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Re: radiography - deja vu all over again
The message in both of your posts seems to be that there's nothing more that the regulators can do, and that I'm "reactionary, ignorant, and irresponsible" for suggesting otherwise.
I think I've said all of this, before, but recognizing that my communciation abilities may be almost as bad as yours, I'll try again.
I think that 10 CFR 34 is a good regulation. The problem is that enforcement seems to be reactive rather than proactive, i.e. they slam anyone who's unfortunate enough to screw up (and get caught), but do not seem to identify and address the root causes of the problem.
Although the proximate cause for most of these incidents is an individual failure, this is probably the tip of the iceberg; just a symptom of organizations for which safety is a low priority. Enforcement should be concentrated at the program level, to catch violations before they lead to full scale incidents. Here are some thoughts:
1. It seems that some Agreement State programs are better than others. The NRC should look at this, and benchmark the best programs.
2. training - Another Radsafer described a situation where an individual who failed the exam was coached thru the same exam to pass. I've seen a similar situation. The NRC should look at exam content and validity. It may be necessary to require radiographers to pass a NRC (or Agreement State)-administered exam.
3. procedures - The NRC should review licensee procedures to assure that they are current and valid, that there is a program to incorporate radioagrapher comments, and that all radiographers have current copies of the procedures they need.
4. safety culture - I admit this is a tough one. You can't dictate attitude. I would suggest that all licensees have an ombudsman program, where all employees have confidential access to an individual who can follow up on safety concerns. One of the problems seems to be the time pressure, which is really a reflection of cost pressure. Effective enforcement would take away the cost advantage of cutting corners.
When I ask, "When will the NRC take radiography seriously?" I'm really asking the NRC to devote the resources necessary to fix this problem.
If this is your definition of "reactionary, ignorant, and irresponsible," then I'm guilty as charged.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
"Grimm, Lawrence" wrote:
> Dropping the sarcasm of my previous post, here's a serious reply.
>
> The NRC recognized the problem of industrial radiographers (IRs) at least 30 years ago. IRs as a group had more overexposures than any other group of radioactive material users, and probably still do. The NRC implemented all sorts of regulations specifically aimed at the IRs. The NRC implemented IR training courses for NRC and agreement state inspectors - which I attended in 1979. It is a very good course. The NRC created an excellent book/guide for IRs. I would argue that the regulatory bodies are most cognizant of the problem and work hard to decrease the problem.
>
> When one studies the problem, it is evident that almost all the overexposures are related to an individual failing to follow the rules. There are a lot of factors for this happening. IRs work in horrendous environments. They are always under pressure to get the work done and often have to work when no one else is around, i.e. after midnight. They spend days and weeks on the road, sleeping in fleabag motels. They tend to be a rough and tumble lot, and there are not too many Ph.D.'s in the crowd. As an indication of how rough they can be, I know a State inspector who was shot at by an IR.
>
> I beg the question of, "What more can the regulators do?" I would say, not much. How do you stop an individual from doing something stupid? Short of implementing my sarcastic recommendations for rules, I believe the regulators have done a good job of trying to solve the problem.
>
> What troubled me about the Radsafer's post was the reactionary, "call-to-arms" indicating the NRC was not doing enough. This type of reactionary, ignorant (of all facets of the problem) behavior is irresponsible for a HP. It is typically the irresponsible behavior of a politician or an anti-nuke person, but should not be the behavior of a HP.
>
> Larry Grimm
>
> If this email is not RSD business, the opinions are mine, not my employer's.
>
>
>
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