ML20054M623
| ML20054M623 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| FRN-47FR19152, RULE-PR-34 NUDOCS 8207140064 | |
| Download: ML20054M623 (66) | |
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In the.v2. :er of:
PUBLIC MEETING ON THIRD PARTY CERTIFICATION OF INDUSTRIAL RADIOGRAPHERS 10 CFR PART 34 D
DATE: June 8, 1982 PAGES: 1 thru 65 A7:
Atlanta, Georgia i
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400 Virginia Ave., S.W. Washing =n, D.
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UNITED STATES OF AMERICA O
2 NUCLEAR REGULATORY COMMISSION 3
PUBLIC MEETING 4
ON THIRD PARTY CERTIFICATION 3
6 i
OF INDUSTRIAL RADIOGRAPHERS E
7 10 CFR PART 34 N
j 8
N Habersham Room 9
i Colony Square Hotel S
Peachtree and 14th Streets jo Atlanta, Georgia 5
11 Tuesday, June 8, 1982 ti 12 The meeting was convened, pursuant to notice, at O
e i3 9:00 a.m., MR. BERNARD SINGER, NRC Panel Chairman.
E 14 y
PANEL MEMBERS PRESENT:
2 15 y
MR. JAMES A. JONES J
16 Office of Nuclear Regulatory Research G
U. S. Nuclear Regulatory Commission i
17 Washington, D. C. 20555.
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18 MR. NATHAN BASSIN
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Nuclear Materials Saf ty and Safeguards Office b
19 U. S. Nuclear Regulatory Commission.
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20 JOHN POTTER - NRC - Region II, Chief, Materials Section.
21 CECIL BROWN, representing the STATE OF NORTH CAROLINA.
Q 22 ALSO PRESENT:
23 y ROBERT D. MARTIN - Deputy Regional Administrator, l
Region II.
Q 24 DICK WOODRUFF, Agreement States Officer, Region II.
25 I
ALDERSON REPORTING COMPANY,INC.
2 1
PUBLIC COMMENTS BY:
2 JAMES R. FORBES, P.E.
Quality Assurance Manager 3
Radioactive Material Licensing Coordinator Law Engineering and Testing Company KEN K. KLINDT 5
g Quality Assurance Engineer ei Oak Ridge National Laboratory 6
R AL J. MOBERG 7
Manager Laboratory Services Newport News Shipbuilding r)
JERRY WADE 9
Charleston Naval Shipbuilding 10 FRANCIS BERRY Chicago Bridge & Iron Company j
11 B
DAVID RUMRILL j
12 Law Engineering Testing Company 5
Atlanta, Georgia O i
'3 DONALD CRABTREE h
I4 Combustion Engineering, Inc.
Chattanooga, Tennessee 15 5
AL MOBERG - Additional Comments.
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MR. SINGER:
Good morning to all of you.
I would 3
like to start the meeting now.
I am Bernard Singer, Chief of
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4 the certification Procedures Branch in the office of Nuclear e
5 Materials Safety Standards of the United States Nuclear 2N 6
Regulatory Commission.
I will be Chairman for this meeting.
6 E
7 On behalf of the Nuclear Regulatory Commission, I
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want to welcome you to the meeting on Third Party Certification dd 9
of Industrial Radiographers as an alternative to the present Y
g 10 system of permitting radiography licensees to train and j
11 designate individuals as radiographers.
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12 We are being hosted today by Region II.
Before
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13 proceeding any further, I would like to introduce our host, 14 Mr. Bob Martin, Deputy Administrator, Region II, who will 15 provide a brief welcoming address.
Bob.
j 16 MR. MARTIN:
Good morning.
At the outset, the hope 1
6 17 l was that the Regional Administrator, Mr. O'Reilly, would be 5
M 18 able to greet you himself.
Unfortunately, he is in the process
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19 of defending the Regional Operations Budget before the Budget 5
20 Review Group in Washington and that has precluded his attendance 21 at this meeting.
22 I want to welcome all of you to Atlanta and to Region
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23,
II.
