Request for Information on Potential Impacts of Draft REGDOC-1.1.2, Licence Application Guide: Licence to Construct a Reactor Facility, Version 2
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-1.1.2, Licence Application Guide: Licence to Construct a Reactor Facility, Version 2 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 in the draft regulatory document.
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.
Background
REGDOC-1.1.2, Licence Application Guide: Licence to Construct a Reactor Facility, Version 2 sets out the requirements and guidance for facility design, construction and fuel-out commissioning for a reactor facility.
Construction and commissioning activities for a reactor facility are licensed under the Nuclear Safety and Control Act (NSCA).Objectives
REGDOC-1.1.2, Licence Application Guide: Licence to Construct a Reactor Facility, Version 2 identifies the information to be provided in support of an application for a licence to construct a reactor facility. It sets out requirements and guidance on submitting a formal application to the Canadian Nuclear Safety Commission (CNSC) to obtain a licence. By following the information in the regulatory document, applicants will submit the appropriate information to demonstrate that they are qualified and will make adequate provisions to undertake the activity to be licensed.
This version of the licence application guide will replace the first one, REGDOC-1.1.2, Licence Application Guide: Licence to Construct a Nuclear Power Plant, which was published in August 2019. This version:- organizes the information into the CNSC’s safety and control area (SCA) framework
- builds on the information already published in REGDOC-1.1.1, Site Evaluation and Site Preparation for New Reactor Facilities and REGDOC-1.1.3, Licence Application Guide: Licence to Operate a Nuclear Power Plant
- provides additional information on the applicant’s planned organizational structures and the oversight of contracted work as it relates to construction of a reactor facility
- provides flexibility for applications related to small modular reactors (SMRs)
(note: where appropriate, this document may be used in conjunction with REGDOC‑1.1.5, Supplemental Information for Small Modular Reactor Proponents)
Regulatory approach
No new requirements have been established in this licence application guide. The requirements were previously published in Version 1.
REGDOC-1.1.2 Version 2 organizes the information (both requirements and guidance) into the CNSC’s safety and control area framework (a standard organization for the CNSC’s technical information), and may provide more clarity in the guidance. It also provides additional clarity in terms of the information that should be considered in planning for future operation.
Guidance contained in this document exists to inform the applicant, to elaborate further on requirements or to provide information to licensees and applications on how to meet requirements. CNSC staff considers guidance when determining the adequacy of a submission. An applicant may put forward a case to demonstrate that the intent of a requirement is addressed by other means, and demonstrate this case with supportable evidence.
A graded approach, commensurate with risk, may be defined and used when applying the requirements and guidance contained in this regulatory document. The use of a graded approach is not a relaxation of requirements. With a graded approach, the application of requirements is commensurate with the risks and particular characteristics of the facility or activity. All criteria in REGDOC‑1.1.2 Version 2 are intended to be scalable to SMRs, based on the safety case for the reactor facility.
Implementation
REGDOC-1.1.2 Version 2 will become effective upon publication. New reactor facilities will be expected to follow the requirements and guidance in this regulatory document in their application for a licence to construct a reactor facility. Licence applications for small reactor facilities will be expected to follow the requirements and guidance as applicable under a graded approach.
Potential impacts
The CNSC welcomes information on the potential impacts to the regulated community or alternative approaches to meeting the document’s objectives. Interested stakeholders may provide information about the potential impacts of incorporating construction information in a periodic safety review.
Documenting acceptable practices for construction and commissioning provides clarity to applicants and licensees, which in turn is expected to result in complete applications, and therefore both an efficient and effective regulatory review.
For current licensees, many of the areas addressed in this regulatory document have already been taken into account in the existing reactor facility’s safety case.
Stakeholders may consider impacts in terms of costs, operations or other impacts.
Feedback requested
Please submit comments or feedback to the CNSC, 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, ONT K1P 5S9 - Fax: 613-995-5086
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