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Type II Inspection Worksheet Use Type: 812 - Industrial radiography

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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
Ratings: Comments:
2

Inventory

NSRD 36 (1) (a) A complete nuclear substance and radiation device inventory is available. M
Ratings: 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, measurement, test and servicing are kept on file for three years.
L
Ratings: Comments:
4

Licence details

NSCA 26 Licence activities are conducted in accordance with the licence. H
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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
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6

Exposure device records retained

NSRD 37

The following records are maintained:

  1. (a) the brand name, model and serial number
  2. (b) the quantity (in Bq)
  3. (c) dates and locations of use
  4. (d) dates of receipt and transfer
  5. (e) authorized users
  6. (f) authorized workers to perform source changes
  7. (g) trainee supervisor acknowledgements
  8. (h) inspections and maintenance
  9. (i) all submitted records from workers to the licensee.
M
Ratings: Comments:
7

Source change records

NSRD 34 (1)

Person who performs source change:

  1. shall have written authorization from the licensee (reference NSRD 30 (5));
  2. shall record their DRD readings and the surface dose rates resulting from the source change; and
  3. shall report the measurements in (2) to the licensee.
M
Rating Comments:
9

Records retained Rating:

GN 28

  • (2) The CNSC was notified 90 days prior to the disposal of any prescribed records.
L
Ratings: Comments:
10

Device certification and transfer

NSRD 11

  1. All radiation devices in use are certified models (unless authorized in the licence).
  2. All radiation devices transferred to other licensees are certified models.
H
Ratings: Comments:
11

Storage notification

LC 2298-1

Upon request by the CNSC, the licensee notified the CNSC of the storage site of each nuclear device.

M
Ratings: Comments:
12

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
Ratings: Comments:
13

Authorized transfer

GN 13

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

H
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14

Leak test

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

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

L
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15

Leak test/event Rating:

NSRD 18 (1) (c)

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

L
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16

Failed leak test Rating:

NSRD 18 (3)

Appropriate actions were taken upon detection of a leaking source.

M
Ratings: Comments:
17

Head hose nozzle cap dye- penetrant tests

LC 2720 - 1

The dye-penetrant inspection of the nozzle cap has been performed annually. The nozzle cap was removed from service if cracks were apparent.

H
Ratings: Comments:
18

Maintenance requirements

LC 2719-1

The S-tube inspection is performed at the frequency specified by the manufacturer and the exposure device is removed from service if wear-through was apparent.

M
Ratings: Comments:
19

Device accidents

NSRD 21

Any radiation device involved in an accident or incident has been tested/inspected and confirmed to be functioning properly prior to return to use.

H
Ratings: Comments:
20

Reportable events

GN 29

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

H
Ratings: Comments:
21

Reporting requirements

PTNS 37-38-40

The consignor, the carrier and the consignee must provide an immediate report to 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
Ratings: Comments:
22

Training and sufficient workers Rating:

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

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

M
Ratings: Comments:
23

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.
  • (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
Ratings: Comments:
24

Appointment of supervisor of trainee

NSRD 32

The licensee has obtained a written consent from any qualified CEDO requested to supervise a named trainee.

M
Ratings: Comments:
25

TDG training certificate on file Rating:

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
Ratings: Comments:
26

List of NEWs Rating:

RP 24

A current list of NEWs including names and job categories is available.

L
Ratings: Comments:
27

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
Ratings: Comments:
28

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
Ratings: Comments:
29

Dose limits/body Rating:

RP 13 (1)

Dose limits not exceeded.

H
Ratings: Comments:
30

Action Levels

LC 2700

Upon becoming aware of an action level, specified in the Appendix: Licence documents, has been reached the licensee:

  • (a) investigated the situation,
  • (b) took the necessary corrective action, and
  • (c) notified the CNSC within 48 hr.
M
Ratings: Comments:
31

Licensed dosimetry Rating:

RP 08

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

H
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32

Meter calibrated Rating:

NSRD 20

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

H
Ratings: Comments:
33

Shipping doc kept 2 years Rating:

TDG 3.11

Shipping documents kept on file for two years.

M
Ratings: Comments:
34

Competent authority certificates

PTNS 25 (2)(c)

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

M
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35

Type A package certification Rating:

PTNS 42

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

H
Ratings: Comments:
36

Act/Regs available Rating:

GN 12 (1) (k)

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

L
Ratings: Comments:
38

Sealed Source Tracking Rating:

LC 2404-6

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

H
Ratings: Comments:
39

Import Export Restrictions

LC 2480

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

H
Ratings: Comments:
40

Export restrictions/sealed sources

LC 2408-8

Export of sealed sources is 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
Ratings: Comments:

* Risk level:

  • H - High
  • M - Medium
  • L - Low
Work Doc: 2 TII - Operation/Storage
# Description Regulatory Requirements Compliance Expectations Risk*
34

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:
35

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 (based on RP 21 requirements).

