Radiation Protection Program Audit Checklist

• Conducted on

  Date

• Prepared by

• Location
  Address

INTRODUCTION

• License Name:

• License No.:

• Auditor:

AUDIT HISTORY

• A. Last audit conducted on:

  Date

• B. Any deficiencies noted?

  Yes

  No

• C. Were corrective actions taken?

  Yes

  No

  N/A

• D. Brief description of prior deficiencies, corrective actions taken:

ORGANIZATION AND SCOPE OF PROGRAM

• A. If the mailing address or permanent address changed, has the license been amended to reflect the change?

  Yes

  No

  N/A

• B. If ownership has changed or bankruptcy has been filed, was the agency notified?

  Yes

  No

  N/A

• C. Does the license authorize all sources & devices possessed?

  Yes

  No

• D. Do all temporary job sites meet regulatory definition (serve only one contract, open for less than 18 months)?

  Yes

  No

• E. If no to A., has the agency been notified?

  Yes

  No

• F. If the RSO has changed, has the license been amended to identify the new RSO?

  Yes

  No

  N/A

• G. Is the RSO meeting the duties & responsibilities for the position?

  Yes

  No

• H. Is company management appropriately involved with the radiation protection program & oversight of the RSO’s activities?

  Yes

  No

• I. Does RSO have sufficient time to perform all duties/responsibilities?

  Yes

  No

• J. Staffing sufficient to support to rad. protection program?

  Yes

  No

MEMBER OF PUBLIC (MOP) DOSE LIMITS

• A. Has a MOP dose compliance study been developed, submitted & approved by the agency?

  Yes

  No

• B. Have licensed activities changed during the year to increase likelihood of public dose limits being exceeded?

  Yes

  No

• C. If yes to B., has a new MOP study been performed to demonstrate compliance with MOP dose limits is still being achieved?

  Yes

  No

  N/A

TRAINING PROGRAM

• A. Are workers likely to exceed 100 mrem/yr provided radiation awareness training?

  Yes

  No

• B. Have gauge Authorized Users (AUs) completed approved training?

  Yes

  No

• C. Hazmat employee training provided to workers per 49 CFR Part 172?

  Yes

  No

• D. Field observations of operators demonstrate use of safe work practices & compliance with regulatory requirements?

  Yes

  No

  N/A

PERSONNEL MONITORING (PM)

• A. If PM is conducted:

• 1. PM badges worn properly & protected from heat, light, moisture & chemicals when not being worn?

  Yes

  No

• 2. PM badges consistently stored with the control badge in a protected location when not in use?

  Yes

  No

• 3. Are badges exchanged in a timely fashion to ensure accurate dosimetry reports?

  Yes

  No

• 4. Any badges lost or damaged?

  Yes

  No

• 5. If yes to 4., was RSO immediately notified & record of worker’s estimated dose provided to badge vendor and kept on file?

  Yes

  No

• 6. Any spare badges assigned to workers?

  Yes

  No

• 8. Are dosimetry reports reviewed by the RSO upon receipt?

  Yes

  No

• 9. Are PM records maintained on NRC-issued or equivalent forms?

  Yes

  No

• (a) NRC Form NRC-4 “Cumulative Occupational Exposure History” or equivalent completed for each monitored worker?

  Yes

  No

• (b) NRC Form NRC-5 “Occupational Exposure Record for a Monitoring Period” or equivalent completed for each monitored worker?

  Yes

  No

• 10. Upon hiring, female workers provided instructions regarding and documentation of receipt of instructions maintained on file?

  Yes

  No

  N/A

• 11. Female workers declaring pregnancy document their declaration, to the embryo/fetus, and receipt of instructions documented?

  Yes

  No

  N/A

• 12. For workers that have declared pregnancies, records kept demonstrating embryo/fetus dose < 50 mrem for gestation period?

  Yes

  No

  N/A

• 13. Annual & termination reports provided to workers per 64E-5.903?

  Yes

  No

• 14. PM records reviewed within these dates: (date range)

• 15. Highest annual dose: (mR and Date)

• 16. Occupational exposures within limits?

  Yes

  No

• 17. Do PM records indicate that worker doses are being kept ALARA?

  Yes

  No

PERSONNEL MONITORING (PM)

• B. If PM is not conducted:

• 1. Has a request for an exemption been submitted & approved by the agency?

  Yes

  No

• 2. Have licensed activities changed during the year to increase workers’ radiation exposures (i.e., expanded work load)?

  Yes

  No

• 3. If yes to 2., has a new evaluation been performed to demonstrate workers’ doses are likely to remain < 500 mrem/yr?

  Yes

  No

POSTING AND LABELING

• A. Following documented posted at permanent facility:

• 1. Emergency procedures

  Yes

  No

• 2. “Notice to Employees”

  Yes

  No

• 3. Any notice of violations, proposed imposition of administrative penalties, and agency issued orders and responses to the cited violations

  Yes

  No

• 4. Company radioactive materials license, and company operating procedures documents and where they can be viewed

  Yes

  No

• B. Above documents posted in conspicuous location(s) to permit workers to observe them on way to/from

  Yes

  No

• C. Radiation signs:

• 1. “Caution (or Danger), Radioactive Material” signs: posted at permanent facility & job sites where portable gauging devices are stored?

