Request for Information on Potential Impacts of Draft REGDOC-3.1.3, Reporting Requirements for Waste Nuclear Substance Licensees, Class II Nuclear Facilities and Users of Prescribed Equipment, Nuclear Substances and Radiation Devices

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 draft REGDOC-3.1.3, Reporting Requirements for Waste Nuclear Substance Licensees, Class II Nuclear Facilities and Users of Prescribed Equipment, Nuclear Substances and Radiation Devices, should it receive Commission approval. The CNSC welcomes comments on this document, as well as on the proposed regulatory document itself.

Comments could include additional information on potential impacts should the regulatory document be approved by the Commission and subsequently implemented. Should stakeholders decide to submit impact estimates, the CNSC encourages them to clearly state assumptions and provide enough detail to allow an independent observer to understand how the estimate was derived. Stakeholders could 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-3.1.3.

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 (NSCA) 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

This initiative builds on previous efforts by the CNSC to clarify its reporting requirements, including REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants, Version 2, and REGDOC-3.1.2, Reporting Requirements, Volume I: Non-Power Reactor Class I Facilities and Uranium Mines and Mills. This document will provide guidance on reporting requirements for waste nuclear substance licensees, Class II nuclear facilities and prescribed equipment licensees, nuclear substance and radiation device licensees, as well as those who transport nuclear substances under the Packaging and Transport of Nuclear Substances Regulations, 2015.

3. Objectives

The goal of this document is to provide guidance on reporting requirements for waste nuclear substance licensees, Class II nuclear facility and prescribed equipment licensees and nuclear substance and radiation device licensees. This document does not establish any new requirements, but rather provides guidance on existing requirements under the NSCA and its associated regulations. Currently, reporting requirements are found in various regulations; this document is intended to help bring requirements together in a single, convenient location for ease of reference.

This document will provide a clear reference that explains what type of reporting is required, and in what timeframe, for each set of circumstances that would require a report for waste nuclear substance licensees, Class II nuclear facility and prescribed equipment licensees and nuclear substance and radiation device licensees.

4. Regulatory approach

This document does not introduce any new requirements – it provides guidance only. It provides examples as to how to comply with the reporting requirements for waste nuclear substance licensees, Class II nuclear facility and prescribed equipment licensees and nuclear substance and radiation device licensees as established under the NSCA and its associated regulations, but it is not prescriptive. This approach provides licensees with a useful reference if they require clarity about how to comply with their reporting requirements.

5. Potential impacts

The CNSC welcomes stakeholder comments on potential impacts of REGDOC-3.1.3, should the draft regulatory document be approved. Stakeholders may consider these potential impacts in terms of costs, operations or other impacts.

6. Feedback requested

Please submit comments or feedback to the CNSC by February 15, 2019, 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