Today this group will be discussing a, proposal to license or
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otherwise certify individual radiographers to improve public 24 25 j safety.
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ALDERSON REPORTING COMPANY,INC.
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I As many of you may know, this idea has really been O
2 under consideration by the NRC and its predecessor, the AEC, 3
since about 1964.
By way of impetus for a process of this sort, O
4 it is interesting to note that during the period of 1971 to 5
g 1980, that ten-year period, radiographers who constitute only e
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three percent of the Materials Licensees, NRC Materials Licensees R
7 produced over 60 percent of the reported whole body exposures n
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that exceeded 5 rems and in fact, constituted the source of rJ over 80 percent of all exposures that exceeded 25 rems.
10 The agreement state licensees, based on our informa-I tion, have had similar experience and we assume that industrial NI x-ray overexposures might very well be' comparable.
In 1979, I
nine. members of the general public were exposed during a E
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radiography incident and five were reported to have suffered z
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I injury from that incident.
16 In 1980, 31 members of the general public received hI between 90 and 4,000 millirems from another single radiography x
incident.
Many similar events may have been unreported to the 19 j
various regulatory agencies, NRC, of the agreement states organizations.
We cannot really ascertain a total number with I
. great confidence.
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individual radiographers would impose upon them a direct O
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24 accountability towards the general public.
The NRC pursued 11 ALDERSON REPORTING COMPANY, INC.
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more information to support this particular thesis and by March, 2
1980, the staff had developed the elements of the certification 3
program.
This led to discussions with the various agreement O
4 states and an advanced notice of proposed rulemaking is now 5
g before the NRC Commissioners on this cabject.
a 6
The NRC staff has proposed third party certification 7
of individual radiographers rather than reliance upon licensee a
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training programs and activities.
The various organizations d
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9 providing the certification program would be required to meet g
10 NRC standards.
Now there have been other proposals and they E
II included an FCC type radio or an FAA type mechanic licensing is g
12 exam for radiographers.
Along similarclines, we now believe 13
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that the various states now regulate in a comparable type of l
14 fash' ion about 800 other occupations.
Under either third party 15 certification or direct licensing, the NRC would still retain j
16 authority to order the removal of a radiographer.
In this us h
I7 regard, we are not approaching the point of abrogating our own 18 responsibilities.
However, employers would also be required to P
h I9 verify current certification or licensure before a radiographer n
20 were employed.
21 Two of the major policy questions that this group and O
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22 23 exposures warrant a new initiative or should we retain the status 24 quo?
Secondly, would occupational licensing or certification 25 reduce the exposures or just increase costs?
ALDERSON REPORTING COMPANY, INC.
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Your views here today will contribute importantly O
2 towards the development of a FEDERAL REGISTER notice for broader j
3 public comment in the near future.
4 In addition to these gentlemen, Dick Woodruff, our j5 Agreement States Officer, and John Potter, who is sitting at the e,.
6 end of the table who is the Chief of our Materials Section will fr 7
be the Regional hosts for the meeting, for the remainder of the sj 8
meeting today and will be available in our Atlanta office d
9 following the meeting to answer any more specific questions that g
10 may arise.
5 II At this point, I want to welcome you again to Atlanta.
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12 We invite you to visit our offices before you depart if the 13 time is made available to you and you can arrange.that through 14 either Dick or John, and at that point, again, welcome to all E
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of you.
I hope your meeting is very productive and I will turn
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El 16 it back to Bernard for the remainder of the day.
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h I7 MR. SINGER:
Thank you, Bob.
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18 Notice of Proposed Rulemaking was published in the p
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I9 FEDERAL REGISTER on May 4, 1982 and a press release was issued n
20 on May 24, 1982 announcing the meeting.
Copics of both of these 21 announcements are available on the table outside the room.
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23 already registered at the door, I would appreciate it if you i O
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i 25 As indicated in the notice, this meeting will be I
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7 conducted informally.
