RADIATION CONTROL PROGRAM
Inspection Findings and Responding to a Notice of Violation
Radiation Control will inspect your facility to determine whether you are in compliance with the rules, your approved operating, safety, and emergency procedures, and conditions of your license.
- In the case of a new license, the initial inspection occurs within six months of the date of license issuance.
- In the case of an existing radioactive material license, an inspection is performed approximately every 24 months.
The inspection is usually performed by an inspector from one of the inspection programs in the state's Public Health Regions or, in certain circumstances, by Austin central office personnel.
It is Radiation Control policy that inspections be performed unannounced, if possible.
The inspector will arrive at the inspection site and ask to speak with the individual who is in charge at the site or the individual who is listed on the license as the RSO. If an employee with knowledge of the operations under the license or the radiation safety program is not available to assist the inspector, the inspector has the option of rescheduling the inspection.
The inspector will begin the inspection by explaining the reason for the visit and describing the scope of the inspection. Inspection staff will make sure that the inspection process disrupts your business activities as little as possible. It is beneficial for the licensee to provide the inspector with an area in which to review records and record the inspection findings. This will, in most cases, expedite the inspection process.
In most cases, the inspector will ask to perform a physical inspection of your facilities, including those areas where radioactive materials are used and stored. This portion of the inspection will consist of the following.
- Observations and visual checks of the posting of storage and use areas.
- Security and proper storage of sources of radiation.
- A check for proper labeling and radiation surveys to verify radiation areas are in compliance with the rules.
- Verification that your use and storage areas remain the same as submitted and approved in the license application.
If a temporary field site use is authorized, transport vehicles will be checked for the required company signs and the United States Department of Transportation (DOT) placards.
The inspection will also include a review of records associated with operations at the main site/records location and temporary field sites. The inspector will need to determine from the available records that rules, operating, safety, and emergency procedures, and procedural and license condition requirements are being met. The inspector will request specific records that need to be reviewed in order to determine compliance. The following should be available for inspection.
- Current copy of license.
- Current copy of operating, safety, and emergency procedures.
- Training records for all users of sources of radiation.
- Receipt and transfer records for all sources of radiation.
- Survey instrument calibration records.
- Leak test records for sealed radioactive sources.
- Semi-annual inspection and maintenance records.
- Individual monitoring records.
- Semi-annual inventory records.
- Storage areas surveys.
- Utilization logs.
- Radiation protection program.
Following the inspection, the inspector will conduct a summary with management and the RSO. The inspector will explain what was covered during the inspection, the results, and violations to be cited, if any. During this inspection summary, you will have the opportunity to explain or respond to any discrepancies found during the inspection.
The inspection report will be submitted to the Austin central office where it will be reviewed and the appropriate correspondence sent to the licensee.
INSPECTION FINDINGS AND RESPONDING TO NOTICE OF VIOLATION
- If you receive a letter stating you were found to be in compliance, no response is required.
- If you receive a Notice of Violation, you are required to respond in writing to each alleged violation cited in the notice.
- >a. Respond to each alleged violation separately and include specific steps taken to correct the violation and prevent a recurrence.
- b. Include in your response the date when full compliance will be achieved.
- Included with each Notice of Violation is a "Notice of Violation -- Explanation and Guide for Response." Appendix A explains the significance of each of the five severity levels, how and what should be in your response, and the address where your response should be sent. A more detailed description of the severity levels appears in 25 TAC §289.205.
- 4. Always reference your license number when corresponding with the BRC.
- 5. When correspondence concerns a specific inspection, also reference the Compliance Number shown on the notice.
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Division for Regulatory Services - P. O. Box 149347 - Austin, Texas 78714-9347 - (512) 834-6770