[ RadSafe ] Lost sources at Illinois Hospital

[Clayton J Bradt]

I posted a response to Barb's and Franz's  posts on Sunday morning but it 
seems to be still floating out there somewhere. Let me try again:

I think Dan McCarn explained quite well what I was getting at with my 
original comments.  I was not suggesting that ignoring regulations or 
losing control of sources is acceptable. Nevertheless, these types of 
incidents occur with regularity, and from my experience as a regulator the 
scenario described in the report is typical.  I am convinced that without 
regular and fairly frequent physical inspections by regulators, the 
control of radioactive sources is jeopardized.  (Even with frequent 
inspections, security is not guaranteed.)  This being the case, the 
intense pressure on states to cut payrolls could very likely result in the 
reduction of the frequency of inspections and thus increase the likelihood 
of more sources being lost track of in the future. 

As to Barb's question about a mechanism for NRC to take back an agreement: 
Such a mechanism is written into Section 274 of the Atomic Energy Act. It 
allows for a state to voluntarily discontinue its regulation of most 
radioactive materials and for the NRC to assume control. It also allows 
for the NRC to unilaterally terminate an agreement and assert regulatory 
authority in cases where the public health and safety require it.  I am 
aware of only one instance where an agreement was returned to the NRC. 
About 30 years ago (someone else may have a better recollection) the 
governor of Idaho was persuaded to ask the commission to resume its 
regulatory authority in that state. This came about only after a decade or 
so of the state having no personnel assigned to its radiation control 
program.  Presumably in the future the Commission will act with more 
alacrity. 

However, the existence of a mechanism doesn't mean that NRC has the 
capacity to absorb the radiation control programs of every state that is 
facing budgetary retrenchment.  The states regulate 80% of the materials 
licenses in the US.  NRC would have difficulty absorbing even a fraction 
of this. 

Let me also reiterate here what Barb has said about Illinois having had 
historically a very strong radiation control program. It has and I assume 
still does, and there is nothing in this event to suggest otherwise. 

Clayton J. Bradt
Principal Radiophysicist
NYS Dept. of Health
Biggs Laboratory, Room D486A
Empire State Plaza
Albany, NY 12201-0509

518-474-1993

*****************************************

Dear Clayton, 

After having read for years complaints about the "all to strict" US
regulations (spare me a comment), I am rather surprised to find here a
pledge for ignoring regulations!!! 

"Jaw dropping" has even a corresponding meaning in German and means more 
or
less the reaction to an opinion, which is first of all absolutely absurd 
and
unbelievable and secondarily totally unacceptable. 

Do you really recommend to forget radioactive sources somewhere, because
they are not needed any more? Do you recommend that they should be
forgotten, because a new RSO was appointed? 

And "retirement" is another excuse?

No, come one, you cannot be serious about your message!!!! Do other
RADSAFErs support these opinion? Hopefully not!

Franz
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Clayton & RadSafers,

I believe Illinois used to have quite a robust agreement state oversight 
program, perhaps they do not inspect known stored souces with the same 
frequently as sources in use.  I find it surprising that the program would 
not be required to have good records especially as concerns therapy 
sources, and that the safety department would not be in the loop on where 
rad safety involvement is needed.   More information is needed before 
determining the root and contributing causes of the incident. 

The great beekeeper (D.S.) of INPO taught me that the root cause is almost 
always management failure.  I do know of a (very) few cases where it was 
not, for example I don't think managment should be held responsible for a 
rogue bee flying into a car and stinging the driver. 

Is there a process that allows agreement states to revert to non-agreement 
status if they cannot fulfill the tasks of maintaining proper oversight? I 
have never seen the NRC revoke agreement state status.  I don't mean to 
imply that this one incident reflects on  Illinois' program, I am just 
asking in general since Clayton brought up the issue of the potential 
demise of good agreement programs due to the economy.

Barbara Reider, CHP
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