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Radioactive Materials Branch
Inspection Guidance

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Industrial Radiography Licenses

 

The agency has two "categories" of industrial radiography licenses: Field and Booth.  Since these licenses authorize the "use" of industrial radiographic sources is very different configurations and operating environments, they are listed separately below.

The agency performs field audits of industrial radiography.  These audits are unannounced and occur at the temporary jobsite.  Because of this, they are typically of shorter duration that the "home office" audits. 

Listed below are some "parameters" of the Industrial Radiography Inspection.

Note: Industrial Radiography licensees are also frequently required to comply with the security requirements of 10 CFR Part 37, which are incorporated by reference in 10A NCAC 15 .1700. Please direct any questions you may have about these additional security requirements to the Radioactive Materials Branch Security Inspections contact.

 

Field   Radiography
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Inspection Frequency* (see notes below) HOME OFFICE:   Annually
FIELD USE:  No Set Frequency (see notes below)
Duration of the inspection HOME OFFICE:  3 hours to 1 day, depending on the scope and extent of licensed activities.
FIELD USE:  1 - 4 hours, depending on location, availability of crew, working conditions and findings.
Scope of the Inspection Variable for both Home Office and Field Operations.  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, 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:    Annual Radiation Protection Program Reviews conducted since last inspection, List of all approved authorized users,  Radiation Safety Manual, personnel dosimetry records (including SRPD and alarm ratemeter logs), records of receipt and disposal of sources, records required by 10A NCAC 15 .0523, 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 .0300, .0500, .1000 and .1600
FIELD USE:  All records required to be at the temporary jobsite, as defined in 10A NCAC 15 .0500,
Performance-based component The inspector will observe approved radiographers and radiographer assistants in the performance of licensed activities.  This observation may include: loading and unloading of exposure device from conveyance, boundary determinations, surveys, utilization logs, etc..  The agency's focus during this inspection is to assess radiographer's ability to control the jobsite and work safely with the equipment.
Who needs to be available for entrance and exit meetings? HOME OFFICE:   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.

FIELD USE:  Entrance and exit meetings usually involve the radiography team at the jobsite.  Many times, and especially if problems are noted, the inspector will perform a "telephone" exit meeting with the RSO (local and/or corporate as applicable).
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Booth Radiography
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Inspection Frequency* (see notes below) Every two (2) years
Duration of the inspection 3 hours to 2 days, 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 inspection process.  The scope and extent of the inspection will be discussed at the entrance meeting, 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]

Annual Radiation Protection Program Reviews conducted since last inspection, List of all approved authorized users,   Radiation Safety Manual, personnel dosimetry records (including SRPD logs), records of receipt and disposal of sources, copies of the Radioactive Materials License and all subsequent amendments, records of tests on booth (interlocks, alarms, etc.), and other pertinent records which demonstrate compliance with the applicable sections of 10A NCAC 15 .0300, .0500, .1000 and .1600
Performance-based component The inspector may observe the licensee "set-up and take a shot."  This normally includes wearing appropriate personnel dosimetry and other safety equipment, removing the exposure device from the safe, checking area for unauthorized personnel, checking postings, 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 ANYTIME.  The licensee is required to notify the agency at least THREE DAYS IN ADVANCE of ANY USE of radioactive materials at a TEMPORARY JOBSITE.  The licensee may receive multiple field inspections over the "normal" inspection cycle" timeline (e.g. 3 or 4 field inspections in a one year period).

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Last Modified: 28 October 2016
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