  Yes

  No

• 2. “Caution (or Danger), Radiation Area” signs: Is manufacturers’ storage areas?

  Yes

  No

SECURITY

• A. Each portable gauging device is provided a storage/transport container equipped w/ lock?

  Yes

  No

• B. Minimum of two independent physical controls used to prevent access to portable gauging devices during transport and temporary storage?

  Yes

  No

• C. Portable gauging devices kept secured against unauthorized access/removal when not under direct surveillance?

  Yes

  No

• D. Extra precautions used to deter theft (e.g., concealing devices from view distance, shielding, general use rules)?

  Yes

  No

OPERATING AND EMERGENCY (O&E) PROCEDURES

• A. Any revisions to O&E procedures made that have not been reviewed & approved by the agency?

  Yes

  No

• B. O&E procedures list correct phone numbers for RSO & the agency?

  Yes

  No

• C. O&E procedures accompany portable gauges at all times?

  Yes

  No

TRANSPORTATION

• A. Portable gauging devices transported to job sites are prepared & transported in same manner as when offered to third party for shipment?

  Yes

  No

• B. Only DOT-7A or other authorized packages used to transport devices?

  Yes

  No

• C. Packages used to ship devices properly marked & labeled per 49 CFR Part 172, Subparts D & E?

  Yes

  No

• D. Shipping containers properly locked, blocked & braced prior to transport?

  Yes

  No

• E. Prior to shipment, transport containers inspected to ensure proper packaging, unimpaired physical condition of container & closure devices?

  Yes

  No

• F. Properly completed bill of lading & emergency response information provided for each device shipment?

  Yes

  No

• G. Shipping papers & emergency response information immediately accessible to driver during shipment of devices?

  Yes

  No

• H. Devices classified as excepted instruments/articles (e.g., XRF analyzers) have notice included w/ package listing consignor/consignee name & conformity statement per 49 CFR 173.422?

  Yes

  No

GENERAL RULES OF USE

• A. Management & RSO emphasize to workers importance of maintaining doses ALARA?

  Yes

  No

• B. Field observations of workers conducted to evaluate performance?

  Yes

  No

• C. Good work practices used by workers to minimize doses (i.e., time, distance, shielding, general use rules)?

  Yes

  No

LEAK TESTS

• A. Sealed sources leak tested at required intervals?

  Yes

  No

• B. Leak tests conducted by authorized personnel following procedures approved by the agency?

  Yes

  No

• C. Leak test records include all information required by the agency?

  Yes

  No

• D. Any sources found leaking, & if so, was the agency notified?

  Yes

  No

GAUGE INVENTORY

• A. Receipt & transfer/disposal records maintained?

  Yes

  No

• B. Portable gauging devices physically inventoried at 6-month intervals?

  Yes

  No

• C. Inventory records document all necessary information?

  Yes

  No

GAUGE MAINTENANCE

• A. Copies of the manufacturer’s operation/maintenance manuals maintained on file for reference?

  Yes

  No

• B. Manufacturer’s procedures referenced & followed for routine cleaning & lubrication of portable gauging devices?

  Yes

  No

• C. Non-routine device maintenance performed in-house?

  Yes

  No

• D. If yes to C., is non-routine device maintenance conducted by authorized personnel following procedures approved by the agency?

  Yes

  No

RADIATION SURVEY INSTRUMENTS

• A. If a survey meter is not possessed, are specific plans in place to have one available when needed?

  Yes

  No

  N/A

• B. If a survey meter is possessed:

• 1. Has the meter been approved by the agency?

  Yes

  No

• 2. Is there access to an equivalent back-up meter when the primary meter is out for calibration/repair?

  Yes

  No

• 3. Is the meter calibrated annually & after repair by a licensed vendor, & are calibration records maintained?

  Yes

  No

RECORD KEEPING, NOTIFICATIONS & REPORTS

• A. All required documents maintained on file at permanent facility for duration specified by the agency?

  Yes

  No

• B. Did any incidents/emergencies occur since last audit?

  Yes

  No

• C. If yes to B., was the response appropriate? (i.e., operator followed emergency procedures, required notifications/reports timely filed, cause of incident investigated, corrective actions taken & documented?

  Yes

  No

INDEPENDENT AUDITS/INSPECTIONS

• A. Any independent audits/inspections conducted since last internal audit (e.g., consultant or FL BRC inspection)?

  Yes

  No

• B. If yes to A., summary of deficiencies identified & corrective actions taken:

AUDIT DEFICIENCIES & CORRECTIVE ACTIONS

• A. Summary of problems/deficiencies identified during this audit:

• B. Description of corrective actions planned or taken:

• C. Description of other recommendations for improvement: