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
Preface
This regulatory document is part of the CNSC’s reporting requirements series of regulatory documents, which also covers reporting requirements for nuclear power plants and Class I nuclear facilities. The full list of regulatory document series is included at the end of this document and can also be found on the CNSC’s website.
Regulatory document 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, incorporates and clarifies requirements found in the Nuclear Safety Control Act (NSCA) and regulations made under the NSCA. This regulatory document also provides guidance for reports and notifications that licensees must submit to the Commission. It also provides details on the events, situations and dangerous occurrences that must be reported.
Guidance contained in this document exists to inform the applicant, to elaborate further on requirements or to provide direction to licensees and applicants on how to meet requirements. It also provides more information about how CNSC staff evaluate specific problems or data during their review of licence applications. Licensees are expected to review and consider guidance; should they choose not to follow it, they should explain how their chosen alternate approach meets regulatory requirements. For existing facilities: The requirements contained in this document do not apply unless they have been included, in whole or in part, in the licence or licensing basis.
An applicant or licensee may put forward a case to demonstrate that the intent of a requirement is addressed by other means and demonstrated with supportable evidence.
The requirements and guidance in this document are consistent with modern national and international practices addressing issues and elements that control and enhance nuclear safety. In particular, they establish a modern, risk-informed approach to reporting requirements.
For information on the implementation of regulatory documents and on the graded approach, see REGDOC-3.5.3, Regulatory Fundamentals.
The words “shall” and “must” are used to express requirements to be satisfied by the licensee or licence applicant. “Should” is used to express guidance or that which is advised. “May” is used to express an option or that which is advised or permissible within the limits of this regulatory document. “Can” is used to express possibility or capability.
Nothing contained in this document is to be construed as relieving any licensee from any other pertinent requirements. It is the licensee’s responsibility to identify and comply with all applicable regulations and licence conditions.
1. Introduction
1.1 Purpose
This regulatory document sets out requirements and guidance for reports and notifications that licensees of waste nuclear substances, Class II nuclear facilities and users of prescribed equipment, nuclear substances and radiation devices must submit to the Canadian Nuclear Safety Commission (CNSC). This document also presents the types of reports and the applicable timeframe for reporting.
Licensees and those who transport nuclear substances are required to report to the CNSC regarding situations, events and dangerous occurrences. Regulatory document REGDOC-3.1.3 incorporates and clarifies requirements found in the Nuclear Safety and Control Act (NSCA) and regulations made under the NSCA, including requirements for content and timing of reports. Additionally, it provides guidance on the interpretation and scope of application of these requirements in the context of Class II nuclear facilities, nuclear substances and radiation devices and waste nuclear substance licensees.
Further to the reporting requirements set by the NSCA and the regulations, a licence may contain any term or condition that identifies a reporting requirement and the time frame for submitting the report. This document provides guidance on these licence conditions, including the submission of an annual compliance report (ACR).
1.2 Scope
This regulatory document incorporates and clarifies requirements found in the NSCA, the regulations made under the NSCA and licence conditions for reporting. Reporting requirements found in the NSCA and the regulations apply to all licensees; licence conditions for reporting apply only to those licensees who have said conditions included in their licence.
Note: The term “reporting” means reports on events, notifications and the submission of specific records, along with ACRs. Specifically, this document covers the following types of reports and notifications:
- preliminary reports and immediate notifications
- full reports
- action level reports
- specific reports under the Packaging and Transport of Nuclear Substances Regulations, 2015 (PTNSR 2015)
- ACRs
This document applies to licensees of waste nuclear substances, Class II nuclear facilities and users of prescribed equipment, nuclear substances and radiation devices and those who transport nuclear substances under the PTNSR 2015. Class I and uranium mines and mills licensees who are also authorized to conduct these activities under their Class I and uranium mines and mills licences should instead consult either REGDOC-3.1.1, Reporting Requirements for Nuclear Power Plants, version 2 or REGDOC-3.1.2, Reporting Requirements, Volume I: Non-Power Reactor Class I Facilities and Uranium Mines and Mills, as appropriate.
Nothing contained in this document is to be construed as relieving any licensee from any other pertinent requirements. It is the licensee’s responsibility to identify and comply with all applicable regulations and licence conditions.
1.3 Relevant legislation
The following provisions of the NSCA and the regulations made under it are most relevant to this document:
- Nuclear Safety and Control Act:
- subsection 24(5)
- paragraph 27(b)
- section 45
- General Nuclear Safety and Control Regulations:
- section 15
- subsections 28(1), (2) and (3)
- sections 29, 30, 31 and 32
- Radiation Protection Regulations:
- paragraph 6(2)(c)
- paragraphs 16(a) and (e)
- Class II Nuclear Facilities and Prescribed Equipment Regulations:
- subsection 17(1)
- paragraph 19(2)(d)
- Nuclear Substances and Radiation Devices Regulations:
- subsection 18(3)(d)
- subsection 30(2)
- sections 35 and 38
- Packaging and Transport of Nuclear Substances Regulations, 2015:
- subsections 3(3)(b) and (c), (4) and (5)(a) and (d)
- paragraphs 32(a) and (d)
- subsection 36(2)
- sections 37, 38, 40(4) and (6) and 41(a)
As part of Appendix A, the relevant reporting requirement provisions found in the NSCA and regulations made under the NSCA are provided in full.
2. Reporting Requirements
The following reporting requirements apply to licensees of waste nuclear substances, Class II nuclear facilities and users of prescribed equipment, nuclear substances and radiation devices:
- After determining if a situation, event or dangerous occurrence is reportable, the licensee shall immediately notify, or make a preliminary report to, the Commission.
- The licensee shall file a report to the Commission in response to an event, a situation or a dangerous occurrence.
- As required, licensees shall provide other notifications or reports, including a failure to comply with section 26 of the PTNSR 2015.
- All reports filed by the licensee shall contain the name and address of the sender of the report, and the date the report was submitted to the Commission.
- The licensee shall report on the licence conditions listed in Appendix A of this document as applicable to the licensee.
- A full report, preliminary report or notification shall:
- contain the specific information required by the reporting provision; see sections 3.1, 3.2 and Appendix A for guidance
- be submitted within the time frames as required by the reporting provision; see Appendix A for guidance
Guidance
The NSCA and the regulations made under the NSCA state that reports are submitted to “the Commission”. In terms of submitting reports and notifications, “the Commission” is understood to be the CNSC. If needed, reporting parties should contact their CNSC point of contact for information on how to submit any particular report. Once a report is submitted, the point of contact may contact the licensee if more information is required.
Appendix A lists the situations, events and dangerous occurrences that require a report or notification, along with time frames for providing the respective reports or notifications.
The first priority for any situation, event or dangerous occurrence is to ensure that reasonable measures have been taken to mitigate the potential consequences for the health and safety of persons or the environment, or for security. For reporting requirements involving “immediate” notification of the Commission, notification should occur as soon as practicable after the licensee becomes aware that a situation, event or dangerous occurrence is reportable and has taken reasonable mitigation measures. Complete remediation of the situation or event is not required prior to reporting.
A preliminary report or notification that must be submitted immediately may only be provided in person or by telephone to either the duty officer through the emergency telephone number at 613‑995‑0479 (or toll-free at 1-844-879-0805), or the licensee’s CNSC point of contact, depending on the situation, event or dangerous occurrence. If the point of contact cannot be reached, the Duty Officer must be notified.
Table A indicates to whom licensees should send their preliminary reports. Note that a licensee should speak to someone; leaving a voicemail or sending an email is not acceptable. Further information on reporting is available on the CNSC website.
Full reports that do not include prescribed information (e.g., security issues) may be filed by email, fax or regular mail. All related information required under the regulations or a licence condition may also be submitted in electronic format (e.g., emails with pdf attachments, scanned copies of documents and photographs). Note: Prescribed information must not be transmitted electronically.
