Your agency has a comprehensive program that guides them through the inspection process. Generally, inspectors verify that the organizational structure, operator qualifications, storage design, gauge maintenance, gauge handling, and environmental and radiation protection programs are adequate and that they comply with agency safety requirements. These inspections also cover areas such as personnel training, company radiation protection programs, dosimetry records, and security of gauges.
You can think of a regulatory inspection as an official annual audit. If you are conducting solid and successful internal annual audits you should do well during an inspection.
A good first step is to have complete and accurate recordkeeping. But make no mistake, the inspection is an interactive event. The inspector will review training records and utilization logs to determine which employees have been using gauges. They will then question employees to determine their knowledge of operating and emergency procedures. They may ride along with an employee to visually determine their understanding of the Radiation Safety Program.
The following represents a sample manual, similar to a playbook, used to inspect your premises:
- To determine if licensed activities are being conducted in a manner that will protect the health and safety of workers and the general public.
- To determine if licensed activities are being conducted in accordance with the regulatory agency requirements.
The review of the licensed activities will be commensurate with the scope of the licensee’s program. The inspector’s evaluation of a licensee’s program will be based on direct observation of work activities, interviews with workers, demonstrations by workers performing tasks regulated by the agency, and independent measurements of radiation conditions at the facility, rather than exclusive reliance on a review of records.
The inspector should determine if the licensee possesses gauges as authorized by a specific license. If so, the inspector should assess the adequacy of the licensee’s program for management and oversight of the specific licensed gauges.
The structure and the emphasis of the inspection will be on the following Focus Elements that describe the outcomes of an effective portable nuclear gauge radiation safety program:
a. The licensee should control access to and prevent loss of licensed gauges so as to limit radiation exposure to workers and members of the public.
b. The licensee should maintain shielding of gauges in a manner consistent with operating procedures and design and performance criteria for devices and equipment.
c. The licensee should implement comprehensive safety measures to limit other hazards from compromising the safe use and storage of gauges.
d. The licensee should implement a radiation dosimetry program to accurately measure and record radiation doses received by workers or members of the general public as a result of licensed operations.
e. The licensee should provide radiation instrumentation in sufficient number, condition, and location to accurately monitor radiation levels in areas where gauges are used and stored.
f. The licensee should ensure that workers are:
1. Knowledgeable of radiation uses and safety practices
2. Skilled in radiation safety practices under normal &accident conditions
3. Empowered to implement the radiation safety program
g. The licensee’s management system should be appropriate for the scope of use and should ensure:
1. Awareness of the radiation protection program
2. That audits for ALARA practices are performed
3. That assessments of past performance, present conditions and future needs are performed and that appropriate action is taken when needed
In reviewing the licensee’s performance the inspector should cover the period from the last to current inspection. However, older issues preceding the last inspection should be reviewed, if warranted by circumstances, such as incidents, noncompliance, or high radiation exposures.
The NRC’s inspection guides can be viewed in the Appendices/Attachments. (Most Agreement States also have guides – Go to the “View My State” listings to access their websites and view their versions).
Fines for violations typically begin at $3,250.00. The following are examples of actual violations:
- A current copy of the regulations is not available to radioactive material users
- A current copy of the Materials License is not available to radioactive material users
- Operating & Emergency procedures are not available to radioactive material users
- The “Notice to Employees” form is not posted or not readily visible to all gauge users
- Gauges were not adequately secured from unauthorized removal or access by unauthorized individuals
- A daily utilization log to track where, when, and by who gauges are being used is not in use
- Radioactive Material Storage areas are not posted with “Caution: Radioactive Material” signs
- Sources or cases of gauges are not labeled with radioactive material labels
- Radiation Areas were not posted with “Caution: Radiation Area” signs
- A documented Radiation Protection Program was not available for inspection
- The Radiation Protection Program does not appear to be complete or is not adequate to ensure compliance with the rules
- Annual program audits are either not performed or not documented
- The Radiation Protection Program does not adequately address the ALARA philosophy of keeping doses as low as reasonably achievable
- Inventories were not performed at the required frequency
- Inventory records do not contain the required information
- Leak tests were not performed at the required frequency
- Leak tests are not being performed in accordance with license application or rules
- Leak test records do not contain the required information
- Written procedures for receipt and opening of packages containing gauges were not readily available, or not being used
- Damaged packages were not surveyed for contamination or radiation level, or provisions to perform surveys are not in place
- Packages containing Type A quantities of radioactive material were not surveyed for radiation levels
- Package receipt surveys are not properly documented or records were unavailable
- Gauges were improperly transferred to another licensee
- Gauges were improperly transferred between branch offices of the licensee
- Radiation workers were not monitored for radiation dose
- Individuals who were monitored for radiation dose were not provided with an annual written record of their radiation dose
- Records of individual dose monitoring were not available or not complete
- Dose monitoring reports were either not reviewed or reviewer failed to take action on abnormal readings (ALARA concern)
- Individuals were allowed to use gauges without receiving adequate training
- Individuals working with gauges were not receiving annual refresher training
- Individuals were working with gauges without prior approval of the RSO
- Support staff were not trained in applicable radiation safety issues
- Training records were either not complete or not available
- Shipping papers were not compete or not is use
- Emergency response information did not accompany the shipping papers
- An emergency response phone number (monitored at all times during transit) was not available in the shipping papers
- Shipping papers are not readily available to, and recognized by, authorities in the event of an accident or inspection
- Labels and/or markings on shipping containers were either missing or incomplete
- Packages containing radioactive material were not blocked and braced during transportation
- Individuals have not received hazmat or Department of Transportation training within the last 3 years
- Special form certificates and Type A package test documents were not on file
- Transportation requirements for Type A packages were not met
- Transportation requirements for use of an overpack were not met
- Radiation worker did not have an adequate understanding of the operating procedures
- Radiation worker did not have an adequate understanding of the emergency procedures
- Radiation worker did not have an adequate understanding of the licensee’s ALARA program
- Radiation worker did not have an adequate understanding of the annual dose limits
- Radiation worker did not have an adequate understanding of survey meter use and operation
- Radiation worker did not have an adequate understanding of package receipt procedures
- Radiation worker did not have an adequate understanding of transportation procedures