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RE: radiography - deja vu all over again





With the exception of a few pointed comments (unfortunately), there has been

some very good dialogue on the topic. As with many areas, one argues over

the proper balance. 



As I see it, the problem is not that, for example, that someone received 10

rads, increasing their chances by ~0.1% of getting a terminal cancer. This

whole field is so heavily regulated compared with other fields (are there

regulators there when your spouse uses a chemical cleaner?) that most

stupidities and mistakes at least get reported for all to see. This is good,

at some level (ours), but it tends to hurt the industry as a whole -

especially when it provides fodder for the anti-nuke establishment.



Also, we so often forget that people can do dumb things at any time,

irrespective. Being proactive at the regulatory front is no substitute for

being competent, methodical and careful when dealing with radioactive

materials. I think that promoting the proper attitude, and ensuring that

those who are so-licensed must adopt it as well, seems key here. Note that,

in many businesses, it is typically a company policy that two qualified

people be present during hazardous maneuvers. The same might apply when

dealing with hazardous sources. There is typically a lack of common sense

that permeates most such issues. Two heads do tend to be better than one

when coupled with the right personality type. The attitude must be promoted

by both the regulators and the industry as a whole.



Grant



-----Original Message-----

From: William V Lipton [mailto:liptonw@DTEENERGY.COM]

Sent: Wednesday, May 21, 2003 2:14 PM

To: Grimm, Lawrence

Cc: radsafe@list.vanderbilt.edu

Subject: 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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