ML19289C553
| ML19289C553 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1978 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| References | |
| NUREG-0495, NUREG-495, NUDOCS 7901170325 | |
| Download: ML19289C553 (68) | |
Text
s.
- PUBLIC MEETING ON: RADIATION SAFETY FOR INDUSTRIAL!RADIOGRAPHERS:
(
Remarks, Questions and
- Answers at Five NRC Regional Meetings-
,e I
790117652f Office of Inspection'and Enforcement
- U.S. Nuclear Regulatory l Commission :
NUREG-0495 PUBLIC MEETING ON RADIATION SAFETY FOR INDUSTRIAL RADIOGRAPHERS Remarks, Questions and Answers at Five NRC Regional Meetings Manuscript Completed: November 1978 Date Published: December 1978 Office of Inspection and Enforcement Division of Fuel Facilities and Materials Safety inspection U.S. Nuclear Regulatory Commission Washington, D.C. 20555
TABLE OF CONTENTS Page Foreword.
ii Keynote Address..
I NRC Inspection Program and Summary of 5
Inspection Findings.
Overexposures-Case Histories.
- S SUMMATION.
41 Questions and Answers.
42 FIGURES 1.
Exposures Exceeding Limits - Byproduct Materials Licensees.
20 2.
Routinely Identified Item of Noncompliance...
23 TABLE 1.
Noncompliance Statistics-Radiography Licensees......
22 APPENDICE Appendix A - List of Participating Individuals and Their NRC Office Affiliation.
65 i
FOREWORD Over the past several years the number of radiation overexposures experienced in the radiography industry has been higher than for any other single group of NRC licensees.
To inform radiography licensees of NRC's concern for these recurring overexposure incidents, NRC staff representatives met with licensees in a series of five regional meetings.
At these meetings the staff presented prepared remarks and answered questions on NRC regulations and operations.
The main purposes of the meetings were to express NRC's concern for the high incidence of overexposures, and to open a line of communication between the NRC and radiography licensees in an effort to achieve the common goal of improved radiation safety.
The remarks presented by the staff and subjects discussed at these meetings included:
the purpose, scope, findings and goals of the NRC inspection program; ways and means of incorporating safety into radiography operations; and case histories of overexposure incidents, with highlights of the causes and possible preventions.
At each of the regional meetings the staff received a request for a copy of the prepared remarks and a consolidation of the questions and answers that were discussed.
This document includes that information, and a copy is being provided to each organization or firm attending the regional meetings.
Requests for other copies should be made in accordance with the directions printed inside the front cover of this document.
ii
KEYNOTE ADDRESS The subject of our meeting today is " Radiation Safety for Industrial Radicgraphers." We are not here to discuss new radiographic techniques or to sell new radiographic equipment.
We are here to promote radiation safety in radiographic operations.
Safety is the mission of the Nuclear Regulatory Commission.
This is the principal reason for the existence of NRC--the reason NRC was established as a separate and independent regulatory agency.
Our mission encompasses protection of the public health and safety, protection of the environment, and safeguarding of nuclear materials.
This mission does not make NRC the natural adversary of the industry.
Rather, I am sure the NRC and the industry seek the same ultimate goal--0PERATION WITH SAFETY.
While pursuing the same goal, disagreements sometimes result as to just what is necessary for safety.
We are hopeful that, through discussions such as those we will hear today, we can all reach a better understanding of how to achieve our mutual goal of radiation safety in the area of industrial radiography.
To achieve its mission, the NRC is organized to accomplish three principal functions.
First, there is the standards setting fenction.
This is the function of developing and expressing the generic requirements to be placed on industry in order for the NRC to discharge its responsibility.
These requirements are normally expressed in the NRC's rules and reaulations, a.'d are published as Title 10, Code of Federal Regulations.
Second, there is C.9 licensing function.
This is the function of evaluating applications for specific licenses and issuing such a license when it is determined that there is reasonable assurance that activities proposed will be carried out safely and in compliance with NRC requirements.
Third, there is the inspection and enforcement function.
This is the function carried out by the Office of Inspection and Enforcement, the office of which we in this region are a part.
I would like now to discuss further the role of the Office of Inspection and Enforcement in what might be called the IE missior,.
There are three principal functions in the IE mission which are support-ive of the overall NRC mission of public protection.
These are (1) inspect and investigate, (2) evaluate and inform, and (3) enforce.
In carrying out its function to inspect and investigate, IE conducts inspections of individuals and organizations subject to NRC jurisdiction in order to:
Ascertain the status of compliance with NRC requirements, including rules, regulations, elders and license provisions, Identify conditions within areas inspected that may adversely affect public health and safety, and Provide a basis for recommending issuance or denial of an authoriza-tion, permit or license.
In addition to conducting inspections, IE investigates incidents, acci-dents, allegations and any other unusual circumstances involving matters which may be subject to NRC jurisdiction.
The purpose of our investiga-tion is to ascertain the facts about a particular situation and to take or recommend appropriate action.
The function to evaluate and inform is also an important element of the IE mission.
In performing this function, notifications and reports concerning incidents and accidents that present a potential or actual threat to public health and safety are promptly assessed to:
Assure adequacy of the overall response to the incident or accident, Provide for prompt ongoing response by appropriate NRC staff, and Develop information and provide notifications as appropriate.
On a less immediate time frame, IE evaluates the results of inspections, investigations, inquiries, enforcement actions, and reports by licensees and other organizations and individuals to:
Determina the adequacy of licensee performance,
- Understand activities and events which transpired and provide a basis to take or recommend appropriate action, Verify the effectiveness of the IE program for inspection, investiga-tion and enforcement, and Identify areas for consideration for change in the regulatory process.
Providing others with appropriate information is a continuing function of IE.
IE informs the Commission, other NRC staff offices, other govern-mental agencies, lic asees, and the public of notices or reports of occurrences received by IE and of actions taken by IE.
In addition, -
special communications are sent to licensees so that precautionary or corrective action can be taken by licensees.
The third IE function is to enforce.
In carrying out this function, IE takes the enforcement action necessary to assure corrective action is taken and compliance with NRC requirements is maintained.
I would like to return now to the second IE function, evaluate and inform, an aspect of which is the basis for our meeting here today.
The NRC Licensing and Inspection Program are based on the premise that licensee management is responsible for assuring that licensed activities are conducted safely and in compliance with NRC requirements.
In conducting our program of inspection, certain of our activities are directed toward verifyirig that the licensee has established management control systems to carry out his responsibilities.
We feel that certain information which is available to us, as a result of these inspection activites, we a be helpful to you in establishing and conducting your licensed prog It seems appropriate, therefore, that some mechanism be developed an exchange of information between the NRC and its licensees, in addition to exchanges that are experienced during particular inspection interfaces.
Such an exchange of information, which is in support of the IE mission, is the purpose of this seminar.
While conducting meetings such as this, a new initiative on our part, it is not accidental that the first regional meetings with NRC licensees would be planned for industrial radiography licensees.
No other single group of NRC licensees has recorded a comparable number of personnel overexposures.
Because of our concerns regarding this record, we have given priority to meeting first with radiography licensees.
It is hoped that in this meetir.g wc can jointly explore those measures which could be taken to prevent unnecessary exposures.
Now let me expor.d on the purpose of this meeting and outline some of the areas that will be covered.
First, the meeting will be a forum in which representatives of NRC can communicate their views on how to achieve radiation safety and can respond to your questions in this regard.
In these sessions, we will explain how we conduct an inspection and give our views as to the purpose and goals of the inspection program.
As I have mentioned, one basic fact underly-ing our inspection program is + hat the licensee is responsible for assur-ing that his activities are conacted safely and in compliance with the regulations; the inspection program of the NRC does not replace licensee management controls.
Our program is essentially a " spot check" or sampl-ing effort-planned and managed--to verify that the licensee is doing his job in discharging his responsibilities.
Consequently, you will learn that our inspectors look particularly at those methods by which management assures compliance with the requirements and these are con-sidered as M~ g equally important as compliance itself.
Second, our presentations today will include discussions of certain case histories of past overexposures and the NRC's evaluation of the items of noncompliance with NRC regulations which caused the overexposures to This review of past errors should be valuable to you either as occur.
radiographers or as managers as a basis for assessing possible weak spots in your program.
You will note that in every case discussed, we believe the overexposure would have been prevented had the licensee's procedures and the NRC's regulations been followed.
Third, during our presentations, during the panel discussions, and during informal discussions during the coffee breaks, we hope you will learn who we are and that we will have an opportunity to learn who you are.
We welcome this chance to open lines of communication between the NRC staff and licensees.
Our staff is more than willing to answer your questions or hear your views at any time.
We hope that lines of communication will be established that will permit a continuing exchange of information well past the conclusion of today's meeting.
The NRC expects several benefits to follow from this exchange of informa-tion.
Understanding the NRC's inspection and enforcement procedures should enable you to review your own compliance program to determine how well it meets the NRC objectives.
An improved effectiveness in your own management control system should result from such a review.
We are confident that a strong management commitment to radiation safety can prevent unnecessary overexposures.
Such a commitment implies much more than lip service to a paper compliance program.
We expect, for example, the working radiographer to know that his management considers performing radiographic operations without an operating survey meter to be of more serious concern, and subject to much stronger discipline, than delaying a re.:ographic exposure until an operating instrument is obtained.
We hope that as government and industry each fulfill their responsibilities, we can achieve our mutual goal and assure the public of the safety of radiographic operations.
We hope the meeting here today will contribute in this regard.
_4_
NRC INSPECTION PROGRAM AND
SUMMARY
OF INSPECTION FINDINGS The NRC is charged with the responsibility of assuring that radioactive materials which are part of the fuel cycle or derived from the fuel cycle are possessed and used in a manner which assures that radiation workers and the general public are protected from the hazards associated with these materials.
The NRC controls th? use of these materials by restricting possession to those persons who request a license to possess and use material and who submit a program for the safe use of these materials.
When the NRC's Radioisotopes Licensing Branch has determined that the submitted program is adequate to control the hazard associated with isotopes requested, a license is issued.
Once a license has been issued, the licensee assumes the responsibility for assuring that all licensed materials are possessed and used in accordance with the regula-tions found in Title 10 of the Code of Federal Regulations and with the conditions of the license.
Included in the conditions of every license is a s+ipulation that the licensee will follow the statements, procedures, and npresentations submitted to and approved by the NRC's Radioisotopes Licensing Branch.
It is the task of the Office of Inspection and Enforcement to assure that NRC licensees fulfill their responsibilities accepted through the licens-ing process.
The Office of Inspection and Enforcement has three (3) functions in the performance of this task.
First, a program of inspections and investigations is conducted by the regional offices of the NRC.
By onsite inspections of the licensee, the NRC is able to verify that the licensee is fulfilling his responsibilities.
Secondly, the office evaluates the findings of the inspection process.
The results of inspections are discussed within the office of IE and passed on to other groups within the NRC, such as licensing and standards, in an effort to improve the effectiveness of our own programs.
Should the findings at one licensed operation appear to have widespread implications for a larger group of licensees, the NRC may issue bulletins or circulars informing its licensees of these findings.
Finally, this office is charged with enforcement.
A licensee, in not complying with NRC rules and regulations, must take corrective actions.
The NRC has various levels of enforcement action and will take whichever enforcement action appears most appropriate in view of the hazard involved and the willingness or ability of the licensee to correct the items of noncompliance found during the inspection process.
It is my purpose in this lecture to describe the NRC's inspection program.
Before going into the details of this program, I wish to make one further point.
The NRC believes its licensing and inspection programs have been effective.
The safety record of NRC licensees in preventing unnecessary exposures of individuals is good.
However, the record is not as good as we believe it could be.
We firmly believe that if all licensed opera-tions were conducted in compliance with the regulations and conditions of NRC licenses, virtually all unnecessary exposure would be avoided.
The NRC inspection program determines compliance with regulatory require-ments.
Thus, it consists of selective examinations of procedures and records, interviews with personnel, measurements made by the inspector, and observations by the inspector.
The criteria for determining if the items examined are in compliance are the regulations in Title 10 of the Code of Federal Regulations, especially Parts 19, 20 and 34, and the statements made in applications and letters supporting the applications for a license.
An important part of the inspection process is to evaluate whether the licensee is aware of these requirements and how well the requirements are understood.
If the requirements are understood and a program for compliance has been instituted, the NRC inspector must evaluate the adequacy of that program and determine whether compliance has been achieved.
A typical inspection will include a walk through the licensees facility.
If operations are in progress, the inspector will observe actual operations.
Otherwise, the inspector may request that a radiographer simulate a radiographic exposure.
During this part of the inspection, the inspector will question workers to determine how well they understand the safety requirements, how well they understand the use of protective devices, and to determine their attitudes and what they perceive management's atti-tudes are toward radiation safety.
Discussions are held with the radiation safety officer to determine the depth of the radiation safety progr e Since the licensee is responsible for compliance, it is extremely important that the radiation safety staff be knowledgeable and have the resources to properly evaluate the hazards associated with possession and use of licensed material.
It is important that the radiction safety officer interact closely with the radiographers in order to evaluate their performance and that he has easy access to management when problems are identified and corrective action is needed.
The inspector will examine records; first, in order to determine that the required elements of the program are being followed; and second, to determine that the results of evaluations indicate compliance with limits specified in the regulations and the licensee's procedures.