Licensees should report any of the following events to the CNSC, directly through the duty officer: an event or incident that triggers actions under emergency response programs, even if it is a false alarm, and an event such as a spill, a release or an injury that could trigger stakeholder interest.
The licensee should make all reasonable efforts to obtain timely information that has been reviewed for accuracy when filing a report to the CNSC. For reports of situations or events that have not attained stability and predictability, timeliness of informing CNSC staff of the situation or event should be prioritized over the availability of data and/or information.
A situation, event or dangerous occurrence that triggers multiple reporting provisions may be amalgamated into a single report at the licensee’s discretion.
A situation, event or dangerous occurrence that triggers reporting by multiple parties may be amalgamated into a single report, subject to the approval of the CNSC.
Licensees should use the reporting provisions of table A that best correspond to the situation(s), event(s) or dangerous occurrence(s).
Flexibility is allowed for integrated/harmonized reporting. For example, if a licensee is required to submit reports to regulatory bodies other than the CNSC, then sending a copy of the report to the CNSC is acceptable provided the copied report contains all of the reporting information required by the CNSC. This option allows the licensee to avoid duplication of effort and to minimize the administrative burden.
If, after further investigation, the licensee concludes that a situation or event was not reportable, the licensee may provide the CNSC with a written statement that includes a rationale to support this conclusion.
If the licensee determines that investigation beyond the preliminary report is unlikely to yield further relevant details or identify additional corrective actions to prevent recurrence of the situation or event, then a full report may not be necessary. In this case, only one report may be submitted; however, the preliminary report should include the information that would have been required in the full report.
Licensees may use the situation or event reporting according to this regulatory document as input to their public disclosure protocol as applicable.
A report should not contain any proprietary business information so it can be made available to the public upon request. Information should be considered public for the most part. Any information considered classified, protected, proprietary or personal should be submitted with the appropriate security precautions and marked with appropriate protection and classification.
3. Content of Reports and Notifications
Table A in Appendix A provides a list of the situations, events and dangerous occurrences for which a report or notification is required, and includes the timing for each report or notification.
3.1 Preliminary reports and immediate notifications
Both a preliminary report and an immediate notification of a situation, event or dangerous occurrence shall contain the following information, as applicable:
- the location
- the circumstances, which may include:
- a description of the situation, event or dangerous occurrence
- date and time of the onset and the duration (if known), or date and time of discovery (if the time of occurrence is not known)
- whether the situation, event or dangerous occurrence is ongoing
- a description of any actions taken or proposed to mitigate the situation, event or dangerous occurrence and reestablish control of the nuclear substance or prescribed equipment
- confirmation that any workers who were exposed to radiation as a consequence of the situation, and whose dose limit has exceeded the regulatory limit, have stopped any work that is likely to add to the dose of the worker (this includes any work outside of the situation, event or dangerous occurrence that has the potential to add to the dose of the worker)
Guidance
A notification refers to the obligation to inform the CNSC of a situation. A preliminary report is required in certain circumstances. If further reporting is necessary, a full report must be submitted in accordance with the table in Appendix A.
The preliminary report typically contains preliminary, readily available or provisional information on the situation, event or dangerous occurrence being reported. Without compromising safety or recovery, it is important to begin the data collection phase immediately following the situation, event or dangerous occurrence to ensure that data is not lost. The information that should be collected consists of conditions before, during and after the situation, event or dangerous occurrence; personnel involvement (including actions taken); environmental factors; and other information having relevance to the situation, event or dangerous occurrence.
If the licensee has additional information on the situation, event or dangerous occurrence (such as descriptions of any nuclear substances, radiation devices, prescribed equipment or packages), they should include it in the preliminary report or notification.
If available, preliminary reports should contain enough information such that CNSC staff have an understanding of the effects of the situation, event or dangerous occurrence on the health, safety and security of Canadians and the environment.
Contact information, including phone number and email if available, for the person reporting the event should be provided with a preliminary report or immediate notification, along with the names of the persons involved in the situation.
3.2 Full reports
A full report shall contain the following information as far as practicable and applicable:
- reference to the original preliminary report or notification
- the date, time and location where the situation or event occurred or, if unknown, the approximate date, time and location, and the date and time of becoming aware of the situation or event
- the probable cause of the situation or event
- a description of the situation or event and the circumstances including, if applicable, any problem with a radiation device or prescribed equipment
- the effects on:
- the health, safety and security of persons or the environment
- the maintenance of national security
- if applicable, international obligations that have been compromised as a result of the situation or event
- the effective dose and equivalent dose of radiation received by any person (including whether they are nuclear energy workers) as a result of the situation or event, including the measured or estimated doses to the public
- if the situation or event involved an exposure device, the qualifications of the workers, including any trainees, who were involved
- if applicable, information on the activity of the nuclear substance, and the name, model and serial number of the radiation device or prescribed equipment involved
- for dangerous occurrences (under the PTNSR 2015), the names of persons involved and the details of the packaging and packages
- the actions that the licensee has taken or proposes to take, including actions identified and taken to re-establish normal operations, actions taken to mitigate the impact on people and the environment and actions taken or proposed to prevent a recurrence
- any actions that the licensee has taken to inform the public and target audience about the situation or event according to the public disclosure program, if applicable
- if applicable, the information specified in section 3.3, Action level reports
Guidance
The full report is a written evaluation of a situation, event or dangerous occurrence, prepared in sufficient detail to enable assessment of the significance, consequences or implications of the situation, event or dangerous occurrence; and to enable the evaluation of actions being employed to correct the condition and to avoid recurrence. This report is generally required within 21 days after the preliminary report of the event and should be submitted to the CNSC point of contact unless otherwise specified in Table A. There should be sufficient information included to allow for efficient review of the report. For example, the report should:
- identify updates and information that is new or additional to that provided previously
- identify the location of the event through drawings or pictures
- identify any further missing information and the date that the missing information will be provided to the CNSC
- identify the target completion date for each action that the licensee proposes to take to re‑establish normal operations or to prevent a recurrence
- provide all details and assumptions in the calculations of estimated doses
- provide statements from persons involved with or witnesses of the situation, event or dangerous occurrence
- provide a summary of any analysis completed, including the probable cause(s) and conclusions drawn from the investigation(s) after the situation or event
- provide an evaluation of any deficiencies in design, operations, training, management or human performance uncovered by the situation or event
- provide an evaluation of any corrective actions taken and their effectiveness, including recommendations for continuous improvement
3.3 Action level reports
When a licensee with an action level in their licence becomes aware that an action level has been reached, the licensee shall:
- within the time period specified in the licence, notify the CNSC that an action level has been reached
- file a report with the CNSC that:
- describes the results of the investigation conducted to establish the cause of reaching the action level
- describes the steps identified and taken to restore the effectiveness of the radiation protection program
- identifies any incomplete information and describes how and when the information will be provided to the CNSC
- for licensees holding a WNSL, describes the steps identified and taken to restore the effectiveness of the environmental protection program, if applicable
3.4 Specific reports under the PTNSR 2015
Expert assessment of an event in packaging and transport
As per subsection 36(2) of the PTNSR 2015, after a dangerous occurrence the consignor, carrier or consignee must have an expert in radiation protection assess the situation. The expert must report the results of the assessment as soon as feasible to the CNSC.
Note: “As soon as feasible” means as soon as possible after becoming aware that a dangerous occurrence is reportable, but after the obligations listed in subsection 36(1) of the PTNSR 2015 have been met.
Annual report of radiation detections in packaging and transport
As per subsection 3(1) of the PTNSR 2015, any nuclear substance referred to in paragraph 2(2)(o) (of the PTNSR 2015) must be characterized at the earliest possible time to determine the extent to which it is subject to the PTNSR 2015 and the Nuclear Substances and Radiation Devices Regulations (NSRDR).
