To assure compliance with the USDA radiation safety program, the Radiation Safety Division (RSD) has established an inspection program for locations that have Permit Holders using radioactive material or x-ray producing equipment. The objectives of the inspection program are to:
Inspections are usually done by appointment, with RSD Health Physicists acting as the inspectors. The inspector usually contacts the LRPO about the inspection and the LRPO helps to arrange the appointment for the inspection. The LRPO also assures that appropriate personnel are available, facilitates the inspection, and may act as the location spokesman.
During the inspection, the inspector compares the scope of radioactive material and x-ray equipment activities against the Permits at the location. The inspector looks for additional physical and administrative compliance with the Nuclear Regulatory Commission license requirements. This includes records management, inventory control, security measures, sign posting, survey methods, general training, waste management, and other criteria.
Following the inspection, an exit interview is held with the LRPO and the location management. The results of the inspection are discussed along with any apparent violations and recommendations. A detailed report is transmitted to the location management, and other appropriate officials. If the report lists recommendations or cites violations, RSD works with the location management to resolve these report findings.
The Nuclear Regulatory Commission (NRC) routinely conducts inspections at various licensee sites, including USDA sites. NRC inspections are usually unannounced, so that the Permit Holders, LRPO, other safety specialists, and management officials may be required to modify and improvise their schedule during an NRC inspection.
The scope and methodology of NRC inspections varies widely and is generally unpredictable. Therefore, on-going contact with RSD during an inspection can be helpful and is encouraged. The Radiation Safety Division should be immediately notified upon the arrival of an NRC inspector. This notification can be done openly, in the presence of the NRC inspector, as part of the RSD protocol. In case the LRPO is not present on the day of an NRC inspection, all Permit Holders and other personnel should be made aware of this requirement.
The results of the inspection are usually reported to RSD. The NRC has a complex hierarchy of citations and violations. Serious violations may be circulated to higher management within USDA, for eventual resolution.