Type II Inspection Worksheet Use Type: 816 – logging – sealed source

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Work Doc: 1 TII Records
# Description Regulatory Requirements Compliance Expectations Risk*
1

Change notified

GN 15 (c)

Changes of personnel responsible for management and control of licensed activity (RSO, Applicant Authority, Signing Authority) have been reported to the CNSC within 15 days.

M
Rating: Comments:
2

Inventory

NSRD 36 (1) (a)

A complete nuclear substance and radiation device inventory is available.

M
Rating: Comments:
3

Records retained

NSRD 36 (1) (c), (e),(3), (4)

  • (1)(c) Records of transfer, receipt, disposal and abandonment are available.
  • (1) (e) Records of inspection, measurement, test and servicing are available.
  • (3) (4) Records of inspection, maintenance , leak test and servicing are kept on file for three years.
L
Rating: Comments:
4

Licence details

NSCA 26

Licence activities are conducted in accordance with the licence.

H
Rating: Comments:
5

Annual Compliance Report

LC 2916

The licensee submits the annual compliance report in the form specified in the appendix of the licence for each year the licence is valid.

M
Rating: Comments:
6

Records retained

GN 28

  • (2) The CNSC was notified 90 days prior to the disposal of any prescribed records.
L
Rating: Comments:
7

Transfer documents

NSRD 19

  1. A copy of the most recent leak test result is provided for all transfers of radiation devices as well as instructions to follow in the event of an accident.
  2. A copy of the most recent leak test result is provided for all transfers of sealed sources or nuclear substances used as shielding.
L
Rating: Comments:
8

Authorized transfer

GN 13

All transfers of nuclear substances or radiation devices have been to authorized licensees.

H
Rating: Comments:
9

Leak test

NSRD 18 (1) (a), (b), (d)

Leak testing is performed at the required frequency following acceptable procedures.

L
Rating: Comments:
10

Leak test/event

NSRD 18 (1) (c)

Leak testing was performed immediately after any event that may have damaged the sealed source(s).

L
Rating: Comments:
11

Failed leak test

NSRD 18 (3)

Appropriate actions were taken upon detection of a leaking source.

M
Rating: Comments:
12

Reportable events

GN 29

Incidents and unplanned events havebeen immediately reported to the CNSC and a detailed written report was submitted
within 21 days (refer to NSRD 38).

H
Rating: Comments:
13

Reporting requirements

PTNS 37-38-40

The consignor, the carrier and the consignee must provide an immediate report to the CNSC (PTNS 37 (1)) and a 21 day
report (PTNS 38) when becoming aware of any of the following situations:

  • failure to comply with the requirements of section 26;
  • a conveyance carrying radioactive material is involved in an accident;
  • package damage or tampering or leaking;
  • radioactive material lost, stolen or loss of control;
  • radioactive material has escaped from a containment system, a package or a conveyance during transport;
  • failure to comply with the Act and Regulations can lead to a situation in which the environment, the health and safety of
    persons or national security is adversely affected;
  • the level of non-fixed contamination as defined in the IAEA Regulations, during transport exceeds limits;
  • licensee has provided reports of damage or tampering discovered while opening packages as per PTNS 40(4), (5), (6).
H
Rating: Comments:
14

Training and sufficient workers

GN 12 (1) (a), (b)

There are (a) a sufficient number of trained and (b) qualified workers to carry on licensed activity.

M
Rating: Comments:
15

Worker records retained

NSRD 36 (1) (b), (d), (2)

  • (1) (b) The name of each worker who handles nuclear substances and/or radiation devices is recorded (users list).
  • (1) (d) Training records for all workers who handle nuclear substances and/or radiation devices are available.
  • (2) Worker training records are kept on file for three years after termination.
M
Rating: Comments:
16

Work Procedures

LC 2393-1

Work and radiation emergency procedures are available to workers wherever nuclear substances are used or stored.

M
Rating: Comments:
17

TDG training certificate on file

TDG 6.6, 6.7

A copy of the TDG training certificate is kept on file for two years and is available to the inspector.

M
Rating: Comments:
18

List of NEWs

RP 24

A record including names and job category of each NEW is available.

