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

Kenneth Marshall kenneth.marshall at carestream.com
Wed Apr 4 06:00:44 CDT 2012

I agree with Clayton's comments, 

I've witnessed numerous industrial radiography operations and the tight 
time constraints and working environment is a challenge.  Numerous 
accidents I reviewed for ASNT indicates most are operator error and 
failure to adhere to an administrative control (wearing alarming 
dosimeters, etc.)  These guys will feel the pressure if they forget to 
bring their alarming dosimeter from the truck as they carry lots of other 

 I would offer that such an environment does seem to beg for an additional 
engineering control.   e.g alarming or other  indicator on the camera or 
along the guide  tube to indicate source position or proper retraction.  I 
think technology solutions could be made available now that were not 
available years ago for reasonable costs.


From:   Clayton J Bradt <CJB01 at health.state.ny.us>
To:     doctorbill34 at gmail.com
Cc:     radsafe at health.phys.iit.edu
Date:   04/02/2012 02:11 PM
Subject:        [ RadSafe ] Agreement States v. NRC   (was: radiography 
Sent by:        radsafe-bounces at health.phys.iit.edu

Bill Lipton wrote:
In response:

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 
federal standards). 

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 
incidents occur. 

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

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