[ RadSafe ] Agreement States v. NRC (was: radiography incident)

Clayton J Bradt CJB01 at health.state.ny.us
Tue Apr 3 09:07:41 CDT 2012


Good analysis.

The main difficulties I see in engineering safer units are: 1) the work 
environments in which the industrial units must perform are extremely 
dirty and subject the units to high impact, vibrations, and extremes of 
temperature, etc.  We can all image how long a medical HDR unit would 
survive out in the field. 2) the units (cameras and digital imaging 
units)must be light enough to be portable by one person several 10s of 
meters over rough terrain. 

Now these difficulties could be overcome, but at great expense.  Also, the 
resulting equipment would likely be much more complicated to operate and 
to troubleshoot in the field, requiring a more highly trained and 
motivated radiographer.  In short, the current business model will not 
support ($$$$$$$$$$$$$$$$$$$$$$$$) the changes required to produce safer 

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


Philip Egidi <Egidi.Philip at epamail.epa.gov> 
04/03/2012 09:03 AM

"The International Radiation Protection \(Health Physics\) Mailing List" 
<radsafe at health.phys.iit.edu>
CJB01 at health.state.ny.us, radsafe-bounces at health.phys.iit.edu
Re: [ RadSafe ] Agreement States v. NRC (was: radiography       incident)

OK, as a former materials inspector who has survived two IMPEP reviews, I 
offer the following:

1) the program can be found compatible by the auditors who review the 
regulations and records: check.
2) field audits of inspections by IMPEP staff can show the inspectors are 
trained and doing their job (or not): check.
3) review of records during inspections can show patterns of certain 
individuals getting higher doses than other workers and can be flagged for 
follow up (which RSOs do all the time): check.

That DOES NOTHING to change the behavior of the companies and workers in 
the field once the inspections are over. It is the culture of the 
industry. The best way to get these companies to change their behavior is 
through heavy fines. If the fines are big enough, and not negotiated away 
for promises of better future performance, only then will the companies 
enforce a stricter safety culture. It is more profitable now to just pay 
the small fines and get the slap on the hand than it is to change the 

Unannounced inspections during off hours is a good way go catch these 
folks behaving badly. But if you don't know where they are working, you 
can't inspect them - so you almost always tip your hand when you call and 
ask where the crews are. This also happens under reciprocity inspections 
(when they come in from another state). Unfortunately, that means extra 
staff hours and time that the States just don't have. The recession hits 
all programs, including inspections. State program staff are generally 
underpaid and overworked, and some States have license writers also doing 
inspections as well as incident response. It takes time to become a good 
inspector, you just can't hand someone a checklist and cut them loose. Add 
to that the radiography often happens far from the State capital where the 
inspectors are based, and you get significant travel costs on top of 
everything else.

However, there is also room for improvement on the hardware side. For 
example, I also inspected high dose rate afterloaders for brachytherapy at 
hospitals. Those devices also use I-192, although much smaller sources 
(~10 Ci). Since they involve sending a high-activity source into a human 
being, those gizmos have hardware and software mechanisms to prevent 
unintended exposure. The HDR units control when, how long, and how far out 
the source is extended into the catheter; a similar device could be 
designed for the guide tubes that would also allow the operator to stand 
further back as opposed to the hand cranks that are only about 35 feet 
long. This too would reduce dose on a daily basis to the radiographer. If 
a smaller, field hardened system could be devised for radiography cameras, 
this would result in lower dose to the workers. Couple that with digital 
radiography, and doses in this sector can be reduced tremendously. It just 
takes a lot of time and money to get put in place.

For disconnects, such as what sparked this thread, it still appears to me 
that something was not communicated in the post - the person who retrieved 
the source may have not followed his training and got himself a lot more 
dose than what he could have gotten. Putting a guide tube around your neck 
with a source in it to climb down a ladder is just plain stupid. If he was 
trained in retrieval, then he should have known better. We already 
discussed the fact that he didn't listen to his alarming ratemeter.

I agree with the previous poster about the lack of education and language 
barriers in the field. Very high turnover, and the companies steal workers 
from each other on a routine basis.


Philip Egidi
Environmental Scientist
U.S. Environmental Protection Agency
Office of Radiation and Indoor Air
Radiation Protection Division
Center for Waste Management and Regulations
Washington, DC

phone: 202-343-9186
email: egidi.philip at epa.gov
cell: 970-209-2885

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