The inspector will question the recorded results:
Does the radiation safety officer have a method to assure that numbers recorded are valid? Has he observed the methods used during surveys by radiographers? Have badge results and dosimeter records been compared and evaluated for consistency? 00 examina-tions documenting training cover the essential elements of the radiation safety program?
In other words, by a critical examination of records, and by questioning, the inspector hopes to evaluate the effectiveness of the radiation program.
Inconsistencies between observations and measure-ments made by the inspector and results found in records may seriously decrease the confidence in the safety program as a whole.
The final part of the inspection is a discussion and review of findings with the licensee's management.
Keeping in mind that the purpose of the NRC's inspection progran is to assure compliance, this part of the inspection can be the most productive part of the inspection.
If apparent items of noncompliance have been identified, the inspector will bring these to management's attention and the items can be fully discussed.
The inspector should make clear the requirement on which the item is based and the findings which indicate noncompliance.
In addition, the inspector may, on the basis of professional judgments and observation of other programs, indicate areas in which management may strengthen its own compliance program.
If procedures are available but not followed, the inspector may suggest that management increase the frequency and depth of its internal audit program.
If procedures are inadequate, the inspector may suggest that management obtain the services of an expert in radiation protection practices so that management may correct deficiencies in the program.
In any case, the corrective actions to be taken are to be developed by the licensee, and it is important that management representa-tives fully understand the basis for all apparent items of noncompliance.
The exit interview at the close of the inspection is the most appropriate time to discuss and resolve issues rather than after the enforcement letter and notice of violation have been received.
I now wish to focus on particular items which the inspector reviews during the various part of the inspection.
The licensee's internal inspection program is reviewed in detail.
This part of the program is viewed as being extremely important since it impacts on all other phases of the radiation protection program.
The criteria for compliance is the description of the program included in applications and letters to the NRC's licensing branch.
The inspector also reviews the adequacy of the internal program.
If radiographers and radiographers' assistants do not follow license provisions and NRC regula-tions, there is a strong indication that the internal audit program is ineffective.
The inspector will expect that management would identify problems as a result of the audit program and that corrective action would have been taken.
The training program is another aspect of the overall radiation protec-tion program which impacts on nearly every other part of the program.
Minimum training requirements are set forth in Parts 19 and 34 and specific procedures are required to be submitted with the license appli-cation.
The inspector verifies that the formal instruction and testing are being performed.
In addition, the inspector attempts to determine the effectiveness of the training.
By observation and questioning, the inspector determines if the radiographers or assistants know the require-ments, are aware of the hazards, and know how to use the protective devices provided.
It is not satisfactory to have written tests on record if, in fact, the individuals do not understand the procedures or use of devices.
In this respect, I will mention that it is disturbing when tests for radiographers contain only 25% questions on radiation safety and have a passing score of 80% or lower.
It is suggested that written tests be evaluated beyond a simple passing or failing grade and that additional training be directed in those areas where the radiographer shows a lack of understanding.
It does not seem reasonable to state that a radiographer is adequately trained if he fulfilis the formal require-ments of the program but has demonstrated by his answers that he neither understands nor can he perform an adequate survey to determine his posting requirements.
In other words, compliance is not an 80% or a 100% score on a written test, but rather that management identifies weaknesses and provides the additional training required to assure that the individual can safely perform his duties in compliance with all requirements.
The inspector may thus find that the training program is formally in compli-ance with the requirements of your license but will draw your attention to the inadequacies of the program and its effect on the rest of your compliance program.
Surveys are an extremely important part of a good radiation program, and the licensee's survey program is examined closely during an inspection.
You should be aware that making a survey is far more than making a physical measurement.
As defined in Part 20, a survey is "an evaluation of the radiation hazards incident to the production, use, release, disposal or presence of radioactive materials under a specific sct of conditions.
When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radia-tion or concentrations of radioactive material present." The important word in the definition is " evaluation." Thus, the recognition and assessment of the hazard is the essential purpose of making a survey.
In many cases, a physical measurement is necessary but in all cases the informatson available to the individual must be intelligently evaluated prior to proceeding with operations.
An inspector may observe that a radiographer carries a survey instrument when approaching an exposure device.
This fact does not demonstrate compliance with the survey requirement.
To verify umpliance, the inspector may question the radiographer as to the readings noted, whether such readings were expected, which areas the radiographer measures, and finally as to the radiographer's own evaluation of the hazard involved.
In addition, the inspector will review records to determine that surveys are being performed at the required times and during specific operations.
From the numbers recorded and comments made, the inspector attempts to determine that physical measurements are being evaluated.
Personnel monitoring practices and records are carefully examined.
Employees involved in operations are checked to determine that the required dosimeters including film badge and pocket dosimeter are being worn.
The inspector may ask to read the pocket dosimeter to <utermine that it is working and that is has been recharged at the start of the shift.
Records of pocket dosimeter and film badge data are examined and compared.
The inspector will ask for explanations of results that are unusual or when large discrepancies between records occur.
Dosimetry is a survey of personnel exposure and as such must be evaluated.
Whenever exposures are higher or lower than anticipated, the NRC expects the licensee to evaluate the circumstances.
If an investigation reveals that film badges and/or pocket dosimeters were either not worn during a specified period when exposure did occur or were exposed while not being worn, then the inspector expects that the true dose will have been evaluated and documented.
In those cases where film badges have been lost, the inspector will look for an evaluation of the dose received and for corrective actions to prevent the badge from being lost in the future.
The inspector checks for unreported overexposures and may request an evaluation of skin and extremity exposure if whole body overexposures or near overexposures are found.
If an incident has occurred in which extremity overexposures may have been possible, the inspector will request an evaluation of possible dose to the extremities.
In an application for a license to perform radiographic operations, a licensee is required to submit operating and emergency procedures including as a minimum those subjects covered in paragraph 34.32 of Part 34.
The inspector will determine if these procedures are available to radiographic personnel and are being followed.
The items covered by the procedures are to include:
The handling and use of licensed sealed sources and radiographic exposure devices to be employed such that no person is likely to be exposed to radiation doses in excess of the limits established in Part 20 of this chapter, " Standards for Protection Against Radiation";
Methods and occasions for conducting radiation surveys; Methods for controlling access to radiographic areas; Methods and occasions for locking and securing radicgraphic exposure devices, storage containers and sealed sources; Personnel monitoring and the use of personnel monitnring equipment; Transporting sealed sources to field locations, including packing of radiographic exposure devices and storage containers in the vehicles, posting of vehicles, and control of the sealed sources during transportation; Minimizing exposure of persons in the event of an accident; The procedure for notifying proper persons in the event of an accident; Maintenance of records; and The inspection and maintenance of radiographic exposure devices and storage containers.
The inspector looks beyond the soecific procedures to determine that the facility and operations are the same as described in the application.
Changes made without licensing approval could make procedures inadequate on inappropriate for operations as they actually exist.
If the licensee has provided additional safeguards, the inspector will recommend that these be added to existing procedures and that the new procedures be submitted to the NRC's licensing branch for review and incorporation into the license.
The inspection items discussed to this point have an impact on the whole radiation program.
Part 34 includes several specific requirements that our inspectors review to assure compliance.
Specific requirements of Part 34 include limits on levels of radiation around exposure and storage devices, locking of devices, storage precautions, radiation survey instrument maintenance and calibration, leak testing and handling of sealed sources, quarterly inventories, utilization logs, inspection and maintenance of devices, security requirements for high radiation areas, and posting requirements.
The inspector will verify compliance in each of these areas by a sampling of records and some independent measurements.
The inspector may choose one or more areas for an in-depth rt iew.
An inspection in response to a notification of an incident involving possible overexposure of individuals will have a different emphasis from the routine inspection we have been discussing.
In these cases the inspector will first try to establish the likely doses received by individuals.
This includes a review of dose estimates by the licensee and independent measurements by the inspector.
A reenactment of the incident is usually staged.
Careful note is made of times and distances for various portions of the individual's body with respect to position of the source.
The dose rates at various distances from the source will be measured with instruments such as R-meters and with other devices such as film or TLD dosimeters.
Dosa estimates are calculated for the various portions of the body based upon the data obtained from the reenactment and physical radiation measurements.
Estimates of the exposure of the film badge worn during the incident are made and can be used to compaia the calculated doses with the actual film exposure.
It is often the case that the film badge is not worn in a position which represents the maximum exposure of a part of the body.
Thus, the film badge worn may not show the most significant exposure but it does aid in determining the accuracy of dose estimates made.
Once the range of potential doses is determined, the NRC may recommend action to be taken by the licensee for the benefit of the health of the exposed individual.
If truly high doses were initially believed possible, the NRC recommends immediate medical treatment and/or appropriate treatment.
In those cases where medical treatment is thought necessary, the NRC will obtain a medical consultant to advise the Commission as to whether the individual is receiving the appropriate care.
Once the magnitude and the probable consequences of the exposure are known and the appropriate immediate actions have been taken, an investi-gation is begun into the cases of the exposure.
The cause and the con-sequences of the incident, by nature, most often constitute items of noncompliance with the regulations.
This office has two other functions to perform once the inspection or investigation has been completed.
The findings must be evaluated and categorized and enforcement action taken, if appropriate.
The Commission and representatives of the nuclear industry have recog-nized that the significance of items of noncompliance with NRC requirements varies in the potential for affecting the health and safety of the public.
The Commission considers that it is desirable to include in Notices of Violation an indication of the significance of each item of noncompliance cited.
As a means of categorizing the items of noncompliance into an order of importance which will express their relative significance, the Commission has established three categories of items of noncompliance.
The most significant items are categorized as Violations.
A violation is an item of noncompliance which has caused, contributed to, or aggravated an incident or occurrence in which the threat to the health, safety or interest of the public is acute; or an item of noncompliance which has a substantial potential for causing, contributing to, or aggravating such an incident or occurrence.
Several examples of violations are:
Exposure of an individual in excess of the radiation dose specified in 10 CFR 20.403(b), or exposure of a group of individuals resultfig in each individual receiving a radiation dose which exceeds the limits of 10 CFR 20.101, and a total dose for the group exceeding 25 man-rems.
Radiation levels in unrestricted areas which exceed 50 times the regulatory limits.
In terms of the limits specified in 10 CFR 20.105(b), this means levels in an unrestricted area such that an individual continuously present for one hour could receive a dose in excess of 100 mrem, or such that an individual continously present for seven consecutive days could receive a dose in excess of 5 rems.
Note that since access to an unrestricted area is not controlled for radiation protection purposes, there is always the potential chat individuals are present.
Release of radioactive materials in amounts which exceed specified limits, or concentrations of radioactive maturials in effluents which exceed 50 times the regulatory limits.
Radiation or coatamination levels in excess of limits on packages or loss of confinement of radioactive materials in packages offered for shipment on a common carrier.
A breakdown in management or procedural controls as evidenced by items of noncompliance in several areas of the license requirements.
Other similar items of noncompliance having actual or potential consequences of the same magnitude.
Failure to report the items as required constitutes a violation of the same importance level.
The second category of items of noncompliance is called infractions.
An infraction is an item of noncompliance in which there is a threat to health, safety or the interest of the public but in which the threat is limited and not as significant as those in the violation category.
Infractions also include those items of noncompliance which resulted in a reduction of preventive capability below requirements but redundant con-trols precluded an item of noncompliance of the violation category, or which caused, contributed or aggravated an incident of the infraction category, or which has a substantial potential for causing, contributing to, or aggravating such an incident or occurrence.
Examples of infractions are:
Exposure of an individual or groups of individuals to radiation in excess of permissible limits but less than the values in 10 CFR 20.403.
Release of radioactive n.aterials in concentrations or rates which exceed permissible limits but in amounts less than permissible limits.
Failing to perform required surveys.
Failing to provide adequate training.
Failing to perform required inspection and maintenance.
railing to provide required personnel monitoring.
Gther simil. ' items of noncompliance having actual or potential corisequences of the same magnitude.
Failure to report the above items, if required, constitutes an item of noncompliance of the same category.
The third category of items of noncompliance is called deficiencies.
A deficiency is an item of noncompliance in which the threat to the health, safety or interest of the public or the common defense and security is remote, and in which no undue expenditure of time or resources to implement corrective action is required; deficiencies include items such as failure to maintain records and posting or labeling requirements.
Failure to report deficiencies, if required, constitutes an item of noncompliance of the same category.
Once the inspection findings have been evaluated, NRC management, on the basis of the inspector's evaluation and consideration of the type and number of items of noncompliance, determines the appropriate level of enforcement action.
The enforcement program emphasizes corrective action.
where necessary, to assure that regulated activities meet applicable requirements and are conducted with due regard for public health and safety, common defense and security, and protection of the environment.
Corrective action is required for each identified item of noncompliance.
The formal actions available to the Commission in the exercise of its enforcement responsibilities are of four basic types:
NRC Form 591, Notices of Violation, Civil Penalties, and Orders.
NRC-591 Form Following a routine inspection where no items of noncompliance other than those categorized as deficiencies are identified, the enforcement action may be limited to the issuance of NRC Form 591 by the inspector to a representative of the licensee's management.
If deficiencies were identified, the representative of the licensee must sign the Form 591 indicating management's commitment to correct all identified deficiencies within 30 days.
Written Notices of Violation Notices of Violation are written notices to licensees, citing the apparent instances of failure to comply with regulatory requirements which have been classified violations, infractions and deficiencies.