A tentative agenda is available from our y
O rec 9tioat t-2 As Chairman, I will try to permit those who request 3
Q the time to provide statements the opportunity to do so in the 4
rder received.
e 5
A Following these presentations, I will recognize 6
members of the audience who wish to go on record.
7 A transcript of the meeting is being made.
Therefore, I
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it will be necessary that anyone who wishes to make a statement 9
- i 10 r participate in the discussion be recognized.
Each speaker E
should identify himself or herself along with their affiliation j
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rganization before presenting views.
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'"*" *" '"' **'"* ' '*'* """ *" *****"S" held on certification of radiographers.
A transcript of each E
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l 15 meeting will be placed in the public docket room at 1717 H j
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Street in Washington, D. C.
i 16 Es At this time, I would like to introduce the members 37
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18 f the panel who are here to participate and resolve questions pertaining to the meeting.
19 as At my right is Mr. Jones, representing the Research 20 l
office of NRC and who will have the primary responsibility for 21 answering questions pertaining to rulemaking.
22 23!
Seated at my left is Mr. Nathan Bassin of the Nuclear Materials Safety and Safeguards Office of NRC who will have the 24 O
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primary responsibility for responding to questions pertaining to B
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I the licensing of radiographers--of radiography, radiography O
2 programs.
3 Also on the panel are John Potter of Region II and O
4 Cecil Brown representing the state of North Carolina.
5 y
I would like to say a few words about the purpose of e'
3 6
public meetings.
Whenever NRC proposes to change its regula-e7 b
7 tions, we usually according to our practices publish what we 3
4 j
8 intend to do in the FEDERAL REGISTER and seek knowledgeable d
9 comment from the public or the industry prior to taking our c
g 10 action.
5 II From time to time we deal with a subject that is is g
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. complex technically, has potential socioeconomic impact and has O l I3
'been a source of concern which has not been resolyed in spite z
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Radiography overexposure is such a subject.
To deal j
16 with this matter, we have done a number ~of things including a vs h
I7 major revision of Part 34 of Title X of the Code of Federal 18 Regulations.
One of the things we have not done is establish a C
mandatory certification of radiographers by an independent agency. l 20 Through public meetings, we expect to obtain sufficienb 21 information which will effectuate a decision to either establish O
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practices and policies.
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25 Proposed Rulemaking which posed thirteen questions.
Your responses k
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to these questions will serve, in a large part, as a basis for 2
reaching a decision on this matter.
3 I will now ask Mr. Jones to discuss the ANPR and the
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4 questions in the ANPR in more detail.
Jim.
5 MR. JONES:
Thank you.
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6 In my comments, I will briefly cover some of the n
7 background and the thinking that led to the publication of the s]
8 advanced notice of proposed rulemaking and also to this public d
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meeting.
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10 First, I think I should say a few words about the s
11 distinction between an advance notice of proposed rulemaking and a
p 12 a notice of proposed rulemaking.
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(]) f13 A notice of proposed rulemaking is published when the m
5 I4 Commission proposes to adopt, amend or repeal a regulation.
Prior 15 to publishing a proposed rule, the Commission must obtain complete j
16 information concerning the impact of the rule and the most a
h 17 effective means of implementing it.
The information obtained is
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18 used to prepare value impact statements and regulatory flexibility P
h 19 action analysis which are documents that are required to support n
a proposed rule; where an advance notice of proposed rulemaking 20 21 is a mechanism whereby a regulatory agency can inform the public
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at a very early stage in the rulemaking process that a particular 22 23 l rule is being contemplated and attain public reaction and 24
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information concerning the value and the most effective means of 25 {
implementing the rule.
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In general, advance notices are only; published-1 2
concerning major policy questions.
The issues of radiography 3
interpretation was determined to be a major policy question by
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4 the NRC and in order to obtain public input and information at 5
j an early stage, a decision was made to prepare an advance notice 9f6 of proposed rulemaking and conduct a series of public meetings E
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on the issue.
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As Mr. Martin said, the NRC staff has internally d
considered the issue of licensure or certification of radiographers 0
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at the earliest in 1960.
