNSC’s estimate
• Compliance cost is having the documentation available for inspection. Although not all licensees are inspected annually, the CNSC used this assumption since there is no data to assume otherwise
Document revision for all new requirements
• It is assumed that it will take 10 hours to update each licensee's radiation protection program
Document revision for all new requirements – stakeholder’s estimate
• One stakeholder submitted costs for revisions to seven documents: four for radiation protection and one each for training, operations and the emergency response program
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