As per paragraph 3(3)(b) of the PTNSR 2015, the person who performs the characterization must file an annual report to the CNSC by April 30 that contains a summary of radiation detections for the calendar year before the date of the report.
3.5 Other reportable situations and events
The licensee may report on all other situations or events that are not otherwise specified in this document but can be reasonably assumed to be of regulatory interest, including notifications and situation or event reports to other regulatory agencies within the scope covered by the objects of the Commission (see section 9 of the NSCA).
Guidance
As an example, the licensee may submit to the CNSC copies of the report(s) or notification(s) prepared for other governing regulatory bodies.
4. Annual Compliance Report (ACR)
The licensee shall submit an ACR in the form specified by the licence conditions, which includes:
- information that can be made available to the public (note: any classified, protected, proprietary or personal information shall be submitted to the CNSC in accordance with the appropriate security precautions and marked with appropriate protection and classification)
- sufficient details to provide CNSC staff with information to verify that licensees are meeting their regulatory requirements and are operating safely
Guidance
If information from any previous ACR is needed for completeness, the licensee should repeat it to the appropriate level of detail. ACR forms are available on the CNSC’s Annual Compliance Reporting Web page. ACR forms are grouped by licence category and customized for the activity authorized by the licence.
Each annual compliance report should act as a stand-alone document. If any of the information has previously been provided to the CNSC (for example, in an event report or in a separate or previous compliance report), this information does not need to be duplicated. In these cases, a reference(s) pointing to the previous report(s) is adequate.
For licensees holding a WNSL, a sample structure for an annual compliance report, based on the CNSC’s SCA framework, is provided in Appendix B. The licensee is under no obligation to follow this format if a different format is outlined in the WNSL Licence Condition Handbook. However, the report may include all of the information listed in Appendix B, as applicable. If a particular SCA is not relevant or does not apply, the licensee shall include a statement to that effect in the report.
Appendix A: Reports, Notifications and Timing
Table A lists the situations and events that require a report or notification, along with time frames for providing the report or notification. The first priority for any event is to ensure that the reporting party has taken all reasonable measures to mitigate the potential consequences of the event.
For all reportable situations or events, the preliminary report is due immediately (where “immediately” means as soon as the licensee becomes aware that an event is reportable) and, if required, shall be updated with additional information in a full report, generally within 21 days after the licensee becomes aware of the event.
In addition to the reporting requirements given in the NSCA and regulations made under it, a licensee’s licence conditions may contain additional reporting requirements. Licence conditions with reporting requirements are included in table A and only apply to licensees with said conditions in their licences.
Table A also identifies the person to whom licensees should send their reports or notifications (either the CNSC duty officer [613-995-0479 or toll-free at 1-844-879-0805] or the licensee’s designated contact).
Table A: Situations and events for which a report or notification is required, including the timing
No. | Event, notification or filing of specific records with the CNSC | Timing | ||
---|---|---|---|---|
Notification or filing of specific records | Preliminary event reports | Full report | ||
A. | Authorized activities | |||
1 | Contravention of the Nuclear Safety and Control Act (NSCA) in relation to an activity that is authorized | |||
| Applicable section(s) of the NSCA or regulations made under the NSCA: NSCA: “27. Every licensee and every prescribed person shall …
General Nuclear Safety and Control Regulations (GNSCR): “29(1) Every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it:
| Immediate Notify CNSC point of contact | Within 21 days after becoming aware of the event | |
2 | Notification of authorized delegates and responsible persons | |||
| Applicable section(s) of the NSCA or regulations made under the NSCA: GNSCR: “15. Every applicant for a licence and every licensee shall notify the Commission of
Guidance These positions include radiation safety officers and applicant authorities. | Within 15 days Notify CNSC point of contact | ||
B. | Management system, human performance, conventional health and safety, financial status | |||
3 | Contingency plan | |||
3a | Applicable section(s) of the NSCA or regulations made under the NSCA: GNSCR: “29(1) Every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it: …
Guidance A contingency plan may be required for:
Full reports may not be necessary if a contingency plan is triggered but the situation is resolved quickly and prior to the contingency plan being fully implemented. |
| Immediate Notify duty officer | Within 21 days after becoming aware of the event |
3b) |
Guidance The licensee should report any actual, impending, planned or threatened work disruption, including a slowdown, study day, walkout or strike, or another action (such as a civil demonstration) that could affect the safety or security of operations or the capability of the licensee to maintain the staffing levels required by the licensee. Situations involving the possibility of a strike are considered to be reportable when a union is in a legal strike position, regardless of whether any actual strike activity has taken place. |
| Immediate Notify CNSC point of contact | Within 21 days after becoming aware of the event |
4 | Serious illness, injury or death | |||
| Applicable section(s) of the NSCA or regulations made under the NSCA: GNSCR: “29(1) Every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it: …
Guidance Illnesses and injuries that do not result directly from the licensed activity do not need to be reported. (e.g., the death of a patient in the hospital is not reportable but the death or injury of a patient as a result of malfunctioning certified prescribed equipment is reportable.) |
| Immediate Notify duty officer | Within 21 days after becoming aware of the event |
5 | Financial status | |||
Applicable section(s) of the NSCA or regulations made under the NSCA: GNSCR: “29(1) Every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it: …
|
| Immediate Notify CNSC point of contact | Within 21 days after becoming aware of the event | |
C. | Records | |||
6 | Inaccurate or incomplete records | |||
6a) | Applicable section(s) of the NSCA or regulations made under the NSCA: GNSCR: “31(1) Every licensee who becomes aware of an inaccuracy or incompleteness in a record that the licensee is required to keep by the Act, the regulations made under the Act or the licence shall file a report of the inaccuracy or incompleteness with the Commission within 21 days after becoming aware of it, and the report shall contain the following information:
(2) Subsection (1) does not apply to a licensee if
Guidance Examples of inaccuracies or incompleteness in records can include changes in dosimetry records or action levels, changes in operational policies and procedures in radiation safety manuals, inaccurate commitments made to the CNSC, or inadvertent loss or destruction of records. Licensees should notify the CNSC of any changes in their radiation safety manual and any failure to record the release of a nuclear substance as required by the licence. |
|
| Within 21 days after becoming aware of the inaccuracy OR Not required if GNSCR 31(2) applies |
6b) | Licence condition 2920 The licensee shall report to the Commission or a person authorized by the Commission, as soon as is practicable, the discovery of any inaccuracy or incompleteness in the documents referred to in the Appendix: Licence Document(s). | As soon as practicable Notify CNSC point of contact |
|
|
7 | Notification and filing of record of disposal of records | |||
Applicable section(s) of NSCA or regulations made under the NSCA: GNSCR: “28(2) No person shall dispose of a record referred to in the Act, the regulations made under the Act or a licence unless the person
(3) A person who notifies the Commission in accordance with subsection (2) shall file the record, or a copy of the record, with the Commission at its request.” Guidance Examples of records include licence applications, inventories of nuclear substances and/or radiation devices, survey meter calibration certificates, training certificates and leak test certificates. Licensees do not have to wait for a response from the CNSC following the notification to dispose of the records as long as 90 days have passed. A copy of the notification should be kept by the licensee. | At least 90 days before the date of disposal Notify CNSC point of contact |
|
| |
D. | Operating performance | |||
8 | Failure, degradation or weakening of operating conditions | |||
8a) | Applicable section(s) of the NSCA or regulations made under the NSCA: GNSCR: “29(1) Every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposed proposes to take with respect to it: …
Guidance Reporting should include any incipient failure, abnormal degradation or weakening of any systems that could result in a hazard to the health and safety of any person, or that could prevent the system from performing its intended safety function or meeting its limiting conditions for safe operation. Some examples of events that could result in adverse effects are:
|
| Immediate Notify duty officer | Within 21 days after becoming aware of the event |
8b) | Licence condition 2017 The licensee shall notify the Commission of any operation to recover a sealed source stuck in a borehole prior to conducting the operation. | Prior to conducting the operation Notify CNSC point of contact |
|
|
8c) | Licence condition 2026 The licensee shall submit a written report to the Commission within 21 days of submitting the preliminary report of any sealed source that has been abandoned down a borehole. Guidance The report should include:
|
| Immediate Notify duty officer | Within 21 days of submitting the preliminary report |
8d) | Licence condition 2298 Upon request from the Commission or a person authorized by the Commission the licensee shall notify the Commission in writing of the storage site(s) of each nuclear substance. Guidance The licensee should submit the information to the person who made the request. The notification should be provided in the format and method detailed by the requester. | Upon request, in writing Notify the person who made the request |
|
|
8e) | Licence condition 2300 The licensee shall, for any site where licensed activities are to be conducted for more than 90 consecutive days, notify the Commission in writing of the site within 7 days of starting to conduct the activities at the site. The licensee shall notify the Commission in writing within 7 days of the discontinuance of licensed activities at any site. The continuity of consecutive days is not broken during offsite use or offsite temporary storage. Guidance “90 consecutive days” is equivalent to 90 calendar days. | Within 7 days of starting or discontinuance Notify CNSC point of contact |
|
|
8f) | Licence condition 2524 Upon request from the Commission or a person authorized by the Commission the licensee shall notify the Commission in advance of the time, date and location of each job site. Guidance The licensee should submit the information to the person who made the request. The notification should be provided in the format and method detailed by the requester.
