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

Philip Egidi Egidi.Philip at epamail.epa.gov
Tue Apr 3 08:03:12 CDT 2012

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 culture.

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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