The same letter enclosing a Notice of Violation may also enclose a notifi-cation of apparent deviations from licensee commitments and the provisions of appropriate codes, standards or guides.
Civil Monetary Penalties The Commission may levy civil monetary penalties against licensees for violations, infractions or deficiencies with respect to requirements in licensing provisions of the Atomic Energy Act, as amended, or any rule, regulation, order or license issued thereunder.
The Commission is required to issue a " notice of violation" to the person charged before instituting proceedings to impose a civil penalty.
Orders to Cee.se and Desist, and Orders for Suspension, Modification or Revocation of a License The NRC has authority to issue orders to cease and desist, and orders to suspend, modify, or revoke licenses.
Such orders are ordinarily preceded by certain procedural requirements, including a written " notice of violation" to the licensee providing him with an opportunity to respond as to the corrective measures being taken.
In the event the licensee fails to respond to the notice or to demonstrate that satisfactory corrective action is being taken, an order to show cause may be issued requiring the licensee to show why the particular order (either of revocation, modification or suspension) should not be made effective.
In some instances where the health, safety, or interest of employees or the public so requires or deliberate noncompliance with the Commission's regulations is involved, the notice provisions may be dispensed with and the particular order may be made effective immediately pending further order.
In addition to proceeding by way of order, the Commission may also request the Attorney General to obtain an injunction or other court order to enjoin licensees from violating the Act or any regulation or order issued thereunder.
The selection of the appropriate enforcement action is a carefully considered procedure.
Criteria have been established to assure that strong enforcement actions are uniformly applied.
Criteria for NOTICE OF VIOLATION 10 CFR requires that before any formal enforcement action is taken for alleged noncompliance, the NRC will serve on the licensee a written
" notice of violation" except when the Director of Regulation finds that the public health, safety or interest so requires, or that noncompliance is deliberate, the " notice of violation" may be omitted and an order to show cause issued.
Generally, a " notice of violation" will be considered sufficient enforce-ment action in those cases where:
Items of noncompliance are readily correctable, or Items of noncompliance are not repetitive or numerous, and do not constitute an immediate or serious threat to the health and safety of the licensee's employees or the public, to the environment, or to the common defense and security, and There is no indication that appropriate corrective action will not be taken.
In addition, in most cases where stronger enforcement action is being considered, the NRC will arrange a meeting to allow the licensee's management to describe corrective actions planned or taken.
Criteria for CIVIL MONETARY PENALTIES The Commission may levy civil monetary penalties on licensees who do not comply with the licensing provisions of the Act or any rule, regulation, order, or license issued.
Generally, the type of cases that are appropriate for imposing civil penalties are those involving significant items of noncompliance and which represent a threat (but not necessarily an immediate threat) to the health, safety or interest of the public, or to the common defense or security, or the environment.
As a matter of judgment, civil penalties may be used in lieu of license suspension when there is no immediate threat to the health and safety, and license suspension would deprive the licensee and his employees of their means of livelihood, or the public of essential service.
Civil penalties may be the appropriate enforcement action in cases or situations which meet one or more of the following criteria:
Those cases of noncompliance with the same basic requirements that were brought to the attention of the licensee in a " notice of violation" following a previous inspection; Those cases of noncompliance in which the licensee fails to carry out in a timely manner the corrective action the licensee stated would be taken in response to a previous written notice; Those cases involving the deliberate failure of a person to comply with regulatory requirements; Those cases involving items of noncompliance in which (1) the licensee's history is one of chronic noncompliance, or (2) due to the nature and number of itcms of noncompliance, it is apparent that management, having been af.orded an opportunity to correct previous items of noncompliance, i, not conducting its licensed activities in conformance with regulatory requirements; Those cases where (1) an order for immediate, but temporary, sus-pension or to " cease and desist" is issued to remove an immediate threat to the health or safety of the licensee's employees or the public, to the environment or to the common defense and security, and (2) punitive action is deemed necessary to assu:e future compliance; Those cases where an item of noncompliance resulted in or contributed to the cause or the seriousness of an accident or an incident; Those cases involving items of noncompliance in the Violation category; thus, an overexposure in excess of the limits stated in 10 CFR 20.403(b) is automatically considered for Civil Penalties; Those cases where the nature and number of items of noncompliance with the regulatory requirements identified during an inspection or an investigation demonstrate that management is not conducting its licensed activities with adequate concern for the health, safety or interest of its employees or the public or the common defense and security; Those cases where licensees knowingly use materials which are not authorized by the license or utilize authorized materials for uses which are act authorized; or Those cases where significant matters were not reported to the Commission in a timely manner as required by the regulatory requirements.
Civil penalties may be assessed for other cases having comparable types of items of noncompliance and situations for which the Commission deems civil penalties to be appropriate and necessary.
The amount of civil penalty in any given case is determined by several factors including'these:
Potential or actual consequences associated with the item of noncompliance.
This includes consideration of the categories of noncompliance.
Type of licensee.
This includes the purpose for which licensed and the quantity, form and kind of radioactive material authorized.
It also considers the size of the organization including number of employees.
The 11can,ee's recent enforcement history, if applicable.
This includes the nature and numoer of items of noncompliance, the frequency of noncompliance, whether items of noncompliance were repetitive of the same or similar requirements, promptness of corrective action, and the licensee's management of its program for assuring compliance with regulatory requirements.
Criteria FOR ORDERS The NRC has authority to issue orders to " cease and desist" or to suspend, modify, or revoke licenses.
The Commission is empowered to enforce these orders and obtain any other appropriate relief by injunction from Federal district courts, if necessary.
Cases involving an immediate threat to the c blic health and safety, or the common defense and security, require immediate steps to remove the threat and are handled by this type of action.
Persons who deliberately violate, attempt to violate, or conspire to violate the Commission's regulations and orders, are, upon conviction of the violations, subject to a fine up to $5,000 and imprisonment for not more than two years.
In t'.e event the licensee f ails to respond to a " notice of violation" or to demonstrate that satisfactory corrective action is being taken, an order to show cause may be issued requiring the licensee to show why the particular order (either of revocation, modification or suspension) should not be made effective.
In those instances where the health, safety or interest of employees or the public, or the common defense and security so requires, or deliberate noncompliance with the Commission's regulations is involved, the notice provision may be dispensed with and, in addition, the particular order may be made immediately effective pending further order.
Order to Cease and Desist An order to case and desist is ordinarily issued when a person is conducting unauthorized activities and has been notified of the need for authorization but fails to terminate the activity and other similar cfecumstances as appropriate.
Order to Suspend a License An order is ordinarily issued for immediate suspension of a license, or a portir thereof, as nece.ssary to re. move an immediate threat to the health, safety or inter <est of licensee's employees or the public.
Order to Modify a License An order for the modification of a license, in whole or in part, is ordinarily issued as an enforcement sanction when it is determined that a licensee's operations or activities must be limited or modified to protect the health, safety or interest of the licensee's employees or the public, or the common defense and security.
Order to Revoke a License An order is ordinarily issued to revoke a license when:
a.
The licensee's performance shows that he is not qualified to perform the activities covered by the license; b.
Civil penalty proves to be ineffective as an enforcement action; c.
The licensee refuses to correct items of noncompliance; d.
A licensee does not respond to a " notice of violation";
e.
A licensee's response to a " notice of violation" indicates inability or unwillingness to maintain compliance with regula-tory requiremerits; or f.
Any material false statement is made in the application or in any statement of fact required under Section 182 of the Act.
Denial of Application for License Renewal Denial of an application for a license renewal is ordinarily used in lieu of an order for revocation where license renewal is pending or the expiration of the license term is imminent.
Order for Other Items of Noncompliance Orders to cease ano desist, or for suspension, modification or revocation of a license, are ordinarily issued for other comparable types of violations, infractions or deficiencies when the Commission deems such sanctions to be appropriate and necessary.
In all cases where orders are issued to impose civil penalties, to require a licensee to " cease and desist", or to suspend, modify, or revoke a license, tne person so ordered may demand a hearing under 10 CFR Part 2.
The hearing will be granted prior to implementation of the order except in cases where the Commission finds that the violation is deliberate or the public health, safety, or interest requires that the proposed action be temporarily effective pending the outcome of the hearing and/or further order.
This discussion has presented the full scope of the NRC's inspection and enforcement program.
It is our practice to require corrective action for each item identified during inspections.
In the great majority of inspecticns, corrective action is achieved through written notices of violation.
However, the stronger enforcement options are available and are used when the threat is significant or when the licensee appears unable or unwilling to bring the program into compliance.
In closing, I would like to present a summary of our inspection findings in the recent past.
First, I would like to show you data which indicates why this first NRC seminar was conducted for radiographers.
Figure 1 shows a comparison of whole body overexposures among radiographers with whole body overexposures for all other byproduct material licensees during the years 1971 through 1976.
You will note that the number of radiography overexposures exceeds the number for all other licensees in most of the years shown.
This occurs although radiography licenses comprise only a few percent of the total number of NRC byproduct material licenses.
This is not to say that radiography licensees necessarily have poorer programs than other licensees.
However, it does say that the risk is apparently higher and the radiation safety programs are not as adequate for limiting the risk as other programs are for the smaller risks involved.
You should also note that overexposures among radiographers are not limited to while body exposures.
In many instances when a source is not fully retracted, the radiographer places his hand in close proximity to the source.
Exposures to a portion of the hand from hundreds to thousands of rems can occur in a second.
As before, we are comparing radiography overexposures to overexposures among all other byproduct material licensees.
The occurrence of extremity exposures in excess of 18.75 rems among EXPOSURES EXCEEDING LIMITS BYPRODUCT MATERIALS LICEINSEES W RADIOGRAPHY j
L9_J OTHER
& EXTREMITY 25 35 m
g f g 20 h
W C
S 9
O 15 5
5to 5
R 0
R 0
R 0
R 0
R 0
R 0
1 1972 1973 1974 1975 197G
radiographers is of about the same frequency as for all other byproduct material licensees.
It is obvious that in every case where a high whole body exposure is noted there should be an evaluation as to whether a much higher extremity dose may have been received.
Table 1 shows data collected on the results of inspections of radiographic operations during Fiscal Year 1977.
There were a total of 307 such inspections.
Items of noncompliance were identified during 48% of these inspections.
Conversely, slightly more than half of the inspections indicated compliance with NRC rules and regulations.
In the 48% of the inspections which found noncompliance the items have been broken down into the appropriate categories.
Six percent of all items of noncompliance were categorized as violations.
This is a very Figh ratio of violations and indicates the high number of overexposures occurring among radiographers.
Sixty percent of the items were categorized as infractions and thus had the potential of contributing to a reduction of radiation protection safeguards.
Thirty-four percent of the items were categorized as deficiencies in which the threat to health and safety was remote.
Three percent of the 307 inspections resulted in civil monetary pen-alties being imposed.
Again, based upon experience, this is a high ratio and is indicative of the number of overexposures among radiographers.
Finally, we note that, for those inspections during which items of noncompliance were identified, there were an average of three items of noncompliance per inspection.
It is our policy to increase the inspection frequency at those radiographic facilities where numerous or serious items of noncompliance are identified.
Strong enforcement actions are considered an appropriate method of achieving compliance at licensed facilities where items recur or where numerous items continue to be identified.
Figure 2 identifies the inspection items which are most often found to be in noncompliance.
The most frequently occurring item is f ailure of the licensee's employees to follow the procedures submitted by the licensee and incorporated as conditions of the license.
This is disturbing since it calls into question the adequacy of management control systems to verify that employees understand and follow the licensee's own procedures.
In those cases where noncompliance does not appear to result from an isolated circumstance but from general attitudes and lack of supervision, NONCOMPLIANCE STATISTICS RADIOGRAPHY LICENSEES OCTOBER 1,1976 - SEPTEMBER 30,1977 NUMBER OF RADIOGRAPilY LICENSES
'353 NUMBER OF INSPECTIONS 307 NUMBER OF INSPECTIONS - NO NONCOMPLIANCE 158 NUMBER OF INSPECTIONS - NONCOMPLIANCE 149 g
(NOT CLEAR)
AVG. NU,.lBER OF NONCOMPLIANCE /lNSPECTION 3
m
,i, m
NONCOMPLI ANCE CATEGORIES
'o VIOLATION 19 p
INFRACTION 212 DEFICIENCY 179 NUMBER OF civil PENALTIES 8
'4% OF TOTAL BYPRODUCT MATERIAL LICENSEES
ROUTINE ITEMS OF NONCOMPLIANCE FAILURE TO FOLLOW PROCEDURES POSTING OR RECORDS h
33%
?>
Y' EE m
IO INADEQUATE SURVEYS 13%
OTHER 18%
IMPROPER PERSONNEL MONITORING 7%
\\
INADEQUATE TRAINING 4%
the enforcement letter accompanying the Notice of Violation will request a description of actions taken or planned to improve the effectiveness of the licensee's management control systems.
The second most frequently cited item of noncompliance is for inadequate surveys.
This is extremely disturbing since nearly all overexposures of radiographic personnel would be avoided if an adequate survey were per-formed.
To approach a radiographic device without performing a survey is like backing out of a driveway blindfolded.
Most of the time you may be lucky, but you risk serious injury or loss of life.
Improper personnel monitoring is the next most often cited item of noncompliance.
This includes failure to wear a film badge and failure to use a pocket dosimeter properly.
Although personnel dosimetry may not prevent an overexposure, it can limit the consequences of an incident and permit more accurate evaluation of the consequences of an incident.
