Re: deja vu all over again- another radiography overexposure]

[William V Lipton <liptonw@DTEENERGY.COM>]

With John's permission, I'd like to post his private message and

respond.



I'm glad you asked.  The radiography situation has long concerned me. 

Although the situation has improved - there used to be approximately 1

incident per month - industrial radiography is still one of the largest

sources of overexposures, and does not seem to be improving any more.  



What can the NRC do about it?  I don't have any quick answers, but here

are some suggestions:



1.  Look at the Agreement State programs.  The industrial radiography

incidents seem to be clustered in certain states, while other states

seem to avoid them.  There's probably a wealth of information regarding

what works and what doesn't, if someone looked at the elements of

successful programs versus those that continue to have incidents.  



2.  Although 10 CFR 34 provides the basis for a good industrial

radiography program, the implementation is sometimes weak.  I can't go

into details of what I've observed, but here are some questions that

inspectors should be asking:



a.  training - What is the quality of the training?  Does it cover

licensee and industry lessons learned?  How much time is devoted to

initial and requal  training?  EPA regs specify required training hours,

although this doesn't guarantee high quality training.  Perhaps the NRC

should require training program accreditation.  



b.  exams - Is the examination process valid?  Is the exam known in

advance?  Does the training essentially coach the students to pass the

exam?  How are failures remediated?  Does the student keep taking the

same exam until he passes?  Does the inspector personally check on the

knowledge of a sample of radiographers.  Are the required field

observations performed and docuemted?



c.  procedures - Do the radiographers have copies of the applicable

procedures?  Are they familiar with them?  Does the organization culture

emphasize compliance?  (A few questions of the radiographers will answer

this very quickly.)  Do the radiographers understand why it's important

to properly use dosimetry and survey instruments?  



d.  corrective actions - Perhaps the regulations should be more specific

on this important element of a successful program.  Does the licensee

have a zero tolerance attitude for procedural violations or are they

ignored or limited to a wrist slap?  Does the licensee investigate the

root causes of incidents or do they limit the investigation to finding a

fall guy?



e.  enforcement - Do enforcement actions provide an incentive for a zero

tolerance approach to violations, or are they considered a "cost of

doing business?"  



I could probably think of a lot more, but I'm sure you get the point.  I

can't help but get the feeling that this is not a high priority for the

NRC.  However, don't forget that there are probably a lot more

overexposures here than for other licensees.



The opinions expressed are strictly mine.

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

Curies forever.



Bill Lipton

liptonw@dteenergy.com







>

> john grant wrote:

>

> > William V Lipton wrote:

> >

> > > Please see the NRC, PNO, pasted below.  Note that the preliminary dose

> > > estimate is 70 rems DDE.  It's an estimate, since the radiographer was

> > > not wearing his assigned primary dosimeter, and his pocket dosimeter was

> > > off scale.  The radiographer did not use a survey instrument when

> > > reposititioning his equipment and did not realize that the source had

> > > not been completely retracted.  Also, he did not hear his alarming

> > > ratemeter.

> > >

> > > This problem seems to reoccur all too frequently.  Will it take a

> > > fatality before the NRC takes effective corrective actions?

> >

> > What can the NRC do about people that do not use their equipment properly?

> >

> > John Grant

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