Request for Information on the Proposed Implementation of REGDOC-2.10.2, Emergency Management and Fire Protection: Fire Protection Program

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-2.10.2, Emergency Management and Fire Protection: Fire Protection Program 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 consider 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

Regulatory document REGDOC-2.10.2, Fire Protection, sets out guidance for the development and implementation of a fire protection program (FPP) for nuclear facilities in Canada.REGDOC-2.10.2 elaborates on FPP requirements contained in CSA standards CSA N293, Fire protection for nuclear power plants, and CSA N393, Fire protection for facilities that process, handle or store nuclear substances.

3. Objectives

The main objective of publishing this regulatory document is to improve clarity of regulatory requirements and expectations in implementing a fire protection program.

4. Regulatory approach

CNSC licensees are required to meet the provisions of CSA N293 and/or CSA N393 when these standards are referenced as part of their licence. The requirements found in N292 and N393 are sufficient to create an effective fire protection program at licensed facilities. REGDOC-2.10.2 provides clarity through supplemental guidance on CNSC’s expectations for fire protection programs.

5. Potential impacts

Stakeholders are welcome to provide information on any impacts that the regulatory document will have on the regulated community or alternative approaches to meeting the document’s objectives. 

6. Implementation

Licensees who have CSA N293 or CSA N393 in their licenses could use the guidance in REGDOC-2.10.2 to meet CNSC’s expectations. If a licensee does not have reference to either CSA N293 or CSA N393, this document would be for information only and would not create additional CNSC expectations.

Because the REGDOC does not contain any new requirements, licensees would not be required to submit a transition plan.

The CNSC welcomes stakeholder comments on potential impacts of REGDOC-2.10.2.   Stakeholders may consider impacts in terms of costs, operations or other impacts.

7. Feedback requested

Please submit comments or feedback to the CNSC by February 7, 2020, 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