Inadequate training is cited as 4o of all items of noncompliance.
Training is more important than this statistic would indicate as a contriouting cause of items of noncompliance.
The inspection will cite training inadequacies only if a clear failure to provide the required instruction is noted.
Our inspections are limited in time and scope and cannot verify that all employees understand the required procedures.
Prcper training requires constant reevaluation and reinstruction of employees by an alert and aware management.
Eighteen percent of the items of noncomplianc( were for infractions of other specific requirements of Parts 19, 20 and 34 or of specific license conditions.
Thirty-three percent were cited as deficiencies.
That is our program aad the findings of our inspection program.
- Again, the safe use of radioactive materials is the licensee's responsibility.
The NRC's responsibility is to verify that the program is being adequately controlled and is in compliance with NRC requirements.
If programs are deficient, the NRC will take appropriate actions to assure that the licensee takes corrective actions.
I hope you have a better understand-ing of the way we do our job and appreciate the responsibilities that you have assumed in acquiring an NRC license.
Thank you for your attention.
OVEREXPOSURES - CASE HISTORIES The previous discussion described how the NRC in general and the Office of Inspection and Enforcement in particular carries out its responsibili-ties for insuring the safe use of licensed radioactive materials.
We learned this is accomplished first, by a program of inspections and investigations conducted by Regional Offices, and second, by the evalu-ation of findings that result from the inspection process, and finally, by appropriate enforcement action.
During this hour we are going to consider a number of ways that you as licensee management can carry out your responsibilities for assuring that radiographers perform their duties in a manner that will insure their safety and the safety of the public.
We are going to review a number of case histories and discuss the con-ditions or practices which resulted in overexposures of licensee radiog-raphers.
We have noted similar overexposure incidents occurred not only in States which are under the jurisdiction of NRC, but have also occurred in Agreement States.
Therefore, it does not appear the high incidence of overexposures for industrial radiographers is directly related to geographical areas or regulatory agencies.
In an effort to come to some conclusions about the cause of the higher than average incidence of overexposures received by industrial radiographers, we could ask a number of questions.
For example:
Is the nature of industrial radiography such that a certain number of overexposures are unavoidable?
Are job requirements so demanding that the average radiographer cannot be adequately trained to make the right decisions when confronted with either routine or unusual occurrences?
Is it impossible for management to exercise sufficient administrative control, since most of the violations of safety procedures are committed by radiographers when management isn't around?
Is the regulatory program as administered by the Licensing Branch and the Office of Inspection and Enforcement failing to pinpoint problem areas?
Would increasing penalties for items of noncompliance, especially overexposures, significantly reduce the number of overexposures?
From our' experience we conclude the answer to all these questions is NO.
What then has caused one particular class of licensees, namely, industrial radiographers, to have such a high incidence of overexposures? We can approach this problem initially by a review of overexposure experience.
In the years 1971 through 1977, organizations licensed under 10 CFR Part 34 to perform industrial radiography accounted for 53% (46 out of
- 87) of the radiation overexposures greater than 5 rem whole body or 75 rem to extremities, reported by NRC licensees.
These figures include 16 radiography overexposures (out of a total of 18 for all licensees) with exposures greater than 25 rem whole body or 375 rem to extremities.
In 1976 there were 321 NRC radiography licensees.
Another 600 licenses have been issued by Agreement States, principally Texas, Louisiana and California.
It is estimated there are more than 9,000 individual radiog-raphers operating radiography devices for these licensees and are taking millions of radiographs each year.
The overexposure experience previously stated pertains only to NRC licensees.
However, overexposure to Agreement State licensees has been similar to NRC experierce.
One somewhat surprising fact is that the average radiation dose received by industrial radiographers is lower than for five other classes of licensees.
Therefore, our principal concern is the reduction in the number of overexposures received by individuals and not by the long-term health effects of the industrial radiographer population.
There are two basic levels of defense in protecting against overexposures:
(1) prevention of inadvertent exposure of the source, and (2) detection of sources that are exposed before they result in an unnecessary exposure.
The first depends largely upon equipment performance and is more amenable to direct improvement than the second, which depends upon the consistent performance of safety procedures.
Better equipment performance offers the greatest promise of improvement.
This could be accomplished by device designs that reduce possible human error and equipment malfunction.
Overexposures have occurred when sources jammed in guide tubes, became disconnected from the drive cable, or hung up on the lip of the exposure device.
Overexposures have also occurred when the operator forgot to retract the source or became confused about retracting it and had no positive source position indicator to help him determine the location of the source.
Adherence to safety procedures within a licensee organization is brought about through management controls and responsible action by radiography personnel.
It is questionable whether these two factors are capable of direct improvement by regulations.
Lack of training has been cited as a contributing cause in the majority of the 42 overexposure incidents reported.
It was sta+.ed previously that there were 46 overexposures.
However, 46 was the number of individuals who were overexposed during the 42 incidents.
It is not possible to con'irm whether the cause was truly lack of knowledge or whether that rea:on might be used as an excuse to cover up some other factor such as negligence.
Rad ography overexposure accidents generally happen in two parts.
- First, the source is left exposed when it should not be.
Second, a required radiation survey to assure proper radiation levels is omitted or inade-quately done.
Both of these conditions must be met if an overexposure is to occur.
Let's take a look at the 42 overexposure incidents and see why the source was left exposed:
Radiographer forge *.s to retract source.
7 Source jams in guide tube.
7 Source disconnects from control cable.
3 Radiographer does not fully retract source into the safe shielded position.
10 With two sources and controls present, the radiographer exposes the second source instead of retracting the first source.
3 Source moves out of shielded position after survey.
3 Operator confuses "in" and "out" 1
Other miscellaneous.
3 Unknown.
5 Next let's see why the adiographer did not discover the source was exposed:
No survey performed...
23 Incomplete survey.
5 Fail"re to lock the device before moving.
3 Radiographer realized the problem but did not handle the emergency situation properly.
Broken survey meter..
2 2
Other miscellaneous.
4 Unknown.
In none of these cases, however, was a device malfunction positively identified as a contributing factor in causing the source not to be fully retracted.
Of the secondary causes of overexposures, by far the most prevalent cause is the failure of the radiographer to perform the survey after each exposure.
This survey is clearly required by 10 CFR 34.43(b).
A variation of the "no survey" is the incomplete survey where the radiographer does not survey the front of the device or the guide tube.
At this point let's take a look at several incidents that have occurred in the last few years and which resulted in significant overexposure of radiographers.
CASE #1 - shows what happens when N0 SURVEY is made Radiographer Overexposes Extremities (Hand) While Disconnecting Guide Tube Event:
An experienced r.diographer failed to fully retract a 94 curie iridium 192 source into its shielded position in the exposure devi:e, and failed to make a survey of the exposure device o. guide tube. When the radiographer disconnected the s.urce guide tube he saw the end of the pigtail.
His hand had closed around the section of the guide tube holding the source while making the disconnect.
He realized the source was exposed.
He checked his pocket dosimeter and found it read off-scale.
Dosimetry:
A reenactment of the incident indicated a whole body exposure of 5.4 rems and an extremity (hand) exposure of 3700 rems.
Cause:
The incident occurred because the source was not retracted and the radiographer failed to make a survey.
Prevention:
The incident would have been avoided if a survey had been made.
Personnel alarming devices could have alerted the individual to the high radiation levels.
You will note that a reenactment was performed.
What happened to the film badge data? Also, what about the dosimeter reading? We must ask ourselves:
Can an overexposure occur only if a film badge shows an exposure in excess of limits? A film badge is only one method to determine an exposure.
What kind of exposures can one get from handling an iridium-192 sealed source?
If one actually picks up the capsule, he could get about 3.2 R/Ci/sec or for the 94 curie source this would be about 300 R/sec for a significant volume of tissue.
This is defined as 1 cm2 of tissue.
It might also be of interest to know the exposure to the surface of the hand.
This would be about four times the dose to a significant volume of tissue or would be about 1,200 R/sec for the 94 curie source of iridium-192.
CASE #2 - shows what happens when meter carried but not read Radiographer Overexposed After Failing to Make a Survey When Entering Radiography Cell Event:
After completing an exposure using a 71 curie cobalt-60 source, the radiographer failed to retract the source to its safely shielded position.
The radiographer entered the shielded radiography cell with a survey meter in hand but failed to look at the meter.
He remained in the cell and proceeded to set up the next exposure.
As he picked up the survey meter prior to leaving the cell, he noticed that the meter was off-scale.
He immediately left the cell, read his pocket dosimeter, and found it read of f-scale.
Dosimetry:
A reenactment of this incident indicated that the exposures were 11 rems to the lens of the eye, 5.5 i ems to the abdomen, and 2.9 rems to the extremities (5 ands).
The radiographer's film badge did not indicate an overexposure since the beam was highly collimated and the film badge was worn to the side of the radiographer.
Cause:
The direct cause was the failure to make the required
.urvey.
This man entered the radiation area "blird."
Carrying a survey meter offers no protection unless it is used.
A proper survey would have discovered the fact that the source had not been retracted into the shield.
Prevention:
This incident would have been prevented if a survey had been made and if the cell had been equipped with an interlock which activates an alarm upon opening the cell door when a high radiation condition exists.
Additionally, management training reviews might have impressed the worker of the importance of the survey.
CASE #3 - survey made but not adequate Radiographer Overexposed After Making an Inadequate Survey Event:
A radiographer failed to fully retract a 74.2 curie iridium-192 source after making an exposure.
He approached the exposure device while reading his survey meter; he passed the meter in close proximity to the device and noted no unusual readings.
He proceeded to set up the next exposure.
When he picked up his meter he noted the meter went off-scale when it passed in front of the device.
He returned to the crank and retracted the source with about a quarter turn of the crank.
He read his pocket dosimeter and found it read off-scale.
Dosimetry:
A reenactment of the incident indicated the radiographer received a whole body exposure of 4.1 rems.
Cause:
The incident occurred because the radiographer failed to fully retract a radiographic source and failed to make an adequate survey.
The survey was inadequate in that he did not include the guide tube and front of the exposure device.
Prevention:
The incident would have been avoided if the radiographer had been trained to make an adequate survey.
A personnel alarming device would have alerted the radiographer to high radiation levels.
CASE #4 - failure to survey results in exposures to members of the general public Improperly Shielded Radiography Source Exposes Airline Workers and Passengers to Radiation Event:
A 32 curie iridium-192 radiographv source was packaged in an improper manner so as to permit high radiation levels in the vicinity of the shipping container.
The container was delivered to a commercial airline for transpert and the handling and stowage of the source resulted in the exposure of airfreight handlers and airline passengers.
The incident was discovered during a radiation survey by the company receivinc the shipping container.
Dosimetry:
Calculation based on the surveys performed by the company receiving the radiography source and on a reenactment of the incident indicated that the estimated maximum exposure _.. _.................
of the airport handlers was:
airport #1 - 10.4 rems; airport #2 - 26.0 rems; and airport #3 - 134.4 rems.
Passenger estimated maximum exposure on plane #1 was 10.6 rems and on plane #2 was 6.8 rems.
Cause:
The overexposure to members of the general public resulted from the failure of the shipper to follow proper packaging procedures and failure to perform the necessary surveys to show compliance with DOT regulations.
Prevention:
The incident would have been avoided if individuals had been trained in the proper use of shipping containers and had been instructed to make a physical survey for radiation levels.
This type of incident is considered among the more serious because carelessness or poor training resulted in the exposures of members ef the general public.
Relate this to shipping decayed sources for disposal and the need to assure careful survey for determining transport index, but more important for insuring properly secured source.
CASE #5 - shows what can happen when proper training, surveys, and good supervision are all neglected; exposures occurred not only to employees but to members of the public Whole Body Exposure of Radiographer's Trainee and Company Secretary Event:
A radiographer and trainee were performing weld analysis in the field using a 50 curie iridium-192 source.
At the beginning of the operation the trainee attempted to connect the source control cable to the source pigtail.
- However, the connection was not made correctly and when the source was cranked out into the guide tube it disconnected from the drive cable.
The source remained in the guide tube at various positions throughout the day.
Neither the radiog-rapher nor the trainee used his survey instrument to ccnfirm safe return of the source to the shield after each shot or at the end of the last shot.
During the day neither checked his pocket dosimeter.
At the end of the shooting the trainee disconnected the guide tube from the radiography device after he had cranked the control cable back to the safe position.
The source was in the guide tube.
The guide tube, camera, and control assembly were placed in the bed of an open pickup truck.
During transport the source was dislodged from the guide tube and fell into the bed of the truck.
The truck was used several times by a company secretary over a weekend for routine errands.
The source remained in the truck for the entire weekend during which time the truck was parked in several public places.
The source was discovered when the device was to be used on the Monday after the weekend.
Dosimetry:
The trainee's film badge indicated a 93.4 rem exposure.
Reenactment of the incident involving the secretary indicated a whole body exposure of 55 rems.
Cause:
The incident resulted from poor supervision of the trainee, the failure of the trainee and radiographer to make the required surveys, and the failure to read their pocket dosimeters.
Prevention:
The incident would have been avoided by proper supervision of the trainee and would have resulted in minimal exposure of personnel had the required surveys been made.
Further protection would have been provided by radiation activated alarms worn by radiographic personnel and producing an audible and/or visual signal.