L
Rating: Comments:
19

Nuclear Energy Workers informed

RP 07

  1. (1) Each NEW has been informed in writing of their NEW designation, of the risks associated with their work, of the
    regulatory dose limits and of their individual dose.
  2. (2) Female NEW has been informed in writing of their rights (RP 07) and obligations (RP 11).
  3. (3) A signed acknowledgment form is available for each NEW.
M
Rating: Comments:
20

Ascertainment and recording of doses

RP 05

  1. (1) Personnel doses are ascertained and recorded.
  2. (2) Doses are determined by (a) direct measurement or (b) estimation.
H
Rating: Comments:
21

Dose limits/body

RP 13 (1)

Dose limits not exceeded.

H
Rating: Comments:
22

Licensed dosimetry

RP 08

A licensed dosimetry service is used where the effective dose of a NEW will likely exceed 5 mSv in a one-year period.

H
Rating: Comments:
23

Meter calibrated

NSRD 20

Survey meter that is used has been calibrated within the previous twelve months of its use.

H
Rating: Comments:
24

Shipping doc kept 2 years

TDG 3.11

Shipping documents kept on file for two years.

M
Rating: Comments:
25

Operation notification

LC 2524-0

The CNSC is notified of each job site when requested.

M
Rating: Comments:
26

Storage notification

LC 2298-1

Upon requested by the CNSC, the licensee notified the CNSC of the storage site of each nuclear substance.

M
Rating: Comments:
27

Competent authority certificates

PTNS 25 (2)(c)

Consignor has competent authority certificates for applicable sources and packages (refer to SSR-6 561).

M
Rating: Comments:
28

Type A package certification

PTNS 42

Type A package design, test results and packaging instructions kept on file for two years after last shipment.

H
Rating: Comments:
29

Act/Regs available

GN 12 (1) (k)

A copy of the Act and Regulations (paper or electronic copy) are readily available to all workers.

L
Rating: Comments:
30

Logging Source Recovery Notification

LC 2017-2

The CNSC is notified prior to source recovery operations.

H
Rating: Comments:
31

Logging source abandonment approval

LC 2375-0

Written authorization from the CNSC is obtained prior to abandoning a sealed source.

H
Rating: Comments:
32

Logging Source Abandoned Report

LC 2026-3

A written report was submitted to the CNSC for any abandoned sealed source. All required information listed in this condition
was provided.

M
Rating: Comments:
33

Logging Source Requirements

LC 2185-4

Only sealed sources that meet the criteria listed in the licence condition are used or imported.

H
Rating: Comments:
34

Sealed Source Tracking (General)

LC 2406-16

The CNSC is notified of any transfer, receipt, export or import of a sealed source in accordance with the licence condition.

H
Rating: Comments:
35

Export restrictions/sealed sources

LC 2408 - 8

Exports of sealed sources are within the limits specified in the licence condition. An export licence has been issued for any exports of sealed sources exceeding the limits specified in the licence condition.

H
Rating: Comments:
36

Import Export Restrictions

LC 2480

The licensee is not authorized to import or export all items described in the schedule, Parts A and B, to the Nuclear Non-proliferation Import and Export Control Regulations, and specifically listed in the licence condition.

H
Rating: Comments:

* Risk level:

  • H - High
  • M - Medium
  • L - Low
Work Doc: 2 TII Operation/Storage
# Description Regulatory Requirements Compliance Expectations Risk*
38

Posting of Signs

RP 21

A radiation warning symbol is posted:

  1. at the boundary of and at every point of access where there is more than 100 times the Exemption Quantity of a nuclear substance; or
  2. where the radiation dose rate could exceed 25 µSv/h.
H
Rating: Comments:
39

Contact details posted

NSRD 23

The name or job title and a 24 hr. telephone number are posted in a readily visible location where the nuclear substance is
stored or used (refer to RP 21).

H
Rating: Comments:
39

Worker's obligations

GN 17

Every worker:

  • (a) uses equipment, devices, facilities and clothing in a responsible and reasonable manner in accordance with the Act,
    Regulations and Licence Conditions;
  • (b) complies with procedures and measures established by the licensee;
  • (c) informs the licensee or supervisor of any situation where there may be:
  • (i) an increase in the risk to the environment or the health and safety of persons;
  • (ii) a threat to security;
  • (iii) a failure to comply with regulatory requirements;
  • (iv) sabotage, theft, loss or illegal use or possession of prescribed equipment, or
  • (v) a release into the environment not authorized by the licence;
  • (d) observes and obeys all notices and warning signs; and
  • (e) takes all reasonable precautions to ensure the safety and security of individuals, the environment and the nuclear
    substances or facilities.
H
Rating: Comments:
40

Radiation Warning Sign

RP 22

When a radiation warning symbol is used, it is posted in accordance with regulations.