| Upon request in advance Notify the person who made the request |
|
|
8g) | Licence condition 2970 The licensee shall submit a written report to the Commission within 21 days of submitting the preliminary report of any neutron generator that has been abandoned down a borehole to include:
Guidance Descriptions of the integrity of the neutron generator should be provided, if known.
|
| Reportable under licence condition 2975 (See section 8h of table A) | Within 21 days after submitting the preliminary report
|
8h) | Licence condition 2975 The licensee shall immediately make a preliminary report to the Commission of the location and circumstances of the situation involving any neutron generator the licensee has abandoned in a borehole. |
| Immediate Notify CNSC point of contact |
|
8i) | Licence condition 2985 The licensee shall notify the Commission of any operation to recover a neutron generator stuck in a borehole prior to conducting the operation.
| Prior to conducting the operation Notify CNSC point of contact |
|
|
9 | Nuclear substances, radiation devices, and exposure devices and sealed source assemblies, and Class II equipment | |||
9a) | Applicable section(s) of the NSCA or regulations made under the NSCA: Nuclear Substances and Radiation Devices Regulations (NSRDR): “30(2) Every licensee who becomes aware of any of the following situations shall notify the Commission immediately of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it:
| Immediate Notify duty officer |
| Within 21 days after the day on which the licensee becomes aware of the event |
9b) | NSRDR: “38(1)Every licensee who possesses or uses a nuclear substance or a radiation device and becomes aware of any of the following situations shall notify the Commission immediately of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it: …
Guidance Examples of reportable situations may include the inability to retract a source to the shielded position in a portable gauge, shutter damage on a radiation device, and when a portable gauge is crushed at a worksite. Spills less than 100 exemption quantity are not reportable but may be recorded by the licensee in their internal documentation, which can be used during a licensee’s review of their safety practices. If, however, a spill of less than 100 exemption quantities of the nuclear substance results in personnel contamination with a resulting dose above the CNSC regulatory limits, it is reportable. | Immediate Notify duty officer |
| Within 21 days after the day on which the licensee becomes aware of the event |
9c) | Applicable section(s) of the NSCA or regulations made under the NSCA: Class II Nuclear Facilities and Prescribed Equipment Regulations (CNFPER): “17(1) Every licensee who installs a sealed source in any Class II prescribed equipment other than a pool-type irradiator shall, after installing the source, take measurements of radiation dose rates when the equipment is not in the irradiation mode and notify the Commission in writing as soon as practicable if the dose rate at any location that is 1 m from any sealed source in its shielded position exceeds the manufacturer’s specifications.” Guidance In many instances, a CNSC servicing licensee is contracted to install the sealed sources and take the measurements; they are responsible for notifying the Commission. | In writing, as soon as practicable Notify CNSC point of contact |
|
|
9d) | NSRDR: “35(1) Every licensee who uses more than 2 GBq of a nuclear substance that is not a sealed source for the purpose of conducting a tracer or subsurface tracer study shall notify the Commission before conducting the study. (2) Every licensee shall, within 60 days after using a nuclear substance referred to in subsection (1) for the purpose of conducting a tracer or subsurface tracer study, file with the Commission a report that includes:
| Before conducting the study Notify CNSC point of contact |
| Within 60 days after using a nuclear substance |
10 | Counterfeit, fraudulent or suspect items | |||
Specific reporting provisions The licensee shall report on the discovery of counterfeit, fraudulent or suspect items during the conduct of licensed activities. |
| Immediate notification to the CNSC point of contact | Within 60 days after becoming aware of the event | |
11 | Other reportable situations and events | |||
The licensee may report on all other situations or events that are not otherwise specified in this document but can be reasonably assumed to be of regulatory interest, including notifications and situation or event reports to other regulatory agencies within the scope covered by the objects of the Commission (see section 9 of the NSCA). Guidance As an example, the licensee may submit to the CNSC copies of the report(s) or notification(s) prepared for other governing regulatory bodies. | Simultaneous with submitting the report to the other regulatory agency; otherwise, immediately notify CNSC point of contact |
| Upon request | |
E | Radiation protection | |||
12 | Actual or potential exposure in excess of legal radiation dose limits | |||
12a) | Applicable section(s) of the NSCA or regulations made under the NSCA: GNSCR: “29(1) Every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it: …
Guidance Limits are provided under the Radiation Protection Regulations (RPR), sections 13, 14 and 15. An example of when an event is “likely” to result in an exposure in excess of a limit is where there is a reason to believe that a regulatory dose limit may be exceeded but has not yet been confirmed. The CNSC’s expectations for the reporting of skin contamination incidents is that only instances in which the dose exceeds 10 percent of the corresponding dose limit must be reported. An information document on this subject is available on the CNSC’s website. “Persons” include nuclear energy workers, pregnant nuclear energy workers and any person who is not a nuclear energy worker. If a licensee submits this report, a separate report under section 16 of the RPR is not required, if the event is the reason that the person exceeded the regulatory dose limit. |
| Immediate Notify duty officer | Within 21 days after becoming aware of the event |
12b) | RPR: “16. When a licensee becomes aware that a dose of radiation received by and committed to a person or an organ or tissue may have exceeded an applicable dose limit prescribed by section 13, 14 or 15, the licensee shall
Guidance Results of the investigation are expected to confirm whether the exposure resulted in a dose that exceeded the applicable dose limits. Examples of possible overexposure:
| Immediate Notify duty officer |
| Within 21 days after becoming aware that the dose limit has been exceeded |
12c) | NSCA: “45. Every person who, on reasonable grounds, believes that
shall immediately notify the Commission or an appropriate authority of the location and circumstances of the contamination or event.” Guidance NSCA 45(b) applies to every person who is aware of the event. | Immediate Notify duty officer |
|
|
12d) | Licence condition 2601 If thyroid screening detects more than 10 kBq of iodine-124, iodine-125 or iodine-131, or 100 kBq of iodine-123 in the thyroid, the licensee shall immediately make a preliminary report to the Commission or a person authorized by the Commission and have bioassay performed within 24 hours by a person approved by the Commission to provide internal dosimetry. |
| Immediate Notify CNSC point of contact |
|
13 | Reaching an action level for the purposes of environmental or radiation protection | |||
13a) | RPR: “6(2) When a licensee becomes aware that an action level referred to in the licence for the purpose of this subsection has been reached, the licensee shall …
Guidance Each licensee’s specific values for action levels are defined in the licensee’s radiation protection program and are referenced in the licence. | Within the period specified in the licence Notify CNSC point of contact
|
|
|
13b) | Licence condition 2700 Subject to any other condition of this licence and unless otherwise permitted by the prior written approval of the Commission or a person authorized by the Commission, the licensee shall report in writing to the Commission or a person authorized by the Commission within 48 hours after becoming aware that any action level specified in the Appendix: Licence Documents has been reached. | Within 48 hours in writing Notify CNSC point of contact
|
|
|
13c) | Licence condition 2945 The licensee shall report in writing to the Commission or a person authorized by the Commission within 21 days after becoming aware that any action level specified in the Appendix: Licence Documents has been reached. Guidance If the results of the investigation are known, they should be included in the report. | Within 21 days in writing Notify CNSC point of contact
|
|
|