CASE #6 - shows what can happen when the radiographer uses an exposure device indicator light instead of a survey meter to establish the safe return of a source Event:
In this case an assistant radiographer was operating an exposure device eugipped with a light on the control cvank to indicate when the source was in a shielded position or in an exposed position.
The assistant cranked the source (a 100 curie iridium-192 source) back into the exposure device following a normal shot.
He observed that the green (safe) light on the crank control came on and the red (exposed) light turned off.
The assistant approached the device from the rear and pushed the lock into a closed position.
He then entered the area and proceeded to set up for the next shot.
Shortly afterward, the radiographer entered the area.
He was carryi, _ a chirper (gamma alarming pocket dosimeter) which alarmed as he entered the radiation field.
He alerted the assistant that the source must be exposed and both left the area immediately.
In order to retract the source, the assistant had to go up to the camera and unlock it.
The radiographer was then able to crank the source back full to its safely shielded position.
Together the radiographer and the assistant surveyed the device and confirmed the proper shielding of the source.
The assistant checked his 0-200 mR pocket dosimeter and found that it was off-scale.
Dosimetry:
The assistant's film badge indicated a dose of 8.3 rems.
An NRC reenactment confirmed that the film badge was a valid indicator of the whole body dose.
Cause:
The incident occurred because the assistant failed to fully retract the source and depended upon the exposure device indicator light rather than making the required survey.
The overexposure was made worse by the actions of the assistant in locking the device without making a survey and then reentering a high radiation area to unlock the device.
Prevention:
Of course, the direct cause was the failure to survey the camera and guide tube.
Reliance upon the light indicator is not a good technique.
Batteries often fail and the light switch is occasionally activated just before the source reaches the shield.
Using the survey meter is essential in each case regardless of other indications.
In addition, proper supervision of the assistant by the radiographer should have avoided the error.
Primary is the training of the assistant.
Good training should emphasize the use of the survey meter as the authoritative indicator of radiation levels and therefore whether a source is exposed or shielded.
CASE #7 - Trainee Overexposed While Assigned to Perform Radiography Without Direct Supervision of Radiographer Event:
A trainee, who was assigned to perform radiography without the direct supervision of a radiographer, neglected to retract a 13.5 curie cobalt-60 source.
He entered the high radiation area without making any surveys.
An independent gamma alarming system had been installed inside the radiography cell, but was not operating at the time.
The trainee read his pocket chamber, but entered zero since he interpreted the absence of a hairline as an indication of no exposure.
The exposed source was discovered the following day by a second trainee.
Dosimetry:
A reenactment of the incident indicated that the trainee's whole body received an exposure of 6.2 rems.
The second trainee received an exposure of 2.5 rems.
Cause:
An inexperienced individual was allowed to perform radio-graphic operations without receiving the appropriate supervision or training.
As a result of being untrained, the individual failed to retract a radiography source, failed to make surveys, and could not interpret a personnel dosimetry device that could have informed him of his overexposure and prevented the overexposure of the second trainee.
Prevention:
The incident would not have occurred if proper training procedures had been followed.
In addition, the indenendent gamma alarming system provided would have prevented the overexposure if it had been in an operable condition.
CASE #8 - Radiographers Overexposed While Failing to Follow Emergency Procedures Event:
A radiographer entered an enclosed radiography cell and noted his survey meter indicated a high radiation level.
He correctly deduced that the radioactive source was outside its safe storage position.
He discussed the problem with his partner and they tried to remedy the situation by cranking the source out and then back.
When this failed, they entered the room and attempted to reconnect the pigtail to the cable.
Failing again, they pushed the source out of the cable onto the floor and, using a pair of pliers, they picked up the source and placed it into the source changer.
Using another set of cables, they were able to return the source to its camera.
They noted that both pocket desimeters were off-scale and notified their supervisor of the incident.
Dosimetry:
Reenactment of the incident indicated that each man received 6.9 rems whole body exposure and an extremity exposure of 100 rems.
Cause:
The incident resulted from failure to properly maintain the source cables and to properly train radiographers in emergency procedures.
Prevention:
The incident would not have occurred if cables had been properly maintained.
The overexposure would have been avoided if the radiographers had followed proper emergency procedures including notification of their supervision as soon as the problem was noted.
CASE #9 - Radiographer and Radiographer's Assistant Overexposed When Assistant Cranks Out Second Radiographic Source Event:
A radiographer's assistant not under direct supervision mistakenly exposed a 35 curie cobalt-60 source instead of retracting a 94 curie iridium-192 source.
Both cranks were in the same location and the assistant could not distinguish one from the other.
The radiographer and the radiographer's assistant entered the cell with both sources exposed.
The radiographer's assistant carried a survey meter but failed to note that the two sources were exposed.
The radiographer set up the next exposure and bumped his head against an exposed source twice.
Dosimetry:
A reenattment of the incident indicated that the radiog-rapher received an exposure of 4 rems to the trunk of his body, 11 rems to the gonads, 18 rems to the lens of the eye, and between 100 and 400 reos to the two areas of his head.
The reenactment indicated that the radiographer's assistant received a whole body dose of 4 rems.
Cause:
The incident resulted from the radiographer's assistant's inability to distinguish which source was out and failure to make an adequate survey.
In addition, the assistant was performing the duties of a radiographer without direct supervision.
Prevention:
The incident would have been avoided if proper procedures for using two sources (without putting one away) had been followed.
The likelihood of the incident occurring would have been reduced had the radiographer properly supervised the actions of his assistant and if both individuals had been properly trained as to their respective duties and responsibilities.
CASE #10 - Radiographer Overexposed Although Gamma Alarm Indicated High Radiation Area Event:
At the conclusion of a radiographic exposure using a 81 curie cobalt-60 source in a fixed enclosure, the radiographer noted the gamma alarm at the entrance was signaling a high radiation level.
The radiographer called his supervisor and both individuals entered the area.
Since the survey meter used did not indicate any radiation levels, it was assumed that the source was safely stored.
No attempt was made to test the survey meter to assure that it was operating properly.
The radiographer proceeded to set up the next exposure although the gamma alarm continued to signal.
He entered the cell again using a different survey meter and noted that the new meter indicated high radiation levels.
The radiographer notified his supervisor that the source was exposed and the supervisor locked the cell and informed personnel that the source was exposed.
Although the radiographer's pocket dosimeter was off-scale, the reading was not recorded and the possible overexposure was not recorded.
Dosimetry:
A reenactment of the incident indicated that the radiog-rapher's whole body was exposed to 5.4 rem and his extremities (hands) were exposed to 15 rems.
Cause:
The overexposure was caused by the radiographer and his supervisor failing to believe the independent alarming system and failing to perform an adequate survey (verify-ing proper operation of the survey instrument).
In addi. ion, a proper evaluation was not made because pocket dosimeter data was ignored and procedures were not followed.
Prevention:
The overexposure would have been avoided had the radiog-rapher and his supervisor been trained in and instructed to follow emergency procedures for incidents in which the independent alarm was signaling.
CASE #11 - Radiographer Overexposed When Source Not Retracted Before Shift Change Event:
A 44 curie cobalt-60 source and a 92 curie iridium-192 source were being used to radiograph the same casting.
When the first shift was terminated, the radiographer failed to retract the cobalt-60 source into the exposure device.
The second shift radiographer continued to enter the area to set up exposures with the iridium-192 source, failed to make surveys, and failed to learn that the cobalt-60 source was still exposed.
When the second shift radiographer attempted to set up an exposure with the cobalt-60 source, he discovered that the source was left exposed and immediately left the area.
In his haste to crank in the source he mistakenly cranked out the iridium-192 source.
Both sources were now exposed and the radiographer attempted to reduce the persistent radiation levels by repeatedly cranking the cobalt-60 source in and out before finally deciding that the iridium-192 source was exposed.
Dosimetry:
A reenactment of this incident indicated that the first shift radiographer received a whole body exposure of 6.7 rems and that the second shift radiographer received a whole body exposure of 24 rems and an extremity exposure of 43 rems.
Cause:
The incident occurred because the first shift radiographer failed to retract both sources and because both radiog-raphers failed to make surveys.
Prevention:
The incident would have been avoided if procedures for using two sources had been developed and followed.
The need for check out procedures at shift changes is apparent.
If either radiographer had made the required surveys the situation could have been corrected.
CASE #12 - Radiographer Overexposed After Defeating Safety Alarm Event:
While performing radiography in an enclosed cell, a radio-grapher decided to prop open the cell doors to allow air circulation in the room as he changed films and set up for the next exposure.
When he did this the first time he switched the door open alarm to the off position.
This switch also defeated the in-cell radiation alarm.
In a subsequent exposure, the radiographer failed to retract the 166 curie cobalt-60 source being used.
He entered the cell without using a survey meter and while the cell alarms were defeated.
Furthermore, the radiographer was not wearing his film badge or pocket dosimeter.
A production coordinator working with the radiographer also entered the cell.
He too was not wearing any personnel monitoring deveues.
The radiographer exchanged films, adjusted the source collimater, and exited the area along with the production coordinator.
When the radiographer attempted to crank the source out to an exposed position, he realized that the source had not been retracted on the previous exposure and that he and the production coordinator had been exposed.
Dosimetry:
A reenactment of the incident demonstrated that the radiog-rapher probably received a dose to his eyes of 9 rems and a dose to portions of the hand which adjusted the source collimator in excess of 1250 rems.
The production coordinator received a dose of 4 rems to his eyes.
Cause:
The failure to retract the source following an exposure is the direct cause of the incident; however, equally important was bypassing an interlock and failure to use survey meters as required.
It is apparent that use of an easily defeated safety system is a poor practice--one which good management review should have detected.
Likewise, good management audits might have detected poor work practices on the part of the radiographer.
Proper training should emphasize the importance of using survey instruments, wearing dosimetry, and not defeating interlocks.
Prevention:
The incident would have been aveided had the radiographer followed procedures and if management controls had existed to assure he followed procedures.
CASE #1_3 - Radiographer Overexposed When He Failed to Fully Retract Source After Becoming Ill Event:
A radiographer working alone terminated an exposure when he felt ill.
In his haste to secure the device, he failed to fully retract the radiographic source to its safe position in the exposure device.
In addition, he made no survey of the exposure device or the guide tube.
The device with the exposed source in the guide tube was placed in a locked van.
The radiographer drove to several locations but did not return the source to his employer's facility.
The locked van was parked overnight at his residence.
The next morning he picked up his assistant who happened to turn on his survey meter and noted tnat it read off-scale.
They immediately stopped the van and retracted the source.
Dosimetry:
A reenactment of this incident indicated that the exposure was 10.3 rems to the whole body of the radiographer.
The film badge indicated 4.6 rems with the difference due to the fact that the exposure was from the rear side of the radiographer but the film badge was worn on his front side.
Radiation levels in an unrestricted area exceeded 6 Roentgens per hour.
Cause:
The overexposure would have been avoided had the radio-grapher fully retracted the source or made a survey.
The exposure would have been decreased if the radiographer had read his pocket dosimeter.
Prevention:
The overexposure would most likely have been avoided had there been a second man available when the radiographer became ill.
For such cases where a radiographer may be distracted due to illness or injury, there is a need for personal alarming devices which respond automatically to high radiation levels.
S 6.
Conduct periodic training or refresher courses to assure that radiographers maintain a high level of skill.
This does not mean filling out an attendance sheet so you will have a piece of paper to show to the NRC inspector.
7.
If radiographers have difficulty understanding what is required of them, consider the possibility that the management representative who is conducting the training and testing program is not adequately qualified to carry out this important task.
8.
When unusual events occur, investigate them promptly and thoroughly.
Let the radiographer know you mean what you say.
For example:
When a radiographer tells you:
a.
"Nobody ever told me,"
b.
"This is the first time I ever made an exposure without using a survey meter,"
c.
"I left my badge in the exposure area during a shot but I didn't get exposed,"
d.
"I left my badge on my coat,"
e.
"I left my badge in the truck," or f.
"I lost my-badge."
You can reply by saying something like, "That's a strange coincidenc9, I just lost your paycheck." The important thing I am trying to emphasize here is:
when in doubt, check it out.
In closing I would like to say that I hope this is the start of a better dialogue between licensees and the NRC.
I hope that, if in the future you have questions that arise or problems that occur, you will take the opportunity to pick up your telephone and give us a call.
This afternoon, after lunch, you will have an opportunity to direct questions to a panel of experts who I'm sure will be able to answer most of your questions.
These several case histories are typical examples of the kinds of over-exposures being received by radiographers.
We must now ask the question:
How can management do its job more effecti ely and reduce the frequency ano severity of overexposures?
1.
Convey to radiographers that the purpose of training is not ONLY to meet NRC requirements, but more important, to insure the safety of radiographers and the public.
This applies also to written tests and to gaining a thorough knowledge of the operating and emergency procedures.
2.
Insist that a radiographer not only know a requirement but also know why.
It is much easier for a worker to meet criteria if he understands why it is important.
3.
Assure by a vigorous internal inspection program that radiographers are adhering to all required safety procedures, such as (1) maintaining surveillance over exposure sites, (2) making all required surveys, (3) wearing film badges and dosimeters, etc.
It is essential that such inspections be made on an unannounced basis and observation of actual working situations be made without the radiographer being aware that he is being observed.
If you do anything less than this you are not doing the radiographer any favors, because sooner or later he will experience the right set of conditions and an over-exposure will occur.
Also, since management is responsible for the actions of their employces, if you permit such working situations to exist you are placing your company and your NRC license on the line.