NRC's interest in radiographer licensing
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exposure and to the high rate of occurrence of whole exposure 13
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incidents by the radiography licensees.as compared to other E
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NRC licensees.
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Although they constitute only 3 percent of NRC x
16 material licensees, radiography licensees were involved in over i
d 17 60 percent of reported exposures to the whole body greater than x=
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5 rems during the years of 1970 through 1980.
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Although the NRC staff have discussed the pros and 20 cons of radiography and licensing for several years, a consensus 21 was never reached and nothing was done until 1978 when a petition
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was received from the Nondestructive Testing Management Associa-23 tion requesting that the NRC amend its regulations to provide for i
24
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registration, licensing and control of radiographers.
The NDTMA 25 indicated in its petition that a program for licensing would l
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ALDERSON REPORTING COMPANY,INC.
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1 accomplish the following objectives.
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- 1) It felt that it would provide the radiographer with a sense of pride in his knowledge that he has been registered' 4
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4 by a government body.
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- 2) It would provide an awareness that he is directly d
6 responsible for his safety performance.
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- 3) That he is accountable for his conduct to the S
8 extent that registration could be limited, suspended or revoked d
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and future employment in the industry affected.
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- 4) It would provide continuity of safety training and 5
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testing in an industry where the employment is very loyal.
d 12 The NRC published the petition =for. comments in the OE 13 5
FEDERAL REGISTER on August 4, 1978.
Only eleven comments were E
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received concerning this petition.
Two comments favored the 9
15 petition and nine comments opposed the petition.
The NDTMA T
16 subsequently withdrew the petition by letter dated May 10, 1982 6
17 y
without comment.
In March, 1980, the NRC staff, due to recurring M
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problems of radiographer overexposures initiated a new program E
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to improve radiation safety in the industrial radiography 20 industry.
As part of the program, a steering committee 21 l
consisting of senior NRC staff personnel was formed to coordinate A
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manpower, funding, scheduling and priorities.
Representatives 23 l
from agreement states and non-agreement states were later added 24 i
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l in order that a uniform national program on radiation safety 25 l l
could be developed.
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l ALDERSON REPORTING COMPANY, INC.
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The steerint committee established consideration of a
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2 national program for licensing or certification of radiographers 3
as a priority item.
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For clarification purposes, certification is considere m
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a process by which a non-governmental agency or association grants j
6 recognition to an indiridual who has met certain predetermined E
7 qualifications, whereas licensing is a process whereby a
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governmental agency or an agent of the government grants c
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recognition.
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After staff evaluation of guides provided by the 5
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and program guide, the staff determined that due to budgetary Od 13 5
constraints,"an NRC control licen'aing program;was not feasible.
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$4 As a result, the NRC staff recommended to the Commission that a 15 g
regulatory program that incorporates a third party certification
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16 program as an alternative to the precent system be considered.
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g The purpose of the advance notice and also the public meetings J
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is to obtain broad public input to enable the NRC staff to make E
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a determination as well as to recommend to the Commission that 20 a proposed rule be published to establish a radiography certifi-21 cation program.
The advance notice of proposed rulemaking out-()
lines 13 issues that we are especially interested in receiving 23 '
input about.
24 i
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i At this time I would like to highlight those issues 25 !
ll and we would like to receive good public input on them.
i ALDERSON REPORTING COMPANY, INC.
13 1
(slide.)
O 2
In case you can't see those well, of course they are 3
in the advance notice of proposed rulemaking.
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,he firse thing we wou1d 11ke for you to consider, 5
Is the training provided to radiographers under the present 6
system adequate?
Of pourserthenpurpose ofathelthird-party onrour
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7 present training prc.Jram is to ensure that qualified and nj 8
competent radiographers operate out in the field in order to d
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protect themselves and the public, so is the present system C
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adequate for that or would the third-party certification program
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Those are the kinds of questions we would like for s
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Wou1d a third-party certification program reduce the b I4 l' number of over-exposures in the radiography industry?
Again, we
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15 are not sure.
It could possibly increase it, you kno', because
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might report them.