L
Rating: Comments:
41

Frivolous posting of signs

RP 23

Radiation warning signs are not posted where there is no nuclear substance or radiation device, or where there are no plans to have a nuclear substance or radiation device present.

L
Rating: Comments:
42

Storage

LC 2575-2

  1. Access to storage areas containing nuclear substances or radiation devices is restricted to authorized personnel.
  2. Dose rates at occupied areas outside storage areas do not exceed 2.5 µSv/h.
  3. Dose limits are not exceeded as a result of nuclear substances or radiation devices in storage.
H
Rating: Comments:
43

Security indicators

GN 12 (1) (c), (g), (h), (i), (j)

Provisions are in place to ensure the security of nuclear substances and radiation devices and the health and safety of persons. This may be achieved through restricted access (for example locks, alarms, and security systems) and reporting of incidents including loss, theft and sabotage.

H
Rating: Comments:
44

Sealed Source Security
Requirements

LC 2490-1

Licensees have in place security measures including:

  • Inventory accounting
  • Access control measures
  • Up-to-date security plan
  • Information security measures
  • Intrusion detection with monitoring and testing
  • Response protocol
  • Secure storage of substances and devices
  • Security awareness program
  • Vehicle security measures
L
Rating: Comments:
45

Operation/Storage
Post licence

GN 14

  • (1) A copy of the licence or an appropriate notice is posted in a conspicuous place at the site of the licensed activity.
  • (2) The complete licence is available at field locations.
L
Rating: Comments:
45

Container/Device labelled

RP 20

Each container or device containing greater than one Exemption Quantity of nuclear substance(s) is labelled with the
radiation warning symbol and the required wording.

H
Rating: Comments:
46

Use of equipment & procedures

GN 12 (1) (e)

Licensee ensures equipment, clothing and procedures are used appropriately at the site of the licensed activity.

H
Rating: Comments:
47

Record requirements (>90 days at sites)

LC 2350-2

Records and operational procedures are available at storage/use locations (greater than 90 consecutive days).

L
Rating: Comments:
48

Device provided & maintained

GN 12 (1) (d)

Required devices have been provided and have been maintained according to manufacturer's instruction.

M
Rating: Comments:
49

Location notification

LC 2300-2

CNSC was informed in writing, within seven days, of sites where licensed activities were conducted for more than 90 days. Discontinuance of such sites was also reported within 7 days.

M
Rating: Comments:
52

Operation Limitations - General

LC 2917

Activities and procedures, as listed in the licence appendix, are followed.

L
Rating: Comments:
50

Inaccuracies Notification

LC 2920-6

Changes to documents listed in the licence appendix have been reported to the CNSC.

L
Rating: Comments:
51

Survey Meter Requirements

LC 2058-1

A properly functioning survey meter is available at all times.

M
Rating: Comments:
53

ALARA/RP program

RP 04 (a)

The licensee has implemented a radiation protection program that keeps doses ALARA and includes:

  1. management control over work practices;
  2. personnel qualification and training;
  3. control of occupational and public exposure to radiation; and
  4. planning for unusual situations.
H
Rating: Comments:
54

Radiation safety

NSRD 17

Referenced emergency procedures are available to workers at the site of licensed activity.

M
Rating: Comments:

* Risk level:

  • H - High
  • M - Medium
  • L - Low
Work Doc: 4 TII Packaging and Transport
# Description Regulatory Requirements Compliance Expectations Risk*
55

Type A package requirements

PTNS 28 (1)

A Type A package must be prepared and labelled in accordance of PTNS 28(1) and associated requirements from SSR-6.
Package requirements are as follows:

  • contact dose rate below 2 mSv/h (non-exclusive use) - SSR-6 527;
  • name of consignor or consignee package - SSR-6 531;
  • shipping name - SSR-6 532 and TDG 4.11;
  • activity within limits - PTNS 26(2) and SSR-6 428;
  • UN number - SSR-6 532 and TDG 4.12;
  • "Type A" marking - SSR-6 534(b);
  • VRI code - SSR-6 534(c);
  • two (I-white, II-Yellow or III-Yellow) labels - SSR-6 538, 539, and TDG 4.6, 4.7;
  • identify the radionuclide on labels -SSR-6 540 (a);
  • maximum activity on labels - SSR-6 540 (b)(c) and TDG 4.14;
  • transport index on labels (II-Yellow and III-Yellow) - SSR-6 540(d) as determined by SSR-6 523-524;
  • package integrity must not be compromised - PTNS 24(a) and SSR-6 306(b).
H
Rating: Comments:
56