13d) | Licence condition found in some WNSLs: The licensee shall implement and maintain an environmental protection program, which includes a set of action levels. When the licensee becomes aware that an action level has been reached, the licensee shall notify the Commission within X days. Note: In the specific licence condition, “X days” is replaced with a specified period. Each licensee’s specific values for action levels are defined in the licensee’s environmental protection program. | Within the period specified in the licence |
| Within 21 days of the notification date or, if the licence specifies a different time period, within that time period |
14 | Nuclear and hazardous substance release | |||
14a) | Applicable section(s) of the NSCA or regulations made under the NSCA: GNSCR: “29(1) Every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it: …
Guidance Releases outside the scope of the licensed activity or above disposal limits are reportable. For example, licensees should report on the following:
|
| Immediate Notify duty officer | Within 21 days after becoming aware of the event |
14b) | Licensees holding a WNSL shall report on:
Guidance Some examples of events that should be reported are:
For item a), a failure to collect an individual sample where justified, is not considered failure to monitor, For the purpose of event reporting, failure to monitor is more appropriately considered in the context of programmatic failure. |
|
|
|
15 | Notification of sealed source leakage of 200 Bq or greater | |||
Applicable section(s) of the NSCA or regulations made under the NSCA: NSRDR 18(3) and CNFPER 19(2)(d): “Where a licensee, in the course of conducting a leak test on a sealed source or on shielding, detects the leakage of 200 Bq or more of a nuclear substance, the licensee shall… (d) immediately after complying with paragraphs (a) to (c), notify the Commission that the leakage has been detected.” Guidance If the leakage of the sealed source leads to an event as found in GNSCR 29(1), a full report is required. | Immediately after complying with paragraphs 18(3)(a) to (c) of the NSRDR OR paragraphs 19(2)(a) to (c) of the CNFPER Notify CNSC point of contact |
| Within 21 days after becoming aware of an event as set out in GNSCR 29(1) | |
F. | Security | |||
16 | Theft or loss of nuclear substance, prescribed equipment or prescribed information | |||
Applicable section(s) of the NSCA or regulations made under the NSCA: NSCA: “27. Every licensee and every prescribed person shall:
| Immediate | Within 21 days after becoming aware of the event | ||
GNSCR: “29(1) Every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it:
OR | Immediate Notify duty officer | Within 21 days as per GNSCR 29(2) | ||
NSRDR: “38(1)Every licensee who possesses or uses a nuclear substance or a radiation device and becomes aware of any of the following situations shall notify the Commission immediately of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it:
Guidance A nuclear substance is as defined in section 2 of the NSCA, and includes controlled nuclear substances as defined in the Nuclear Non-Proliferation Import and Export Control Regulations, subsections 1(1) and 1(2). Prescribed equipment and prescribed information are as defined in sections 20 and 21 of the GNSCR, and include controlled nuclear equipment and controlled nuclear information as defined in the Nuclear Non-Proliferation Import and Export Control Regulations, subsections 1(1), 1(3) and 1(4). | Immediate Notify duty officer | Within 21 days as per NSRDR 38(2) | ||
17 | Actual or attempted breach of security or act of sabotage | |||
Applicable section(s) of the NSCA or regulations made under the NSCA: GNSCR: “29(1) Every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the location and circumstances of the situation and of any action that the licensee has taken or proposes to take with respect to it: …
Guidance Includes any damage to any building or equipment that might affect the security of the facility or site, and includes actual or attempted theft, loss or unauthorized movement of nuclear substances or prescribed information. Examples include but are not limited to:
The report should include a description of any signs of wrongful entry, efforts undertaken in recovering the source and whether local authorities have been notified. Note: “Security” includes cybersecurity (such as hacker attacks on computer systems). | Immediate Notify duty officer | Within 21 days after becoming aware of the event | ||
G | Sealed source tracking | |||
18 | Filing of a sealed source tracking report | |||
Licence condition 2404 and licence condition 2406* Unless otherwise permitted by the prior written approval of the Commission or a person authorized by the Commission, the licensee shall, in respect of a radioactive nuclear substance set out in the Appendix: Nuclear Substances and Radiation Devices, or in the Appendix: Nuclear Substances and Class II Prescribed Equipment of this licence, report in writing to the Commission or a person authorized by the Commission any transfer, receipt, import or export of any sealed source:
The written report shall be in a form acceptable to the Commission that includes:
* For licence condition 2406, the list of applicable nuclear substances has been omitted for ease or reading. Guidance The report can be provided through the Sealed Source Tracking System (SSTS), within 48 hours (2 business days). | Report in writing at least 7 days before transfer or export, and within 48 hours of receipt of a transfer or import Notify CNSC point of contact through SSTS |
|
| |
H | Safeguards and non-proliferation | |||
19 | Safeguards | |||
Applicable section(s) of the NSCA or regulations made under the NSCA: GNSCR: “30(1) Every licensee who becomes aware of any of the following situations shall immediately make a preliminary report to the Commission of the situation and of any action that the licensee has taken or proposes to take with respect to it:
(2) Every licensee who becomes aware of a situation referred to in subsection (1) shall file a full report of the situation with the Commission within 21 days after becoming aware of it, unless some other period is specified in the licence, and the report shall contain the following information:
Guidance If there is any question as to whether interference, theft, loss or sabotage of safeguards equipment or samples collected for the purpose of safeguards inspection has occurred, the licensee should make a preliminary report. | Immediate Notify CNSC point of contact | Within 21 days after becoming aware of the event | ||
I. | Packaging and transport | |||
20 | Characterizing a nuclear substance | |||
20a) | Applicable section(s) of the NSCA or regulations made under the NSCA: Packaging and Transport of Nuclear Substances Regulations, 2015 (PTNSR 2015): “2(2)These Regulations, except for sections 6 and 7, do not apply to the packaging and transport of a nuclear substance …
3(3)(c) The person who performs the characterization must immediately notify the Commission if the source of the radioactivity in the load is determined to be a licensable quantity of a nuclear substance. | Immediate Notify duty officer
Immediate Notify CNSC point of contact | ||
20b) | PTNSR 2015: “3(4) If the measured dose rate at the time that the alarm is triggered is greater than 5 µSv/h and less than or equal to 25 µSv/h and there is no loss or dispersal of the nuclear substance during the transport, the consignor, the carrier and the consignee must
Guidance This reporting requirement applies if an alarm has been triggered and therefore a person is characterizing a nuclear substance in a load that is being transported (see paragraph 2(2)(o) of the PTNSR 2015). The measurement of the dose rate should be taken at the external surface of the vehicle used for transport. The expert in radiation protection may be an employee of the consignor, carrier or consignee (e.g., a radiation safety officer), or may be an independent consultant retained for the purpose of assessing the situation and reporting to the Commission. | Immediate Notify CNSC point of contact if known. Otherwise, notify duty officer | Within 10 days of the initial detection (if the quantity is licensable) OR Within 21 days after the initial detection (if the quantity is not licensable) | |
20c) | PTNSR 2015: “3(5) If the measured dose rate at the time that the alarm is triggered is greater than 25 µSv/h but less than or equal to 500 µSv/h and there is no loss or dispersal of the nuclear substance during the transport, the consignor, carrier and consignee must
Guidance This reporting requirement applies if an alarm has been triggered and therefore a person is characterizing a nuclear substance in a load that is being transported (see paragraph 2(2)(o) of the PTNSR 2015). The measurement of the dose rate should be taken at the external surface of the vehicle used for transport. The expert in radiation protection may be an employee of the consignor, carrier or consignee (e.g., a radiation safety officer), or may be an independent consultant retained for the purpose of assessing the situation and reporting to the Commission. |