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18 Would a third-party certification program motivate 19 j
radiographers to work more safely?
Again, this is a question we 20 would like responses to.
2 What elements in the present system or in the 2
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3 And tell us why?
Just done say one is better than the other one, O
'i we want '.a know why one is better than the other one.
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14 If a third-party certification procram is adooted.
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what items should be included in the standard for detarmining 3
the competence of individuals to act as radiographers?
We would O
4 have to prepare a standard if this program is adopted and the j
standard should specify exactly what should be evaluated in determining the competence of the radiographer.
We would be E
7 interested in the kinds of things the public feels should be in that standard.
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9 Number 6, If a third-party certification program is j
h,. 10 adopted, should it apply to individuals presently working as
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h radiographers or only to new radiographers?
Should we grand-ci 12 iG father the ones who are presently working in it or should we O-l
'3 We wou1d be interested in geetin,
make everybody take the test, E
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public input on that.
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Number 7, If a third-party certification program is 16 adopted, should certificates be issued to individuals for life or 6.:
17 should there be periodic renewals of the certification?
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18 we would like to know how you feel about that, you know, like
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some occupational programs, certification programs, like lawyers 20 you never have to be retested again.
We are interested in what 21 you think about that.
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Number 8, Would a third-party certification program 23!
l affect the ability of a licensee to respond to variable manpower 24 O
needs?
You know, many projects can come up or programs come up where you need a lot more radiographers than you needed in the ALDERSON REPORTING COMPANY, INC.
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past so would a certification program tend to inhibit the 2
ability to respond to that?
We would like your comments about 3
that.
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since a third-party cereification preoram wou1d 5
g likely be based on cost recovery by a fee system, would the a
6 cost to the licensees of such a program be warranted?
I think
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7 that one kind of speaks for itself.
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8 Number 10, Which alternatives of the two discussed d
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(present system, third-party certification) is preferable?
Why?
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10 Are there other better alternatives?
If so, please explain.
II That is a very good question too.
I think the first question, is j
12 the key thing they want to have out there in the field is Q{
13 radiographers who work safely, protect themse1ves and protect j
14 the public from unwarranted exposures to radiation.
Maybe
_b IS you feel the present system and not the third party is the ij 16 best way to accomplish this, also consider the economic impact w
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of it.
There might could be some ideas.
We are interested to f
18 know those ideas also.
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With respect to the two alternatives, what kind of c:
20 enforcement action could and should be taken against radiographers.
2I who do not operate equipment safely or follow estab11shed O
procedures?
What rights should radiographers have with respect 23 I to such enforcement actions?
We are interested in hearing about 24 this.
We don't know exactly how it should be handled at all at 25 j this point so we are interested in getting really good comments 0
3 ALDERSON REPORTING COMPANY,INC.
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from the public on this issue.
2 Would a small licensee, because of its size' bear a 3
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disproportionate adverse economic impact under a third-party 1
system?
Again, in preparing a regulatory flexibility action m
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analysis we have to say if this would have a more severe impact 4
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on the small licensee than a large licensee.
8 7
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And finally, For those organizations that are interested 8
8 in participating in a third-party certification program, what U
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i would be the estimated cost in implementing such a program?
O 10 This question serves two purposes;' first, in order to have a 5
11 third-party certification program, you need some organization d
12 that is willing to act as a third-p' arty certifier, so we expect 5
to get a response here if there are any organizations out there E
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that want to participate in the program, and we also don't have 2
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a feel for how much a good program like this would cost so we 16 hope to get that kind of information also, so this question is 6
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another very important question to provide information that is M
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(Slide concluded.)
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20 Okay.
These are the basic 13 issues we would like 21 discussed, however, we are also interested in hearing comments
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22 on other aspects of the program that we may have overlooked so 23 anything you would like to say in addition to these 13 issues we would be very happy to hear.
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I will now turn this back over to Bernie.
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ALDERSON REPORTING COMPANY,INC.
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MR. SINGER:
Thank you, Jim.
2 I will now ask Mr. Bassin to discuss the current 3
licensing requirements and policy for radiography training.