4.
Offer an incentive to work safely and comply with company and NRC regulations.
In other words, exercise dynamic management control before an overexposure occurs, not after.
We do not consider management has taken appropriate corrective action when we are told that an employee who received an overexposure has been fired.
The time to take disciplinary action is before the overexposure occurs and at the time it is noted that a radiographer is violating safety procedures or regulations.
5.
Audit records generated by the radiographers for content and validity.
Are records generated for the purpose of giving the NRC inspector or licensee managemt.nt something to look at, or are the records a true representation of actual operating conditions? For example:
Does the survey record show the final survey of an exposure device always results in the same radiation level no matter what the source strength might be?
If you find inconsistencies in the records there is a real possibility that required actions are not being carried out.
CLOSING SUMMATION During the preparations for this meeting a short article entitled, " Thoughts on Compliance," by William A. Brobst, appeared in the Newsletter of the Health Physics Society.
The article speaks frankly to the problem of achieving compliance and summarizes in an informal manner the topics discussed today.
I therefore wish to close this meeting by excerpting from this article.
Mr. Brobst writes that a regulation is a governmental solution to a problem.
However, issuance of a regulation does not, in itself, raise the level of performance by persons who are regulated.
It only sets a legal requirement which, if complied with, raises the level of performance.
It is c,:pliance with the regulation which produces the desired result.
Many regulatory studies have identified compliance--or more appropriately, the lack of compliance--as one of the most critical of all regulatory problems.
To the extent that regulations are not followed, they are useless in raising the level of performance.
Regulations which are not followed are useful only for p osecution.
But what we are after is a higher level of compliance, not punishment for noncompliance.
Mr. Brobst concludes that the three eiements of a compliance program are education, inspection or surveillance, and enforcement.
" Teach people the right way to do things, watch them to be sure they do them, slap their wrists if they persist in doing something else, and be fair in carrying out the compliance program."
In terms of Mr. Brobst's description, the regulatory problem we have discussed today is overexposures.
It may be that better regulations are needed, but it is certain that a higher level of compliance is necessary.
The NRC will continue its program of inspecting, informing, and enforcing to achieve compliance.
It is our hope that as you leave today you will better understand the policy and goals of the NRC and will incorporate the elements of a good compliance and safety program into your radiographic operations.
I thank you for your attention and participation in this meeting.
QUESTIONS AND ANSWERS Q:
Are NRC personnel willing to speak to organizations such as the American Society for Nondestructive Testing or similar groups on subjects such as radiation safety and effects of radiation over-exposures?
A:
Yes.
Requests should be addressed to the Director of the appropriate NRC Regional Office.
The addresses can be found in Appendix D of 10 CFR Part 20.
Q:
How is the " transportation index" determined?
A:
" Transport index" means the number placed on a package to designate the degree of control to be exercised by the carrier during trans-portation.
The transport index (TI) to be assigned to a package of radioactive materials (such as a radiography source) is determined by measuring the radiation dose rate external to the package.
The TI is the highest radiation dose rate, in millirem per hour at three feet from any accessible external surface of the package.
(See 49 CFR 173.389(i)) (Also, there is another method for determining the TI for Fissile Class II packages; see 10 CFR Part 71.11(b)).
Q:
Which rules govern the transportation of radioactive material, Title 10 or Title 49? How can we be assured we have the latest regulations?
A:
In general, all transporting of radioactive material must be in accordance with DOT regulations, and specifically, in the case of interstate transports, 00T regulations apply.
10 CFR Part 71, which sets forth the NRC requirements for packaging and shipment of radioactive material, further requires that shipments where DOT regulations do not apply, for instance intrastate shipments, must be in accordance with DOT regulations.
The latest DOT regula-tions should be available from the Department of Transportation.
The Transportation and Products Safety Branch, Office of Standards Development, USNRC, can provide assistance and information concerning transportation requirements.
Q:
Can a license for performing radiography at a fixed site or facility be amended to permit transport and use of material for offsite or field radiography?
If so, how?
A:
Yes, an application for amendment must be submitted which includes appropriate procedures and instructions for use of licensed material at temporary job sites and for transport of material to job sites.
Q:
When transporting licensed material in a licensee's vehicle which contains a darkroom and other equipment for performing industrial radiography, does the driver of the vehicle have to be a radiog-rapher or a radiographer's assistant?
A:
No.
However, it would be advisable that tha individual be trained in radiation safety and emergency procedures.
Q:
What is the current status of the requirement for posting of "High Radiation Areas"?
A:
There has been no change in the status for posting of "High Radiation Areas."
Posting requirements are as specified in 10 CFR 20.203(c)(1);
i.e., "Each high radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
Caution or Danger, High Radiation Area."
Q:
With regard to iocking source devices after each exposure, will NRC Inspectors consider this a violation or noncompliance if it is not a part of company operating procedures?
A:
Currently there is no regulatory requirement fcr locking radiographic exposure devices after each radiographic exposure.
If a company has procedures that require the devices to be locked after each radio-graphic exposure and those procedures are incorporated into the license as a condition of the license, then failure to follow the procedures is considered " noncompliance".
The failure to have procedures is not considered in itself to be noncompliance.
The proposed amendments to 10 CFR Part 34 (Section 34.22) proposes requiring that the source be secured, by some method, after each radiographic exposure.
Q:
Under what conditions, how, and to what extent will NRC inspectors make suggestions and recommendations on programs?
A:
Inspectors, being regulators, cannot make suggestions or recommenda-tions specific to any situation.
They may, however, describe a spectrum of ways or means by which a given situation might be addressed in order tc satisfy regulatory requirements.
There is a fine line between the inspection process and consulting services.
NRC inspectors are not consultants.
Q:
Are there any plans for standardization of, or suggested structures for, licensee internal audit programs?
A:
The NRC does not suggest or require a prescribed standard or structure for internal audit programs.
The licensee has a latitude in this area; however, the program must be sufficient to assure that the licensed activity will be conducted safely and within regulatory requirements.
In this area of interest, the NRC has published a proposed amendment to 10 CFR Part 34.11(d) which would require that internal inspections (audits) be performed at intervals not to exceed three (3) months.
Q:
How are infractions and deficiencies identified in a licensee's audit program to be reported?
Is it sufficient to record reprimands or rebukes in the daily log on very minor items? Who decides what is " minor", the licensee or the NRC inspector?
A:
First let's assume that you are speaking of internal reporting and second that they were internally detected.
From a management standpoint, there should be some formal documentation of the event showing that it has been reviewed, cause determined, and corrective action taken.
It is expected that the management control system would provide for such a mechanism.
The responsibility for deciding what is minor should remain with licensee management.
Q:
Some people are advocating Federal Licensing of individual radiog-raphers so that they can move from company to company.
I feel that much of this is a hope that " big brother" will take the safety responsibility off of licensee management, where it belongs.
Please comment.
A:
The NRC has received a Petition for Rule Making on this subject from Walter P. Peeples, Jr., President, Non Destructive Testing Management Association.
A summary of the petition, which asked NRC to license individual radiographers, was published in the Federal Register on August 4, 1978, for public comment.
The NRC staff will evaluate the idea of licensing of individual radiographers to determine whether its advantages would outweigh its disadvantages in meeting the objective of improved radiation safety.
The NRC staff's findings will be discussed with the radiography industry when they are complete.
Q:
What is the required time between the NRC proposed regulation dnd its going into effect?
A:
For a proposed rule change one could expect a time frame of approximately one year or longer.
Normally, a rule change would be published as a proposed rule with some designated time frame for public comments (normally 60 days).
If comments are numerous and of substantive quality the rule change might again be published as a proposal which has the comments incorporated, but more likely it would be published as an effective rule with the comments incor-porated.
The rule might be effective upon publication or at some time in the future.
This depends largely on the impact of the rule.
With respect to the proposed amendments of 10 CFR Part 34 published on March 27, 1978 (43 Federal Register 12715), the staff expects to publish the amendments in effective form in early 1979.
This would become effective some months later.
Q:
NRC news release (#78-33), Volume 4, No. 8, announced a revised fee schedule effective March 23, 1978.
Will radiography licensees be affected?
A:
Part 170 - Fees for Facilities And Materials Licenses And Other Regulatory Services Under The Atomic Energy Act Of 1954, As Amended, was published in the Federal Register, Vol. 43, No. 35 on Tuesday, February 28, 1978.
The effective date was March 23, 1978.
The fee schedule is applicable to licenses issued under 10 CFR Part 34.
The license fees are administered by the License Fee Management Branch, Office of Administration, Washington, D.C.
20555.
Any questions concerning fees should be addressed by letter or tele-phone (301-492-7225) to that office.
Q:
How does 10 CFR Part 21, "Peporting of Defects and Noncompliance",
affect raaiography licensees?
A:
This question, and others, concerning 10 CFR Part 21 were raised.
In general, specific responses were not given, but rather, reference was made to the NUREG-0302 document, entitled, " Remarks Presented (Questions / Answers Discussed) At Public Regional Meetings To Discuss (10 CFR Part 21) For Reporting Of Defects And Noncompliance." Sub-sequent to each regional seminar, a copy of NUREG-0302, was sent to each licensee licensed under Part 34.
You are again referred to that document for answers concerning Part 21.
Questions may also be directed to the appropriate NRC Regional Office.
Q:
Are civil monetary penalties levied on individuals, companies, or both?
Is this done in a civil court?
A:
Civil penalties are levied on " licensees."
They are handled as administrative proceedings under the auspices of the Administrative Law Judge.
Q:
Would a notice or citation for an item of noncompliance noted during an NRC inspection be issued although the item of noncom-pliance had been previously found and corrected by the licensee and action taken to prevent recurrence?
A:
A Notice of Violation will not be issued for licensee identified items of noncompliance, provided corrective and preventative actions have been taken, unless the item of noncompliance was of the " violation" category, or if the item contributed to an event or occurrence, such as an overexposure. 4
Q:
An Agreement State licensee must file a Form NRC-241 when working in States where NRC has jurisdiction.
Is the.
a similar require-ment for an NRC licensee when working in an Agreement State?
A:
In general, Agreement States do require notification.
Normally the notification is in the form of a letter which describes the when, where, type of work, etc.
The period of reciprocity varies from 20 days to unlimited, but most hw e a 180 day period like the NRC.
Q:
If an individual radiographar, working alone, is involved in an
" accident", how should hc comply with the requirements of both 20.203(c)(4) and 20.403?
(That is, the safety requirement of preventing unauthorized acceas into high radiation areas vs the requirement for immediate or prompt reporting of the incident.)
A:
In this case, safety first.
The safety of the individual and the public is the primary concern.
Once this is assured, the reporting becomes primary.
Q:
What type of work must be done only by a " radiographer"? What work may be performed by a " radiographer's assistant"? What kind of work may be performed by a " radiographer's helper"? What is meant by
" physical presence of" and "under the supervision of"?
A:
10 tiR Part 34 defines only two job classifications; radiographer and radiographer's assistant.
This answer is limited to that context, regardless of what types of job classifications a company may establish within its own organization.
During any radiographic operation, a qualified radiographer most be present at the site where a sealed source or sources are being used and must personally supervise all radiographic operations.
The radiographer must be intimately associated with each radiographic operation which he supervises to the extent that he knows at all times who is conducting the radiography, what specific radiographic procedurcs are being employed and the specific location at the site where each operation is being conducted.
The radiographer is responsible for seeing that all radiography is conducted in compliance with the regulations and with the conditions of the license.
When the qualified radiographer is not visually observing radiographic operations, a positive means must be provided whereby the radiographer can be immediately called to the spot if he should be needed by a radiographer's assistant.
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Q:
If a single radiographer, operating alone and maintaining surveil-lance of the area as required by 20.c03(c)(4), wishes to develop film, go to lunch, or cease control by surveillsnce, it is understood that he must secure the radiographic source per 20.207.
Must he then change his posting of the area from the requirement of 20.203(c) to the requirement of 20.203(e)?
A:
Yes, he should.
The NRC does not encourage "over posting".
Q:
Will the NRC drop the requirement of posting both the high radiation area and the radiation area and accept a high radiation area sign at the restricted area boundary?
A:
No. Each radiation area and each high radiation area must be posted in accordance with the requirements of 20.203(b) and 20.203(c)(1),
respectively.
Q:
Will you explain the training requirement that must be given to an experienced radiographer?
A:
Let's assume the radiographer has been trained and qualified as a radiographer within the definition of " Radiographer" as defined in 10 CFR 34.2(b).
Let's further assume that he goes to work for a company (licensee) other than the one where he was trained.
That licensee then, must determine and/or provide training such that the individual:
1.
Can demonstrate understanding of the subjects outlined in 10 CFR Part 34, Appendix A; 2.
Has received copies of and instructions in the regulations contained in Part 34 and in the applicable sections of Parts 19 and 20, NRC license (s), and the licensee's operating and emergency procedures, and shall have demonstrated understanding thereof; and 3.
Has demonstrated competence to use the radiographic exposure devices, sealed sources, related handling tools and survey instruments which will be employed in his assignment.
Q:
What is meant by " management controls"?
A:
Simply stated, it means a system whereby responsible management monitors and maintains a program or operation within the limits of established criteria.
An internal audit program is a management control.
Q:
Explain why after one inspection we may have no items of noncompliance, yet on the next inspection we may have one or more noncompliances.
A:
The inspection process is a selective or spot review of procedures and records, personnel interviews, measurements and observations.