| Immediate Notify CNSC point of contact if known. Otherwise, notify duty officer | Within 10 days of the initial detection (if the quantity is licensable)
OR
Within 21 days after the initial detection (if the quantity is not licensable)
|
21 | Actual or potential exposure in excess of legal radiation dose limits (during transport) | |||
Applicable section(s) of the NSCA or regulations made under the NSCA: PTNSR 2015: “32. Every consignor, carrier or consignee who becomes aware that a dose of radiation received by a person may have exceeded an applicable dose limit prescribed by the Radiation Protection Regulations must
Guidance Results of the investigation are expected to confirm whether the exposure resulted in a dose that exceeded the applicable dose limits. | Immediate Notify duty officer |
| Within 21 days after becoming aware that the dose limit may have been exceeded | |
22 | Dangerous occurrence | |||
Guidance Dangerous occurrences with respect to packaging and transport of radioactive material are defined in section 35 of the PTNSR 2015. Dangerous occurrences do not include minor errors in documentation, labelling or handling. Similarly, they do not include any instance of non-compliance with the PTNSR 2015 or with any licence or certificate applicable to a package that may be reasonably expected to have no adverse effects on the environment, the health and safety of persons, or national security. |
|
|
| |
22a) | Applicable section(s) of the NSCA or regulations made under the NSCA: PTNSR 2015: “35. For the purpose of sections 36 to 38, a dangerous occurrence is any of the following situations:
Guidance Regardless of the severity of the accident, the reporting requirements remain unchanged. All accidents involving a conveyance carrying radioactive material must be reported. |
| Notify duty officer | Within 21 days after the dangerous occurrence, to CNSC point of contact |
22b) |
|
| Notify CNSC point of contact (if package is at destination with no leakage) Notify duty officer (if the package has leaked or has not yet reached its destination) | Within 21 days after the dangerous occurrence, to CNSC point of contact |
22c) |
|
| Notify duty officer | Within 21 days after the dangerous occurrence, to CNSC point of contact |
22d) |
|
| Notify CNSC point of contact (if containment system is broken but the leak is contained in the internal package) Notify duty officer (if the leak is not contained) | Within 21 days after the dangerous occurrence, to CNSC point of contact |
22e) |
|
| Notify duty officer | Within 21 days after the dangerous occurrence, to CNSC point of contact |
22f) |
“Exception 37(2) No preliminary report is required for the dangerous occurrence referred to in paragraph 35(f) in respect of the internal surfaces of a tank or intermediate bulk container, as those terms are defined in the IAEA Regulations – or of a freight container or conveyance – that is dedicated to the transport of unpackaged radioactive material under exclusive use for as long as it remains under that specific exclusive use.” |
| Notify duty officer | Within 21 days after the dangerous occurrence, to CNSC point of contact |
22g) |
Guidance As per paragraph 35(g) of the PTNSR 2015 not all non-compliances are considered a dangerous occurrence, and therefore reportable. Only those non-compliances that can adversely affect the environment, the health and safety of persons or national security are reportable. Examples of non-compliances, relating to the transport documents that would not require reporting are:
Note that if no transport document is present, during transport, this would be reportable. Examples of non-compliances, relating to the labelling or marking of packages that would not require reporting are:
Note that if no transport labels are displayed on the package, this would be reportable. However, it should also be noted that for any non-compliances with section 26 of the PTNSR 2015 reports are required. |
| Call the 24-hour number on the shipping document and notify CNSC point of contact (if during transport) | Within 21 days after the dangerous occurrence, to CNSC point of contact |
22h) | PTNSR 2015: “36(2) As soon as feasible after a dangerous occurrence has occurred the consignor, carrier or consignee of the package or radioactive material involved in the occurrence must have an expert in radiation protection assess the situation. The expert must report the results of the assessment to the Commission as soon as feasible.” Guidance The expert in radiation protection may be an employee of the consignor, carrier or consignee, or may be an independent consultant retained for the purpose of assessing the situation and reporting to the Commission. | As soon as feasible after a dangerous occurrence Notify CNSC point of contact |
|
|
22i) | PTNSR 2015: “37(1) Immediately after becoming aware of a failure to comply with the requirements of section 26 or after the obligations set out in subsection 36(1) have been discharged, every consignor, carrier, consignee and holder of a licence to transport a package while in transit must make a preliminary report of the situation to the Commission.” | Immediate Notify CNSC point of contact | ||
“38. Within 21 days after the failure to comply with the requirements of section 26 or after the dangerous occurrence, the consignor, carrier and consignee and any holder of a licence to transport a package while in transit must file a full report with the Commission that includes the following information:
Guidance Subsection 37(1) and section 38 refer to section 26, which sets out the requirements for presenting a package containing radioactive material or a nuclear substance for transport. Subsection 37(1) refers to subsection 36(1), which sets out the [non-reporting] obligations of the consignor, carrier or consignee in the event of a dangerous occurrence. As stated in subsection 37(2), “no preliminary report is required for the dangerous occurrence referred to in paragraph 35(f) in respect of the internal surfaces of a tank or intermediate bulk container, as those terms are defined in the IAEA Regulations – or of a freight container or conveyance – that is dedicated to the transport of unpackaged radioactive material under exclusive use for as long as it remains under that specific exclusive use.” |
| Within 21 days after a dangerous occurrence or a failure to comply with the requirement To CNSC point of contact
| ||
23 | Package is damaged, tampered with, or contents are outside the containment system | |||
Applicable section(s) of the NSCA or regulations made under the NSCA: PTNSR 2015: “40(3) Every person who receives a package or who opens a package must, at that time, determine if any of the following conditions exist:
(4) If any of the conditions exist, the person must immediately make a preliminary report to the Commission and to the consignor. (5) The preliminary report must include information on how and where the condition was discovered and on any action that the person has taken or proposes to take with respect to it. | Immediate Notify duty officer (if the issue with the package may cause an immediate danger to the health and safety of persons or the environment) | |||
(6) Within 21 days after the condition has been discovered the consignor and the person who made the preliminary report must file a full report with the Commission that includes the following information:
Guidance If the issue with the package does not cause an immediate danger to the health and safety of persons or the environment, the reporter may notify their CNSC point of contact for the immediate report. For example:
|
|
Notify CNSC point of contact | ||
24 | Notification of undeliverable consignments | |||
Applicable section(s) of the NSCA or regulations made under the NSCA: PTNSR 2015: “41. If a consignment cannot be delivered to the consignee, the carrier must
Guidance The intent is for the carrier to notify the CNSC when a shipment cannot be delivered to the consignee in order for the CNSC to ensure that the undelivered consignment is secured until they can be delivered or returned to the consignor. Note that this section only requires a notification to the CNSC. As this is a notification only, the CNSC does not expect a report. | As soon as feasible Notify CNSC point of contact (if known) |
|
|
Appendix B: Sample Structure and Content for an Annual Compliance Report for Waste Nuclear Substance Licensees
This appendix provides a sample structure for an annual compliance report for Waste Nuclear Substance Licensees, based on the CNSC’s safety and control areas (SCAs). The licensee is under no obligation to follow this format; however, the report may include all information as applicable. For more information on SCAs and the specific areas within each SCA, refer to the CNSC website.