H
Rating: Comments:
36

Radiation Warning Sign Rating:

RP 22

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

L
Rating: Comments:
37

Frivolous posting of signs

RP 23

Radiation warning symbols are not posted where there is no radiation, nuclear substance or prescribed equipment.

L
Rating: Comments:
38

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/hr.
  3. Dose limits are not exceeded as a result of nuclear substances or radiation devices in storage.
H
Rating: Comments:
39

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:
39

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
H
Rating: Comments:
40

Post licence

GN 14

  1. (1) A copy of the licence or an appropriate notice is posted in a conspicuous place at the site of the licensed activity.
  2. (2) The complete licence is available at field locations.
L
Rating: Comments:
41

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:
42

Field devices I.D.

NSRD 22

Device is labelled with contact information, including 24 hour telephone number.

H
Rating: Comments:
43

Use of equipment & procedures Rating:

GN 12 (1) (e)

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

H
Rating: Comments:
44

Radiation safety Rating:

NSRD 17

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

M
Rating: Comments:
45

Maintenance limitations Rating:

LC 2093-0

Maintenance is limited to cleaning and lubrication in accordance with the manufacturer's instructions.

M
Rating: Comments:
46

Device provided & maintained Rating:

GN 12 (1) (d)

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

M
Rating: Comments:
47

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.

M
Rating: Comments:
48

Inaccuracies Notification

LC 2920-6

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

L
Rating: Comments:
49

Operation Limitations - General

LC 2917

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

L
Rating: Comments:
50

Worker's obligations

GN 17

Every worker:

  1. uses equipment, devices, facilities and clothing in a responsible and reasonable manner in accordance with the Act, Regulations and licence conditions;
  2. complies with procedures and measures established by the licensee;
  3. informs the licensee or supervisor of any situation where there may be:
    1. an increase in the risk to the environment or the health and safety of persons;
    2. a threat to security;
    3. a failure to comply with regulatory requirements;
    4. sabotage, theft, loss or illegal use or possession of prescribed equipment, or
    5. a release into the environment not authorized by the licence;
  4. observes and obeys all notices and warning signs; and
  5. takes all reasonable precautions to ensure the safety and security of individuals, the environment and the nuclear substances or facilities.
H
Rating: Comments:
51

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:

* Risk level:

  • H - High
  • M - Medium
  • L - Low
Work Doc: 4 TII Packaging and Transport
# Description Regulatory Requirements Compliance Expectations Risk*
64

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
Ratings: Comments:
65

Transport document location

TDG 3.7

Shipping document is located within driver's reach or in a door pocket on the driver's side.

M
Ratings: Comments:
66

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.
H
Ratings: Comments:
67

Exposure device exemption

PTNS 28(2)(a)

Exposure devices transported under section 28(2)(a) do not require labelling in accordance with SSR-6 538 to 540, if the following criteria are met:

  • the device is certified – PTNS 28(2)(a) and NSRD 30(1)(a);
  • is transported with goods from one consignor only and in a conveyance that is not carrying passengers;
  • the package and the overpack, if one is used, are clearly marked with the word "RADIOACTIVE" or "RADIOACTIF" PTNS 28(2)(a)(iii); and
  • the vehicle displays 4 Class 7 placards - PTNS 28(2)(a)(ii).
M
Ratings: Comments:
68

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
Ratings: Comments:
69

Type B package requirements

PTNS 28 (1)

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

  • name of consignor or consignee on package - SSR-6 531;
  • shipping name - SSR-6 532 and TDG 4.11;
  • UN number - SSR-6 532 and TDG 4.12;
  • "Type B" marking - SSR-6 535 (c);
  • fire proof trefoil SSR-6 536;
  • competent authority mark - SSR-6 535(a);
  • gross mass marked if exceeding 50 kg - SSR-6 533.

If PTNS 28(2)(a) exception is not used the following is required :

  • two (I-white, II-Yellow or III-Yellow) labels - SSR-6 538, 539 and TDG 4.6, 4.7, 4.10 which include radionuclide (most restrictive), maximum activity;
  • transport index on labels, SSR-6 540;
  • package integrity must not be compromised - PTNS 24 and SSR-6 306.
H
Rating: Comments:
69

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:
70

TDG training certificate

TDG 6.1, 6.3, 6.5

The employer is responsible for:

  1. 6.1(2)(a) ensuring that only an adequately trained worker who holds a valid TDG certificate handle Class 7 dangerous goods ; or
  2. 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.
  3. 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).
M
Ratings: 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.

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