It does not include a detailed review of a licensee's total program, but rather a sampling.
The sampling during one inspection might show an item of noncompliance.
If the item is of some significance or it indicates a weakness in the program, the inspector may esca-late his review.
As the depth of review increases, the possibility for items of noncompliance increases.
Q:
What are the current criteria for a " civil penalty"?
A:
You are referred to the text material in this document.
Criteria is described in the section entitled, "NRC INSPECTION PROGRAM AND
SUMMARY
OF INSPECTION FINDINGS" The discussion of civil penalties begins on page 15.
Q:
If a service agency which performs work, calibrations, or services equipment for a radiography licensee is suspected by NRC to be in violation of NRC regulations and may have its license revoked or sources removed will the NRC make the information available to the radiography licensees so that they will not have their safety programs jeopardized?
A:
The NRC has no plans for such notification.
Experience indicates that such situations occur at a very low frequency and it is not seen as a problem.
It is incumbent on licensees to assure that services are performed by reputable and reliable service companies.
Q:
How does a radiographer determine that his radiation survey instrument is operable?
A:
The most obvious way would be to place it in close proximity to a radiographic device.
Most certainly a radiographer should have some feel for expected radiation levels on equipmeat that he routinely handles.
Another way would be to provide a " check source" that is read'ly available.
Q:
The current NRC regulations require numerous radiation surveys to be made to assure the proper storage and shielding of radiation sources.
A few of the required surveys are:
a.
on receipt (record required).
b.
when approaching a source af ter an exposure or prior to storage.
c.
prior to storage at end of operations (record required).
d.
prior to shipment or transporting sources.
e.
of restricted area to confi 'l proper boundaries are established.
As indicated, only two records are required by regulation.
We are obligated to conduct the other surveys but it would be a hardship to document all surveys as implied by 10 CFR 20.401(b).
Please define our obligation as interpreted by the NRC for maintaining records of surveys.
A:
10 CFR 20.401 and 10 CFR 34.43(d) require that records be maintained of specific surveys.
Judgement by NRC licensees is required for maintaining records of other surveys required by the regulations in which maintenance of the records is not specifically specified in the regulations.
NRC does not expect radiographers to maintain written records of every survey reading that a radiographer makes when approaching a radiography device or confirming that proper boundaries are established during a work day.
However, records should be maintained by each radiographer during the work day to show that proper surveys have been done.
Q:
When a radiographer works at a nuclear reactor, whose dosimetry is the official record?
A:
The dosimetry of record would be that provided by the radiographer's dosimeters.
If there is some discrepancy in the two records an evaluation must be made.
Based on that evaluation, the dosimeter that most closely reflects the estimated dose is the one of record.
Q:
Does the NRC suggest any particular types of film badges?
A:
No; only that they be responsive to the type and range of energies of the radiation associated with the licensed activity.
Q:
Is there any requirement that a female cannot be a radiographer?
A:
No.
Q:
A proposed Regulatory Guide, 10.6, suggested substituting the expo-sure rate of 2 mR/hr for the total exposure of 2 mR in any one hour.
Is the regulatory intent being changed?
A:
The intent is not being changed.
Regulatory Guide 10.6 is only a guide, as the title implies.
It sets forth various ways in which the requirements can be met during the conduct of radiographic operations.
In this case, it is suggested that the restricted area around a temporary radiographic location be established where the radiation level does not exceed 2 mR/hr.
This would assure that a person continuously present would not receive more than 2 mR in any one hour.
Levels of radiation in an unrestricted area still remain as those specified in 10 CFR 20.105(b).
Q:
Will the NRC give authorization for a Radiation Safety Officer or other qualified person to perform maintenance of a minor nature on malfunctioning equipment?
A:
Yes, provided sufficient information e' an individual's experience and qualifications is submitted so that the NRC can make that determination.
A detailed description of the nature and extent of the maintenance or repair should also be submitted for evaluation by the NRC.
Q:
Regarding the proposed 10 CFR 34.2(h), the word " shielded" is indef-inite as to the degree of attenuation or radiation level outside the installation.
It is also indefinite as to direction (360 degrees or otherwise).
Should the proposed 10 CFR 34.2(h) be changed to clarify the definition?
A:
The definition was not intended to be specific in that respect; rather, it is intended to encompass all types of cells or structures in which radiography is regularly performed, regardless of the degree of attenuation, even those without shielding on the top.
Q:
What is to preclude the use of a high-scale dosimeter, reading in R/hr?
A:
High range pocket dosimeters are not precluded by the regulations.
10 CFR Part 34 requires that pocket dosimeters shall have a range from zero to at least 200 mR.
From a practical standpoint, high range dosimeters leave something to be desired from the standpoint of being able to determine radiation exposures of low levels.
For example, it would be difficult to read exposures in the range of the quarterly limits established in 10 CFR Part 20 on a 100 R range dosimeter, or even one with a 50 R range.
Q:
How can radiography licensees obtain reports of overexposures and other incidents so they can use them in their training program?
A:
For a start, this document provides a number of overexposure case histories.
NUREG-0090-03, entitled " Report to Congress on Abnormal Occurrences" also contains information on incidents and overexposures, if they meet specified criteria.
This document is published quarterly and is available from National Technical Information Service, Springfield, Virginia 22161, for $3.50.
You may also contact your regional NRC office.
Q:
Is radiation barrier rope considered an adequate barrier when supplemented with recommended perimeter signs?
A:
The " Caution Radiation Area" signs do not supplement a rope barrier; but rather, a rope barrier supplements the signs.
10 CFR Part 20.205(b) requires that each Radiation Area be conspicuously posted with signs.
Q:
Should a snap and ring type gate be required for entry / exit to a radiation zone?
(Suggested to avoid the casual stepping-over of a rope by authorized personnel.)
A:
This not a requirement.
Q:
The staff has stated that there is a high incidence of excessive radiation overexposures to radiographers.
Does the staff have data on the prevalence of such exposures?
(That is, the number of overexposures per unit hours of radiography.)
A:
The number of reported overexposures for radiographers and for all licensecs of all types are shown below:
Occupational Overexposures to External Radiation Reported by NRC Licensees in the last 7 years Total Overexposures Overexposures greater than Overexposures gr_ater (1.25 or 3 rem whole body 5 rem whole body than 25 rem whf.e body or 18.75 rem extremity) or 75 rem extremity or 375 rem extcemity Year All licensees Radiography All licensees Radiography All licensees Radiography 1971 57 24 11 9
3 3
1972 59 21 12 6
3 2
1973 65 24 12 7
2 2
1974 103 29 13 5
2 1
1975 39 13 2
2 1
1 1976 52 20 14 14 4
4 1977 54 8
4 3
2 1
Total 429 139 (32%)
68 46 (68%)
17 15 (88%)
If one assumes that about 3,000 people are engaged il radiography at NRC licensed companies, then 140 overexposures oc~.. red during 21,000 man years of work.
This represents an overex u ure i_te of 0.007 overexposures per man year.
However, the ".C staff considers any radiation overexposure to be excessive.
Q:
On a ship in a shipyard, there have been instances where the ship's crew have violated the barriers installed by a radiographer.
In some cases the individuals were inebriated or half-asleep, and in one case it was a streaker.
Also, radiation areas have almost been over run by people responding to ship's drills (fire drills, etc).
This can happc so quickly, radiographers have little time to react.
No overexposures have resulted.
How can shipyard radiog-raphers be held accountable for a situation like this?
A.
The obvious answer is that procedures, assistance and other methods be available to aid the radiographer in controlling access to the radiographic area, particularly the high radiation area.
In the case described, it appears that a discussion with the Captain of the ship would be appropriate.
Q:
Has the NRC received a heavy response on the " moonlighting" exposure history proposal, especially concerning radiographers working for multiple licensees?
A:
We assume that the question refers to the proposed amendments to 10 CFR Parts 19 and 20 which would require a licensee to control the total occupational radiation dose to individuals.
Forty-one public comments were received.
This is an average number of comments for a proposed amendment which would affect all licensees and which was mailed to all licensees upon publication.
None of the comments specifically discussed industrial radiography, but a few of the companies submitting comments have radiography licenses along with other types of licensees.
Publication of this regulation in effec-tive form is not expected before mid-1979.
Q:
I am a radiography manager.
With respect to the proposed regulations on transient workers, what are my responsibilities regarding the below situations?
One of my full time employees (unknown to me) is moonlighting for another radiography company.
I hire a part time employee who I suspect is working full time for another radiography firm.
A:
In effect the proposed amendments would require that you (the licensee) have a continued knowledge of occupational doses received by an individual worker from sources outside your control.
This could be accomplished by a variety of licensee-employee agreements or conditions of employment.iuch as an agreement by an individual worker to report promptly to the licensee any occupational dose received ou.tside of the licensee's control.
You need not verify occupational dose information provided by the worker.
The regulation would require only that you make a good faith effort to determine the worker's dose from sources outside your control.
You would have no responsibility under the proposed regulation if a worker untruth-fully denied he was receiving other exposure to radiation.
If yoc suspect an employee is working for another radiography firm you would have to make a good faith effort to find out about his outside occupational exposure.
The employee himself is the obvious source of such information.
Q:
Do you recommend that a iice.isee have radiation safety team?
Who in an organization should be member-of such a team?
A:
Each licensee is 'equired to have effective emergency procedures.
How the licensee s..coses to implement those procedures and/or respond to an emergency remains within the judgment of the licensee.
Each radiographer, in his own right, must be knowledge ele and capable of responding to an emergency within the framewoik of the procedures.
It is expected that the RSO and/or other resconsible management would be involved in directing response to an emer-gency situation.
Emergency procedures should identify responsibili-ties in the area of emergency response.
Q:
If a company had more than one Agreement State lice se, by alternate use of the licenses and the 180-day reciprocity granted under 10 CFR 150.20 it appears that the company could work in a non-Agreement State continually without an NRC license.
A:
The possibility does exist; however, it is eolikely that this situation would occur.
Agreement State licensees are required to report (Form NRC-241) to the NRC whenever they conduct activities in a non-Agreement State.
The reports are monitored for that type of activity.
Q:
What levels of licensee " management" are required to sign infraction notices?
A:
Assuming you mean the individual who would sign the response to a Notice of Violation from the NRC:
It is expected that the response would be signed by a member of management at the corporate level or a membe.' of management that has the authority to act for the licensee in committing the resources required to achieve corrective action for the noncompliances in the Notice.
Q:
With respect to the " advance notice of proposed rulemaking on design of radiographic exposure devices"-
(1) will these rules cover equipment presently in use, and (2) approximately how long before these rules become effective?
A:
As of September,1978, the NRC staff was not certain whether or not to proceed with rulemaking on this subject.
If it is decided to proceed with rulemaking a proposed rule would be published for public comment.
The effective rule would subsequently follow.
The rule would cover devices presently in use only if this pro-vided r' ear safer.y a&antages.
At this time it cannot be predicted when such a rule would become effective.
Q:
Please elaborate on the how and with what, of:
(1) shielding, and (2) source tube in camera shall be lined, as they are addressed in the proposed rule on radiographic exposure devices.
A:
The rule, as proposed, would rr.,uire that the shielding of a radiographic wposure device t.e sufficient so that the dose rate from a loade and locked device will not exceed those specified in 10 CFR Part 34.12.
The rule would also require that the source tube (s tube), inside the device, be lined when uranium is used as the shielding material.
In effect it means that the s tube cavity shall have an insert or liner of some suitable material to prevent the source and pigtail assembly from gouging or sluffing-off of the uranium.
The primary purpuse is to prevent contamina-tion of the source capsule surface.
It has been suggested that Zircaloy, stainless steel, etc., would be suitable liner material.
Q:
If licensed by both State and NRC, is one subject to an NRC inspec-tion if NRC license has not been used?
Is NRC considering an ALARA policy?
A:
If "not exercised" means that no licensed material had been possessed or used under the license, the license would not te inspectable.
This determination would only be made, however, after an inspector had arrived for purposes of making an inspection.
In the case of the t'reement State license, a licensee is subject to inspection when acti.ities are conducted under that license in a state where the NRL..._ ;4risdiction (nonagreement).
With respect to ALARA, the NRC has for,everal years advocated and promoted ALARA.
It should be noted that ALARA is addressed in 10 CFR 20. (c).
Q:
Are " gamma alarms" required for cadiography performed in cells?
A:
Gamma alarms are not currently required.
The proposed amendments to 10 CFR Part 34 include a requirement that permanent cells be equipped with visible and audible alar See Part 34.29 of the proposed rules.
Q:
Why are periodic inspections of radiography operations required at least quarterly?
If there were no significant problems found during any inspections by persons of authority in management or by the NRC within a two year period, could periodic inspections be limited to twice a year?
A:
The quarterly frequencies for internal audits / inspections is based mainly on considerations of effectiveness and reasonableness.
To be effective the audits must (in addition to other things) be conducted frequently enough to be recognized as a continuing program by those being audited.
It is believed that a quarterly frequency serves this purpose and at the same time is reasonable from the standpoint of not being a burdensome, excessive requirement.
Q:
Are there
-.y plans for requiring personnel alarming dosimeters to complement self-reading dosimeters and film badges or TLD, especially in field radiography operations?
A; The advisability of requiring radicgraphers to wear personnel alarm dosimeters is being considered by the NRC staff.
Information to date, however, indicates that certain of the commercially available devices may be of questionable reliability.