O 4
MR..xSSzN:
ehank you, ernie.
5 Section 34.11(b) of 10 CFR Part 34 states that an 3
6 application for a specific license will be approved if the E6 7
applicant has an adequate program for training radiographers 4
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8 and radiographers' assistants and submits a schedule'or dd 9
z.
description of such program which specifies (1) initial o
h 10 training; (2) periodic training; (3) On-the-job training; (4)
II the means to be used by the licensee to determine the radio-i is l
f 12 graphers knowledge and understanding of and ability to complyi
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with Co mission res=1ations and 11censins resuirements, and the 14 operating and emergency procedures of the applicant and; (5) l
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15 means to be used by the licensee to determine that the radio-x 16 graphers' assistant's knowledge and understanding of and ability
,h I7 to comply with the operating and emergency procedures of the z
f 18 applicant.
I9 8
More specifically, Section 34.31 of 10 CFR Part 34 e
20 deals with training requirements for radiographers and radio-21 graphers' assistants.
For an individual to be designated as a i
22 Q
radiographer he must, (1) be instructed in the subjects outlined 23 in Appendix A of 10 CFR Part 34; (2) received copies of and 24 Q
instructions in NRC regulations, the NRC license under which the 25 l radiographer will perform, and the licensee's operating and L
ALDERSON REPORTING COMPANY, INC.
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emergency proceduress (3) demonstrate competence to use O
2 radiographic exposure devices, sealed sources, related 3
3,,. ling tools, and survey instruments; and (4) demonstrate d
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understanding of the topics in Appendix A by successful 5
j completion of a written test and a field examination.
A 6
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For an individual to be designated as a radiographer's S
l assistant, he must, (1) receive copies of and instruction in the n9 8
M licensee's operating and emergency procedures; (2) demonstrate c.5 9
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competence to use, under the personal supervision of a radio-S 10 p,
grapher --I might clarify just a bit " personal supervision." That
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means that the radiographer must have eyeball supervision whenever d
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a radiographer's assistant would use a device.
To repeat,
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demonstrate competence to use, under the personal supervision E
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of a radiographer, radiographic exposure devices, sealed sources, i
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related handling tools, and radiation survey instruments, and 16 ij (3) demonstrate understanding of these matters by successfully 6
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completing a written or oral test and a field examination.
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I might add that all of the agreement states have 19 g
regu1ations which are essentially the same as those of the NRC.
The numbers of different as far as sections and titles of regulations, but the genera 1 requirements are the same.
O In mesu1atory cuide 1o.s, o.ide for the vregaration 1
a 23 of Applications for Use of Sealed Sources and Devices, for 2
O verformins Industria1 madiosraehr, trainins grosrams are 1
25 '
discussed in greater detail and guidance is provided as to the i
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kind of information which should be included in a training program O
2 description.
3 The following are the major points discussed.
For O
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,a,1o,,a,he,s, and,o, the tota 1 train 1n,,ro,,am in,ene,a1, g5 (1) a narrative description of the training program should be 6
provided, specifically for radiographers.
(2) A detailed EE 7
outline of the matters which werezcoveredtin; training, including 3
l 8
the topics in Appendix A and the approximate time to be spent r)f9 on e,ach major area of instruction should be provided.
We suggest 10 and recommend that approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> should be spent in this y
II forma 1 training portion of the program.
g 12 (3) If an outside service organization provides part of 13 the'. training, we ask that the. names of the organizations be I4 specified, so that we know that the training is something that has x
I been reviewed and is acceptable.
Since outside training organiza-tions cannot provide instructions in a particular operating
.h licensees operating and emergency procedure, equipment and z
I faci 11 ties, these matters must be specifically provided for by the applicant and the instruction which will be given in these 0
. areas described in the training program description.
We need a I
description of the on-the-job training which may be provided to O
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l months fu11 time equivalent should be spent in on-the-job O
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comprehensive examination of approximately 50 questions or more ALDERSON REPORTING COMPANY, INC.
