RMS - Inspections of Portable Nuclear Gauging Devices

The agency regulates the use of radioactive materials used in portable nuclear gauging devices. This broad category encompasses devices such as moisture/density gauges and lead-in-paint analyzers (XRF devices). In addition to those regulations in 10A NCAC 15, the licensee must normally follow all applicable regulations of the U.S. Department of Transportation (US DOT) referenced in 49 CFR Parts 100 - 185.

Inspections of the activities authorized under this type of license can - an often will - include a field-use component. The agency has the authority to inspect field activities whenever we observe them taking place.


Inspection Frequency* (see notes below)	HOME OFFICE: Every four (4) years FIELD USE: No Set Frequency^�(see notes below)
Duration of the inspection	1 hour to 1 day, depending on the scope and extent of licensed activities.
Scope of the Inspection	Variable. Scope is determined by taking into account the COMPLIANCE HISTORY as well as issues identified during the current inspection. The scope and extent of the inspection will be discussed at the entrance meeting (for home office inspections), but MAY CHANGE depending on findings during the course of the inspection.
Information that licensee needs to make available at the time of inspection [Note: The information presented here is NOT an all-inclusive list. It is being presented here to give the licensee general guidance on records most frequently audited during an inspection]	HOME OFFICE: Organizational chart, Annual Radiation Protection Program Reviews conducted since last inspection, radiation safety procedures, personnel dosimetry records, leak tests, physical inventory of sources, records of receipt and disposal, copies of the Radioactive Materials License and all subsequent amendments, and other pertinent records which demonstrate compliance with the applicable sections of 10A NCAC 15. FIELD USE: Copy of all pertinent transportation documents (bill of lading, TYPE A package certification, etc.); copy of latest leak test, standard operating & emergency procedures, etc.
Performance-based component	Inspectors will observe the technician on the jobsite for adherence to policies and procedures. Inspectors will review transportation documentation (e.g. bill of lading), check for appropriate personnel dosimetry usage, removing gauge from storage, etc.
Who needs to be available for entrance and exit meetings?	Preferably, the highest ranking official needs to attend both the entrance and exit meetings. The agency recognizes that this is not always possible, but the expectation is that an authorized representative of that individual be present at the meetings.
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NOTES: *: Inspection frequency may vary depending upon the licensee's COMPLIANCE HISTORY. Repeat violations and violation involving health and safety issues may warrant an increased frequency of inspection. ^�Field Inspections of your operations can occur AT ANY TIME. The licensee may receive multiple field inspections over the "normal" inspection cycle" timeline (e.g. 3 or 4 field inspections in a three year period).