Request for Information on Potential Impacts of Draft REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources and Category I, II and III Nuclear Material, Version 2

1. Preface

Acknowledging the draft nature of this document, the Canadian Nuclear Safety Commission (CNSC) is seeking a preliminary assessment of the potential impacts of Part B of draft regulatory document REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources and Category I, II and III Nuclear Material, Version 2, should it receive Commission approval. The CNSC welcomes comments on this document as well as on the proposed regulatory document itself.

Comments may include additional information on potential impacts should the regulatory document be approved by the Commission and subsequently implemented. The CNSC encourages any stakeholders who decide to submit impact estimates to clearly state assumptions and provide enough detail to allow an independent observer to understand how the estimate was derived. Stakeholders may also propose potential alternative approaches that meet the document's safety objectives.

The CNSC will consider comments received. Comments will be included in the main regulatory document disposition table and may lead to modifications to REGDOC-2.12.3, Version 2.

In fulfilling its mandate as a federal regulator, the CNSC must also consider values and principles that are difficult to quantify with a dollar value. It must also give consideration to fulfilling its responsibility under the Nuclear Safety and Control Act to disseminate objective scientific and regulatory information. In all cases, safety is the CNSC's top priority.

All comments received will become part of the public record.

2. Background

REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources, version 1, published in 2013, has been revised as a two-part document with a new title: REGDOC-2.12.3, Security of Nuclear Substances: Sealed Sources and Category I, II and III Nuclear Material, Version 2

Part A of REGDOC-2.12.3, Version 2 contains information published in May 2013 and applies to sealed sources. The information in Part A has not changed from the currently published document. As this part has already been consulted on and approved by the Commission, consultation on this part is now closed.

Part B contains the revised content from two CNSC guidance documents: G-208, Transportation Security Plans for Category I, II or III Nuclear Material and G-274, Security Programs for Category I or II Nuclear Material or Certain Nuclear Facilities. G-208 provides guidance for applicants to prepare a written transportation security plan with respect to a licence to transport Category I, II or III nuclear material. G-274 provides guidance to help applicants prepare and submit the security information to be included with an application for a licence in respect of Category I or II nuclear material or a nuclear facility. At this time, the CNSC is seeking comments on Part B alone.

3. Objectives

G-208 and G-274 have been merged into REGDOC-2.12.3, Version 2 as part of the CNSC's commitment to modernize its regulatory document framework.

4. Regulatory approach

G-208 and G-274 were for guidance and information purposes. The revised draft REGDOC-2.12.3, Version 2 contains no new requirements, but provides expanded guidance to help applicants prepare and submit the security information to be included with an application for a licence in respect of Category I or II nuclear material or a nuclear facility.

5. Potential impacts

The CNSC welcomes stakeholder comments on the potential impacts of Part B of REGDOC-2.12.3, Version 2 should the draft regulatory document be approved. Stakeholders may consider these potential impacts in terms of costs, operations or other factors.

6. Feedback requested

Please submit comments or feedback to the CNSC by August 3, 2018 in one of the following ways:

• Email: consultation@cnsc-ccsn.gc.ca
• Mail: Canadian Nuclear Safety Commission
  P.O. Box 1046, Station B
  280 Slater Street
  Ottawa, ON  K1P 5S9
• Fax: 613-995-5086