Safety could be decreased by use of unreliable devices rather than increased.
Decreased safety would occur if radiographers were to pay less attention to their radiation surveys than at present and instead were to depend on an unreliable alarm dosimeter.
This substitution <culd be a natural human response to a situation where a radiographer felt two equiva-lent devices were present to warn of high radiation levels.
In such a situation the radiographer could be expected to choose the easiest method of protection; in this case by relying on the alarm dosimeter as a substitute for the radiation survey instrument.
The NRC staff will develop performance criteria with emphasis on reliability.
Commercially available alarm dosimeter devices are now being tested at Battelle-Pacific Northwest Laboratory.
Based on the results of these tests a recommendation on requiring the use of such devices will be developed by the staff.
Q:
What are the requirements for controlling the usuable condition of pocket dosimeters; that is:
allowable weekly or daily drif t of indicator, up or down scale in a nonradiation field?
percent error allowable in reading in a controlled radiation field?
A:
At present there are no specific criteria in the regulations.
Recently proposed amendments of 10 CFR Part 34 (43 Federal Register 12715, March 27, 1978) suggested annual checks with and acceptable accuracy of plus or minus 30%.
In addition, performance specifications for pocket dosimeters is described in Regulatory Guide 8.4, " Direct-Reading and Indirect-Reading Pocket Dosimeters." This guide endorsed American National Standard N13.5-1972.
Radiographers should use pocket dosimeters manufactured to meet the specifications in ANSI N13.5-1972.
Q:
What is the current thought on having survey meters calibrated to accuracies of plus or minus 10 percent? This is almost impos-sible to achieve with the types of meters used in industrial radiography.
A:
It is presently recommended by the NRC staf f in Regulatory Guide 10.6 that survey ir,struments be calibrated at two points on each scale to within plus or minus 10 percent of the calculated values.
The NRC staff will also accept calibrations to within plus or minus 20 percent of the calculated values if a calibration graph is attached to the side of the survey instrument.
This issue will be reviewed by the staff when Regulatory Guide 10.6 is revised; revision of the guide is not expected before late 1979.
Q:
What is the adequacy of the present dosimetry used for neutron radiation?
A:
The data below from a test performed at Battelle-Pacific Northwest Laboratories
- may help answer this question.
^L. L. Nichols, "A Test of the Performance of Pers* nel Dosimeters,"
Battle-Pacific Northwest Laboratories Report BNWL-2 59," 1977, available from National Technical Information.
-vice, Springfield, Virginia.
NTA Film 238PuBe Fast Neutron Exposures Actual Dose Equivalents (in mrem) Reported by Processors Dose A
B C
E J
(in mrem) 100 1100 0
50 200 0
79 0
70 140 0
120 0
60 150 0
100 0
90 140 0
300 270 0
170 480 0
220 10 220 420 0
150 0
200 440 20 270 40 220 420 0
800 550 160 630 1000 50 850 40 620 1240 50 780 130 570 990 50 590 0
650 1070 50 As can be seen the dosimetry provided by processors B and J cannot be called adequate.
In addition, even the better processors will greatly underestimate the dose 'f high humidity causes fading of the proton recoil tracks or if a large proportion of the dose comes from neutrons with energy less than about 0.7 MeV (because these neutrons do not create readable tracks).
Guidance on neutron dosimetry, including how to deal with these problems, is given in Regulatory Guide 8.14, " Personnel Neutron Dosimeters."
Q:
Has any medical followup been done on persons who were overexposed during the past years?
A:
The NRC does not normally continue an historical medical follow-up on overexposure cases beyond the time frame ia which an investiga-tion of the overexposure case is completed.
,ignificant cases, however, are referred to the Dep-tment of Energy for their consideration for long term fol w-up.
In all overexposure cases,
'he NRC, with the aid of medical consultants, does determine that the exposed individual (s) is receiving medical care commensurate with the significance of the exposure.
Q:
Does the NRC have any proof of a fatality to a radiographer ca! sed by exposure to iridium or cobalt radiographic sources?
A:
No.
Q:
Does the NRC or anyone else really know how much radiation is actually detrimental to each individual?
A:
There are several schools of thought on what the consequences are from exposure to ionizing radiation; one being that any exposure to radiation is harmful in that it may cause cancer in the individual exposed or genetic effects in offspring.
The Commission assumes this attitude for purposes of regulation.
That is the reason for a policy which emphasizes that exposure to radiation be maintained "as low as is reasonably achievable" (ALARA).
Q:
What is the who, when, where and why of the specific limits established in 10 CFR Part 20, Section 20.101?
A:
The dose limits currently in 10 CFR Part 20 are based on the 1957 recommendations of the National Council on Radiation Protection and Measurements (NCRP).
The NCRP is a private organization of scientific experts specializing in radiation science that formulates recommenda-tions for radiation control.
Subsequently, the radiation protection recommendations have been under continuous review within NCRP, by government agencies, and in other countries.
The present limits were derived assuming that for any dose, however small, there may be some effect, also however small.
With this assumption it becomes a matter of judgment as to where to set permissible standards.
No exposure to radiation is considered small enough to be absolutely safe.
While the limits do involve judgment, there is broad agreement within the scientific community that no " mistake" was made and that no aspects of the problem were inadvertently overlooked or incompletely explored.
Q:
If radiographers experience the highest incidence of overexpowres, what group of NRC licensees experience the next highest incidence?
A:
Nuclear powc reactors.
Q:
Doesn't the inclusion (in 20.101) of the two limits of 1.25 rem per quarter and 3 rem per quarter make the regulations somewhat ambiguous?
How long can you continue using 3 rem per quarter? What are the reporting requirements?
A:
Having two limits does add some complexity to the regulations.
A licensee is permitted to use a whole body dose limit of 3 rems per quarter rather than 1.25 rems per quarter if he has determined the individual's lifetime accumulated occupational dose to the whole body and recorded that dose on form NRC-4.
The licensee may continue using the 3 rems per quarter limit as long as the individual's lifetime occupational dose does not exceed 5(N-18), where N is the individual's age in years at his last birthday.
Part 34 licensees must file annual reports under 920.407 giving the number of individ-uals receiving doses in each of the specified dose ranges and must send a dose report to the NRC and the worker under s20.408 for each worker who terminates employment, Q:
Would you consider a 500 millirem dose in a two-week period an overexposure?
If so, or not so, should it be reported or documented?
A:
A dose of 500 mrem in a two-week period, in itself, is not an over exposure and need not be reported.
However, a dose of this magnitude in a two week pe'iod is ouite high for routine radiography operations.
It would appear appropriate for a licensee to investigate and document the circumstances of such exposure.
It may well be that additional training and/or increased observations of the individual's work habits are in order.
Q:
Does the NRC have evidence of visual or physical disability caused by the radiation doses of 3700 rems and 1250 rems, respectively discussed in Case Histories #1 and #11?
A:
There are no particulars available on these specific cases; however, our medical consultant reports that doses to extremities in a range of 1700 to 2000 rems have resulted in visible erythema (i.e., skin reddening).
With higher doses, probably on the order of 5000 rems, more severe burns will occur.
Raw burn areas may be very slow in healing or may not heal until surgical resection and skin grafting is performed.
Q:
A radiographer receives an overexposure.
Reenactment of the incident indicates that he received a dose sufficiently high to be detected clinically.
Medical exams following the incident, however, do not reveal any evidence of an overexposure.
Over what time period and at what frequency should the employee be re-examined medically for radiation injury?
A:
The medical aspects of exposure to radiation can only be addressed by a competent authority within the medical profession.
The licensee is responsible for assuring that an exposed individual receives adequate medical attention.
Q:
What is the st us of the publication in the Federal Register at 40 FR 50327 w, n regard to the (0.5)(M-18)X(N-M) rem formula?
(re:
Docket
.a. PRM-20-6 relating to 10 CFR 20 while body exposure not to exceed 0.5 rem per year.)
A:
This refers to a petition of the Natural Resources Defense Council to lower the radiation dose limits from 5 rens per year to 0.5 rem per year.
On July 31, 1978, the staff recommended to the Commission that the NRC conduct a public hearing on the reduction of individual dose-limiting standards.
As of September 1978, the Commission was still considering the staff's recommendation.
When the Commission reaches : decision on the petition, the decision will be promptly published.
Q:
A company violated 10 CFR 20.101(b)(1).
The individual received 3.39 rem.
NRC regulations were followed in reporting the incident and corrective action taken by the company.
Approximately 30 days later, the company underwent an inspection by the NRC during which time the violation above was reviewed and discussed.
On completion of the inspection, the company was issued a letter stating "No items of noncompliance found." Three weeks later the company received a letter reversing the decision and requesting the return of the letter stating "No items of noncompliance found", and a citation of noncompliance was issued for the above violation.
An interpretation of the regulations on the above is requested.
A:
The appropriate action in this case should have been a letter (Notice of Violation) to the licensee identifying the overexposure as an item of noncompliance, following the inspe tion during which the overexposure was reviewed.
The enforcement procedures were mishandled in this case.
We apologize for the inconvenience it may have caused.
Q:
Is there any areferred method for maintaining records required by the NRC?
A:
There is no preferred method; only that they be available, accurate, leg.ible and sufficiently detailed to reflect the actual conduct of the licensed activity.
A?PENDIX A LIST OF PARTICIPATING INDIVIDUAL AND THEIR NRC OFFICE AFFILIATION USNRC, Office of Inspection and Enforcement Headquarters - Washington, DC Leo B. Higginbotham, Acting Director, Division of Fuel Facilities and Material Safety Inspections USNRC Region I - King of Prussia, PA Boyce H. Grier, Director Gary L. Snyder, Assistant to the Director Paul R. Nelson, Chief, Fuel Facility and Materials Safety Branch Robert 0. McClintock, Chief, Materials Radiological Protection Section USNRC Region II - Atlanta, GA James P. O'Rielly, Director Jack T. Sutherland, Chief, Fuel Facility and Materials Safety Branch James W. Hufham, Chief Environmental and Special Projects Section John Potter, Chief, Fuel Facility and Materials Safety Section USNRC Region III - Chicago, IL Gen W. Roy, Deputy Director Charles E. Norelius, Assistant to the Director Gerald T. Lonergan, Chief, Materials Radiological Protection Section Jesse A. Pagliare, Chief, Materials Radiological Protection Section William H. Schultz, Radiation Specialist, Fuel Facility and Materials Safety Branch USNRC Region IV - Arlington, TX Glen L. Madsen, Acting Director Walter E. Vetter, Assistant to the Director Glen D. Brown, Chief, Fuel Facility and Materials Safety Branch Robert J. Everett, Radiation Specialist, Fuel Facility and Materials Safety Branch USNRC, Office of Nuclear Material Safety and Safeguards - Washington, DC Nathan Bassin, Section Chief, Radioisotopes Licensing Branch James A. Jones, Senior License Reviewer, Radioisotopes Licensing Branch USNRC, Office of Standards Development - Washington, DC Stephen McGuire, Health Physicist, Occupational Health Standards Branch USNRC, Office of State Programs - Washington, DC G. Wayne Kerr, Assistant Director for State Agreements Program Joel 0. Lubenau, Senior Technical Specialist, State Agreements Program John D. Vaden, Technical Staff Specialist, State Agreements Program U.S. NUCLE AR REGULATORY COMMISSION (7 77)
BIBLIOGRAPHIC DATA SHEET fiUREG-0495 4 TITLE AND SUBTITLE (Add Volume No.. of worterinte)
- 2. (Leave blank)
Public Meetings on Radiation Safety for Industrial Radio-graphers, Remarks Presented--Questions and Answers Discussed 3. RECIPIENT'S ACCESSION NO at Five Regional Meetings
- 7. AU T HO R (S)
- 5. DATE REPORT COMPLE TE D M ON TH YEAR November 78 9 PE RF ORMING ORGANIZATION N AME AND M AILING ADDRESS (/nclude I,p Codel DATL REPORT ISSUED Off:ce of Inspection and Enforcement MONTH l YEAR Division of Fuel Facilities ar.d Materials Safety Inspection November 78 USNRC, Washington, D.C.
20555 s (te,ve uen*>
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- 12. SPONSORING ORGANIZATION N AME AND MAILING ADD 9ESS (include 2,0 Codel p
Same as 9 t i. CONTR ACT NO.
- 15. SUPPLEMENTARY NOTE S
- 14. (Leave blaikt
- 16. ABSTR ACT 000 words or less)
A compilation of the speeches presented, and questions and answers discussed during five regional meetings with NRC radiography licensees. The theme of the material is an expression of the NRC's concern for the high incidence of radiation overexposures, with emphasis on maintaining open communications between NRC and the licensees to achieve the goal of improved radiation safety. Subject material includes:
the purpose, scope, findings and goals of the NRC inspection program; ways and means of incorporating safety into radiography operations; and case histories of overexposure incidents with highlights of the causes and possible preventive means. Questions and answers cover a wide range of subjects concerning the possession and use of NRC-licensed radioactive materials.
- 17. KE Y WORDS AND DOCUMENT ANALYSIS 17a. DESCRIPTORS 17b. IDENTIFIE RS!OPEN-EN DE D TERMS
- 18. AVAILABILIT V STATEMENT
- 19. SE CURITY CLASS (This report)
- 21. NO. OF PAGES Unlimited
- 20. SECURITY CLASS (This pegeJ
- 22. P R ICE NRC FORM 335 17 77)
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