Waste Nuclear Substance Licences (WNSLs) cover a broad range of sites and activities, including:
- universities
- decommissioned and remediated mines
- waste management sites
- sites which process waste
As such, this sample structure should be used solely as a guideline; licensees shall report only on the areas which are applicable to their site or activity. If a particular SCA is not relevant or does not apply, the licensee shall include a statement to that effect in the report.
Cover page
The cover page of the report should clearly summarize the name of the facility, the licensee and the reporting period.
Note: Where the period for a set of information is different from the reporting period, the licensee should use the information that most closely aligns with the reporting period. The licensee should clearly identify this detail. In all cases, each annual compliance report shall be contiguous with the previous annual report.
Table of contents
The following is a suggested structure that licensees may use for their annual compliance report:
- 1.0 Identifying information
- 2.0 Introduction
- 3.0 Safety and control areas
- 3.1 Management system
- 3.2 Human performance management
- 3.3 Operating performance
- 3.4 Safety analysis
- 3.5 Physical design
- 3.6 Fitness for service
- 3.7 Radiation protection
- 3.8 Conventional health and safety
- 3.9 Environmental protection
- 3.10 Emergency management and fire protection
- 3.11 Waste management
- 3.12 Security
- 3.13 Safeguards and non-proliferation
- 3.14 Packaging and transport
- 4.0 Other matters of regulatory interest
- 4.1 Licensee’s public information and disclosure program
- 4.2 Financial guarantees
- 4.3 Other facility-specific matters of regulatory interest
Identifying information
The report should include the following identifiers:
- licensee’s name
- licence number
- name of the facility or facilities (as identified in the licence or LCH)
- reporting period
- licensee’s business address (including suite number, if applicable, and postal code)
Introduction
The report should include the following general information:
- document report date
- a summary of the licensee’s compliance with other federal, provincial and municipal regulations
- a summary of any new licensed activities (since the last compliance report)
- a summary of significant modifications or changes to the site or facility, including modifications to any facility buildings, processes, equipment, procedures, programs or organizational structure
Safety and control areas
The report should include information on all applicable SCAs. Information that should be discussed under each SCA, if applicable, is described below.
Management system
The report should include, as applicable:
- a description of the degree of implementation of the management system and the scope of activities it applies to
- a conclusion of the effectiveness of the management system in meeting all of its requirements (including all the programs and safety areas under the management system), supported by a summary of the outcome of assessments of the effectiveness of each element of the management system, plus any resultant improvement actions and their progress
- an overview and the conclusions of audits of the management system carried out by the licensee and external parties, including a description of any resultant actions and the status of these actions
- a summary of any revisions or changes to the management system, its processes and the documents that describe it and the reason for any change
- a summary of any changes to the organizational structure and the roles and responsibilities of the persons responsible for the management and control of the licensed activity and the nuclear substance, nuclear facility, prescribed equipment or prescribed information encompassed by the licence, including the revised organizational structure, roles and responsibilities
Note: The expectation is that the effectiveness of individual programs is to be reported under their respective SCAs.
Human performance management
The annual compliance report should include, as applicable:
- a description of the implementation status of the various programs used in the management of human performance, and of the interfaces between the programs
- an assessment of the overall human performance at the licensed site
- a summary of the applicable training, including how the training programs satisfy the conditions outlined in the licensee’s LCH as well as the legislative requirements of the Nuclear Safety and Control Act (NSCA) and the regulations made under the NSCA; a general description of relevant statistics should include mandatory federal and provincial legislative training activities and job/task-specific training activities
Note: For any mandatory training program (such as the radiation protection training program), the licensee is required to provide training and qualification statistics (such as completion rate), including a comparison with the performance benchmark adopted by the licensee - confirmation that the licensee had a sufficient number of qualified workers to carry on the licensed activities safely and in accordance with the NSCA and the regulations made under the NSCA
- any matters concerning the examination for certification and the certification of personnel (including recertification and decertification) and any change in status of certified personnel (for example, termination, removal from duties, failure to pass a requalification exam, retirements and transfers)
Operating performance
The report should include, as applicable:
- an assessment of how well the licensee conducted operations in accordance with the licensee’s relevant programs and procedures
- an overview and the conclusion of any audits (related to the licensed activities) that were carried out by the licensee and external parties during the review period
- information about compliance with operational limits and conditions
- a summary of reportable events during the review period, excluding exceedances of radiation and environmental protection regulatory limits and action levels (which should be reported under the radiation protection section and the environmental protection section of this report)
Safety analysis
The report should include, as applicable:
- a description of how the facility’s overall safety case was validated and maintained over the reporting period, including an assessment of the effectiveness of the validation and maintenance
- a summary of all modifications and changes to the facility that may affect that facility’s safety analysis
- a description of actual or potential hazards or benefits/improvements associated with those modifications and changes
- a description of how the preventive measures and strategies for the potential hazards are implemented, along with the evaluation of their effectiveness
- where applicable, a description of the effectiveness of the nuclear criticality program
Physical design
The report should include, as applicable:
- a summary of the changes that occurred in the physical design and related activities that affect the ability of structures, systems and components (SSCs) to meet and maintain their design basis
- for any major changes, a description of all validation activities and the results of the validation
Fitness for service
The report should include, as applicable:
- a description of the effectiveness of the maintenance, surveillance, and in‑service inspection and testing programs, including post-maintenance verification and testing
- a description of the effectiveness of all aging management strategies
Radiation protection
The report should include, as applicable:
- a summary of the application of the ALARA (as low as reasonably achievable) principle; that is, a description of initiatives and activities undertaken to improve the control of worker doses and radiological hazards for the reporting period, and a summary of initiatives and targets for the upcoming year (next reporting period)
- a summary that evaluates the radiation protection program performance against the initiatives and activities identified above, including a discussion of initiatives and activities that were planned but not completed or conducted
- a summary of revisions and improvements to the radiation protection program; some examples are methods and processes, instrumentation and equipment, procedures and training programs
- a summary of radiation doses received by all persons as a result of the licensed activity during the reporting calendar year (that is, January 1 to December 31) according to the following specifications:
- radiation dose data should be reported for all monitored persons and additional dose data should be provided for each work group, as identified by the licensee (for example, various operational work groups, administrative staff, contractors and visitors)
- radiation dose data should include, as a minimum, the total number of persons monitored and the average, maximum and collective dose for all groups of persons as defined above, for the reporting period; two averages should be reported – an average that includes dose values of zero, and an average of all measurable doses that excludes the zero dose values, where:
- average dose is the arithmetic mean of all exposure results for persons monitored for that licensed activity during the reporting period
- maximum dose is the highest dose incurred by an individual as a result of the licensed activity during the reporting period
- the maximum individual dose for the current five-year dosimetry period should be provided
- the radiation dose data should be reported as effective dose, with additional data for each assigned dose component (for example, internal, long-lived radioactive dust, radon progeny) each dose component category should include the average and maximum dose, as well as the number of persons assigned a dose in each category
- the equivalent dose results (for example, extremity, skin and lens of the eye) should be reported for all monitored persons and for all additional groups of persons as defined by the licensee, as applicable
- the radiation dose data should be presented in tabular or graphical format, and should include the distribution of radiation doses by total number of persons monitored by dose range; dose ranges should be appropriate for the range of data and should include the following ranges as a minimum: 0 mSv; 0.01 to 1.00 mSv; 1.01 to 5.00 mSv; 5.01 to 10.00 mSv; 10.01 to 20.00 mSv; > 20.01 mSv