Excepted packages content/activity

PTNS 26(1)(a)

Excepted packages meet the following criteria:

  • dose rate below 0.005 mSv/h – PTNS 16 (4) and TS-R-1 516;
  • activity within limits of PTNS 16 (2) and TS-R-1 408 or 409;
  • consignor or consignee I.D. - PTNS 16 (4) and TS-R-1 – 534;
  • UN number on package - PTNS 16 (4) and TS-R-1 535 ;
  • package must be accompanied by a shipping document (A log kept by driver is acceptable for UN 2909, 2910, 2911)that identifies the shipping name and UN number -PTNS 15 (1), TDG 1.43;
  • "RADIOACTIVE" visible inside package upon opening - PTNS 16 (4) and TS-R-1 518 B for UN 2908 (Empty Packages);
  • contamination inside an empty package does not exceed 100 times the levels specified in TS-R-1 508 ( reference 520) and PTNS 16 (4);
  • Labels removed PTNS 15 (2) and TS-R-1 554.

Note – package integrity must not be compromised.

H
Rating: Comments:
57

Transport document requirement

PTNS 29 (1)

The consignor of radioactive material provides a shipping document that includes the following (refer to TDG 3.5 and SSR-6
546):

  • consignor and consignee names and addresses;
  • 24 hour contact number;
  • number of packages;
  • UN number*;
  • shipping name*;
  • Class # 7*;
  • radionuclide identification*;
  • form*;
  • maximum activity*;
  • category of package*;
  • transport index*;
  • competent authority certificate number(s)*.

For consignments of more than one package, the required information (*) must be given for each package.

  • Consignor's certification with printed name of the consignor - PTNS 25(1), TDG 3.6.1.
M
Rating: Comments:
58

Transport document location

TDG 3.7

Shipping document is located within driver's reach or in a door pocket on the driver's side - PTNS 15 (1).

M
Rating: Comments:
59

Package secured in vehicle

PTNS 25 (4)

Consignments are segregated and securely stowed (refer to SSR-6 562, 564, 574 - PTNS 25(1) and TDG 5.4). Category
II-Yellow and III-Yellow packages are not carried in compartments occupied by passengers - SSR-6 563.

H
Rating: Comments:
60

Vehicle placarded

TDG 4.15

Vehicle must be placarded on four sides when:

  • package is III-Yellow 4.16.1(2)(i);
  • package weight exceeds 500 kg; or
  • exception of PTNS 28(2)(a) is used.
M
Rating: Comments:
60

Showing proof of TDG training

PTNS 25 (1)

A person handling dangerous goods must provide their training certificate or copy of it to an inspector immediately upon
request (TDG 6.8).

M
Rating: Comments:
61

TDG training certificate

TDG 6.1, 6.3, 6.5

The employer is responsible for:

  • 6.1(2)(a) ensuring that only an adequately trained worker who holds a valid TDG certificate handle Class 7 dangerous
    goods; or
  • 6.1 (2)(b) performs those activities in the presence and under the direct supervision of a person who is adequately trained
    and who holds a training certificate in accordance with this Part.
  • 6.3 issuing training certificate that includes:
    • the employer's business address;
    • the employee's name;
    • aspects of handling and transporting;
    • employee and employer signatures; and
    • the expiry date of the certificate (TDG 6.5).
H
Rating: Comments:

* Risk level:

  • H - High
  • M - Medium
  • L - Low

Disclaimer: CNSC licensees may use this worksheet voluntarily to ascertain the CNSC`s general expectations regarding regulatory requirements. Such requirements would generally be assessed during a Type I and Type II Inspection of licences issued pursuant to the Nuclear Substances and Radiation Devices Regulations. The expectations listed for each regulatory requirement are only provided as a guide. Similar worksheets will be used by CNSC staff for on-site inspections. Inspections, will, however, be carried out on a case-by-case basis in the context of the licensed activities and the circumstances of individual situations. This worksheet is not intended to limit the scope of CNSC inspections or the powers of CNSC inspectors. Licensees should contact the CNSC to obtain information regarding their specific licence requirements.