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radiography again (and again and again)



Please see the incident description below, which is copied from the NRC

Daily Event Report for March 16, 2004.



I won't pass judgment on the dropped badge scenario.  That's a

relatively minor concern.



The real problem is this.  Assuming the radiographer did not receive any

dose in December, 2003, he would still have exceeded 4 rem for the

year.  Is this a routine practice?  (It seems to be for this company,

since its  corrective action would not bring in additional controls

until a radiographer reaches 4 rem for the year.) If so, I'd like to

know what aspects of a well-run radiography program would require this?

It seems that if the jobs are planned and implemented properly, doses

should be low.  When my employer brings in radiographers, the doses are

very low.



Consider the provisions of 10 CFR 20.1101, including:  "(b) The licensee

shall use, to the extent practical, procedures and engineering controls

based upon sound radiation protection principles to achieve occupational

doses ... that are as low as is reasonably achievable (ALARA)."  I

assume that LA has similar provisions in its regulations.



When are the regulators planning to enforce this for radiographers?



The opinions expressed are strictly mine.

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

Curies forever.



Bill Lipton

liptonw@dteenergy.com





General Information or Other Event Number: 40584

Rep Org: LOUISIANA RADIATION PROTECTION DIV

Licensee: XRI TESTING

Region: 4

City: LAFAYETTE State: LA

County:

License #: LA-2918-L01

Agreement: Y

Docket:

NRC Notified By: SCOTT BLACKWELL

HQ OPS Officer: STEVE SANDIN  Notification Date: 03/11/2004

Notification Time: 14:41 [ET]

Event Date: 01/30/2004

Event Time: [CST]

Last Update Date: 03/11/2004

Emergency Class: NON EMERGENCY

10 CFR Section:

AGREEMENT STATE

 Person (Organization):

TROY PRUETT (R4)

TOM ESSIG (NMSS)





Event Text



RADIOGRAPHER MAY HAVE EXCEEDED ANNUAL EXPOSURE LIMIT



"XRI reported that [a radiographer] received an annual exposure of 6.120

R for the year of 2003. [The Radiographer] had a dose of 4.016 R prior

to December of 2003. [The Radiographer] received a dose of 2.104 R for

December 2003. Once the badge results were discussed with [the

Radiographer] in January of 2004, he stated that his badge had dropped

near a source. [The Radiographer] did not feel that it needed to be

reported at that time because of the distance from the source. According

to the facilities files [the Radiographer] received 0.315 R for the

month of December 2003. As a result of this incident there have been

some additional steps taken to prevent reoccurrence. All radiographers

have been retrained. Also if a radiographer receives a dose of 4.0 R by

December, that radiographer will not be allowed to perform radiograph

operations until the next calendar year. If that limit is reached prior

to that date, the radiographer may be granted specified permission to

work on monitored low production jobs."



LA Report ID No.: LA040003





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