- an assessment of the significance of the radiation dose trends from year to year should be included, for a minimum period of five years
- a discussion of data and results, including an assessment of trends and fluctuations, of routine radiation surveys and contamination monitoring conducted during the reporting period; some examples are:
- radiation field surveys
- measurements of the concentrations of airborne nuclear substances
- measurements of surface contamination
- personnel contamination events
- a summary of the estimated effective doses to members of the public, including:
- the results and calculations of the annual radiation doses to the representative persons and/or critical group or groups in comparison to the regulatory public dose limit
- a description of the environmental transfer / exposure pathways associated with the operation of the facility, including the dispersion and dosimetric models used
- the mean and maximum doses
- a discussion of the significance of the data
- a description of the trends from year to year, with comments on their significance, for a period of five years
Conventional health and safety
The report should include, as applicable:
- a discussion of the conventional health and safety program and its effectiveness, including:
- frequency of internal and external inspections, audits and reviews
- a description of the findings and corrective actions from the inspections, audits and reviews
- a discussion of effectiveness and adequacy of managerial control on the prevention of unreasonable risks to persons
- details of the occupational/conventional health and safety committee
- a summary of any conventional health and safety improvements and revisions; some examples are methods, instrumentation, equipment and procedures
- a discussion of all conventional health and safety occurrences related to non-radiological health and safety activities, including medical aids/consultations and lost-time incidents (frequency and severity)
Environmental protection
The report should include, as applicable:
- a summary of effluent (air and water releases) monitoring, including:
- a description of the monitoring and testing methods, quality assurance, quality control and detection limits
- discussion on how the results were estimated or calculated
- data for both radiological and non-radiological releases (for example, activity, concentrations, flow rates and loadings)
- an analysis of the effluent monitoring results, including:
- a discussion of any emerging trends
- a separate discussion for each air and water quality monitoring activity on the significance of the air and water release monitoring results
- details on how these trends or results relate to the estimated dose to the public and any critical groups
- trends from year to year, for a period of five years or longer
- whenever either an environmental protection regulatory limit was exceeded or action level was reached, a summary of the investigations completed and corrective actions taken
- an overview of how the environmental protection program is reviewed and its effectiveness, including:
- the frequency of internal and external inspection, audits and reviews
- a description of the findings and corrective actions
- a summary of any environmental protection program improvements and revisions; some examples are the methods, instrumentation, equipment and procedures
- for the environmental protection program performance:
- a description of all performance and initiatives compared against the goals and targets for the year
- a summary of initiatives and targets for the upcoming year
- an evaluation of whether the environmental protection program met its previous year objectives, goals and targets
- a summary of environmental monitoring, including:
- a description of the monitoring and testing methods, quality assurance, quality control and detection limits
- discussion on how the results were calculated
- data for both radiological and non-radiological releases (for example, activity, concentrations)
- an analysis of the environmental monitoring results, including:
- a discussion of any emerging trends
- a separate discussion for each environmental monitoring activity on the significance of the results
- trends from year to year, for the same period of five years or longer as for the effluent monitoring results
- a summary of spills to the environment, including a description of any corrective actions taken, and their effectiveness
Emergency management and fire protection
The report should include, as applicable:
- a summary of emergency preparedness activities at the licensed site, including:
- a description of the effectiveness of the program and any review
- a summary of any changes and improvements to the emergency preparedness program
- a summary of the fire protection activities at the licensed site, including:
- the frequency of the inspections, audits, drills and reviews
- any findings and corrective actions
- a description of the effectiveness of the program and any review
- a summary of any changes and improvements to the fire protection program
Waste management
The report should include, as applicable:
- a description of any change or improvement made to the waste management activities during the reporting period
- identification and characterization of the waste streams generated by the operation of the facility, including:
- production rates and volumes
- physical, chemical and radiological characteristics of each of the waste streams
- inventories of each of the following, including type, volume, total activity level and/or concentration:
- hazardous or radioactive waste stored onsite
- waste that is transferred elsewhere (within a site or offsite) for processing, storage or disposal
- waste that is disposed through authorized controlled releases into the environment
- a description of the effectiveness of the existing waste segregation and/or minimization components, if any, of the facility’s waste management activities, including the effectiveness of any new waste segregation and/or minimization strategies implemented in the course of the reporting period
- the results of any inspection, audit or review completed on any aspect of the waste management activities
Security
The report should include, as applicable but without compromising the security of the site, information on the status of compliance with the regulatory requirements related to security.
Safeguards and non-proliferation
The report should include, as applicable:
- an assessment of the overall performance of safeguards activities, including their effectiveness at the site
- a summary of any changes to safeguards activities
- information on safeguards inspections (if applicable), including the number and type of inspections, who performed the inspections, and any findings (such as issues, best practices, etc.) resulting from the inspections
Packaging and transport
The report should include, as applicable, a brief description of the licensee’s performance with respect to packaging and transporting nuclear substances in accordance with the appropriate regulations.
Other matters of regulatory interest
The report should include information on the following additional matters of regulatory interest:
- Public Concerns
The licensee should include any information about public concerns regarding licensed activities received during the reporting period.
- Financial guarantees
The licensee should include, as applicable, information that the financial guarantee remains valid and in effect.
- Other facility-specific matters of regulatory interest
The report may include, as applicable, information about any facility-specific matter of regulatory interest, to an appropriate level of detail.
Abbreviations
ACR | annual compliance report |
---|---|
Bq | becquerel |
CNFPER | Class II Nuclear Facilities and Prescribed Equipment Regulations |
GNSCR | General Nuclear Safety and Control Regulations |
IAEA | International Atomic Energy Agency |
µSv | microsievert |
µSv/h | microsieverts per hour |
mSv | millisievert |
NSCA | Nuclear Safety and Control Act |
NSRDR | Nuclear Substances and Radiation Devices Regulations |
RPR | Radiation Protection Regulations |
PTNSR 2015 | Packaging and Transport of Nuclear Substances Regulations, 2015 |
SSTS | Sealed Source Tracking System |
Glossary
For definitions of terms used in this document, see REGDOC‑3.6, Glossary of CNSC Terminology, which includes terms and definitions used in the Nuclear Safety and Control Act (NSCA) and the regulations made under it, and in CNSC regulatory documents and other publications. REGDOC‑3.6 is provided for reference and information.
CNSC Regulatory Document Series
Facilities and activities within the nuclear sector in Canada are regulated by the Canadian Nuclear Safety Commission (CNSC). In addition to the Nuclear Safety and Control Act and associated regulations, these facilities and activities may also be required to comply with other regulatory instruments such as regulatory documents or standards.
Effective April 2013, the CNSC’s catalogue of existing and planned regulatory documents has been organized under three key categories and twenty-five series, as set out below. Regulatory documents produced by the CNSC fall under one of the following series:
- 1.0 Regulated facilities and activities
- Series 1.1 Reactor facilities
- 1.2 Class IB facilities
- 1.3 Uranium mines and mills
- 1.4 Class II facilities
- 1.5 Certification of prescribed equipment
- 1.6 Nuclear substances and radiation devices
- 2.0 Safety and control areas
- Series 2.1 Management system
- 2.2 Human performance management
- 2.3 Operating performance
- 2.4 Safety analysis
- 2.5 Physical design
- 2.6 Fitness for service
- 2.7 Radiation protection
- 2.8 Conventional health and safety
- 2.9 Environmental protection
- 2.10 Emergency management and fire protection
- 2.11 Waste management
- 2.12 Security
- 2.13 Safeguards and non-proliferation
- 2.14 Packaging and transport
- 3.0 Other regulatory areas
- Series 3.1 Reporting requirements
- 3.2 Public and Indigenous engagement
- 3.3 Financial guarantees
- 3.4 Commission proceedings
- 3.5 CNSC processes and practices
- 3.6 Glossary of CNSC terminology
Note: The regulatory document series may be adjusted periodically by the CNSC. Each regulatory document series listed above may contain multiple regulatory documents. For the latest list of regulatory documents, visit the CNSC's Web site.
Page details
- Date modified: