[ RadSafe ] Agreement States v. NRC (was: radiography incident)
Clayton J Bradt
CJB01 at health.state.ny.us
Mon Apr 2 13:10:34 CDT 2012
Bill Lipton wrote:
1. The NRC still has final responsibility. The licensee has an
State" license. Although Texas issues the license, the standards are set
by the NRC, and the NRC has responsibility for assuring that the state's
program is adequate. It seems that there are grounds for thinking
2. The problem is not the regulations, but their enforcement. " If Texas
Rad Control don't [sic] have time or expertise to do it..." the NRC should
withdraw it's agreement state status.
3. I agree.
Not so , Bill.
The final responsibility always rests with the Agreement State. Under an
agreement, the NRC relinquishes its authority to regulate by-product
material. The Agreement State enforces state, not federal, law through its
radioactive materials regulations. Although the NRC has claimed
otherwise, the Atomic Energy Act has no provision for NRC to assure that a
state does anything once an agreement has been signed (with the sole
exception of regulating uranium mill tailings site in accordance with
As has been said elsewhere, Texas does in fact have the one of the best
regulation programs for industrial radiography in the country (which means
probably one of the best on the planet). They do a better job than NRC.
By all means we should look at the licensee's compliance history and the
state's responses to previous incidents, but one should not expect to find
any systemic problems with Texas' regulatory program.
The reason we see the same radiography incidents repeating themselves over
and over again is to be found in the nature of the industry itself.
Radiographers are generally not unionized and not paid all that much. Turn
over can be fairly high. Many of the trainees speak English as a second
language. The work sites where radiography is performed, like all heavy
construction sites, tend to be dirty, uncomfortable, and dangerous places
- even without the radiography source! The radiographers frequently work
under considerable time pressure because the construction work has to stop
while they set up their shots and make an exposure. Given all the factors
working against safety it is remarkable how few of these over-exposure
Clayton J. Bradt
NYS Dept. of Health
Biggs Laboratory, Room D486A
Empire State Plaza
Albany, NY 12201-0509
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