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

William Lipton doctorbill34 at gmail.com
Tue Apr 3 14:56:53 CDT 2012

I agree with your statement that heavier fines are needed to deter
violations.  One egregious example involved the NRC.  I forget the date,
but it involved a physician in PA who had a satellite office in NJ.  His
license required him to visit the NJ office at a certain frequency.  He not
only failed to do this, but falsified records to make it look as if he had
made the visits, i.e. a willful violation.  The end result was a token fine
which I calculated was less than the cost of compliance would have been.

Bill Lipton
It's not about dose, it's about trust.

On Tue, Apr 3, 2012 at 9:03 AM, Philip Egidi
<Egidi.Philip at epamail.epa.gov>wrote:

> 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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