20 1
covering all items in Appendix A should be submitted together O
2 with the examination answers, passing grade, and a discussion 3
of the additional instruction which will be given in those-: areas O
4 where the examination indicates a weakness on the part of the e
5 person being examined.
b 6
For radiographers' assistants training, program R
7 requirements are not as comprehensive, we ask only that informa-sl 8
tion be provided including time that we spend in instructing the d
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9 individual in the operating emergency procedures and training g
10 which will be given on use of the equipment which will be 11 involved and a copy of the examination which would consist of, is j
12 or we recommend, approximately 25 questions which will test E
13 understanding of the operation and. emergency. procedures and l
14 equipment together with the examination answers, the passing 15 grade, and additional instruction which will be given in those j
16 areas where weakness is indicated.
as 17 Now, many times persons will be hired by a company' M
18 who have had previous training and experience in the performance i:
19 of industrial radiography.
In such a situation, it is the new n
20 company's responsibility to make his own determination of the 21 competency of each individual and information should be provided 22 concerning the manner in which this will be accomplished and the 23 time which will be spent in instructing that individual in the 24 new licensee's operating and emergency procedures and equipment.
25 We have a requirement for periodic training which i
l ALDERSON REPORTING COMPANY, INC.
21 I
should be conducted at least annually and the information which O
2 should be provided to us should include the contents of the matter, of the subject matters which will be covered in the 3
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periodic training.
2he purpose of the periodic emaining is to 5
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6 personnel in regulations, procedures, policy, and equipment is sr 7
current and up-to-date.
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8 An important aspect of any training program is the d
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personnel who will be providing the training.
We ask that 10 instructors in training programs be specified by name and that j
11 a description of the qualifications in radiation and radiation is y
12 safety and in the use of sealed sources and devices for d'
O i is radiography be provided.
As a minimum, an instructor in the-b 14 radiography training program shoul.d have qualifications that are 9
15 at least equivalent to those of a radiographer and have experience g'
16 and training and have experience beyond the minimum which would us
(
17 be required for a radiographer, 3
18 This is the current regulatory framework for our s
19 consideration of the training program.
In the event a radio-n 20 grapher certification program would be adopted, it would no 21 longer be necessary to provide the comprehensive information i
O concernin, tr,1nin,3u,t described.
,,them, one mechanmism wou1d 22 23 !
be to limit information concerning training in those matters O
24 l which could not be covered by a third party in the testing 25 program.
For example, instruction in a particular licensee's i
ALDERSON REPORTING COMPANY,INC.
22 I
operating and emergency procedures is something that could not 2
be tested by a third party, therefore, we might consider 3
including that as one of the items which would be continued.
O 4
This brief1y describes currene training requiremenes j5 and I will now turn you back to Bernie Singer.
6 MR. SINGER:
Thank you.
Cecil, do you have anything 9
7 prepared you would like to present this morning?
N2 8
M MR. BROWN:
No, I didn't know I was going to sit d
on this panel so I haven't any opening remarks.
MR. SINGER:
John?
I will then ask Mr. Jamea Forbes, representing the Law Engineering Corporation to make t.he first statement in
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response to our RNrR.
3 14 We will limit these statements to fifteen minutes.
5 15 We are running a little ahead so I will be a little liberal is about time.
Mr. Forbes.
MR. FORBES:
Hello.
I am James Forbes, Quality 18
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Assurance Manager and Byproduct Material Licensing Coordinator s"
19 j
for Law Engineering Testing Company.
We are a consulting 20 engineering firm offering industrial radiography as one of 21 our services.
We have been licensed to utilize radioactive O
materials for over twenty years, initially by the NRC and then 23 subsequently with individual state health departments.
We 24 !
Q presently maintain a license with the NRC as well as with all 25 1
!l the agreements states in which we operate.
c 0
il ALDERSON REPORTING COMPANY,INC.
23 I
We have received the advance notice of proposed O
2 rulemaking to establish a third-party certification program for 3
industrial radiographers.
As a company, we see a few benefits 4
to the proposed amendment, however, I would like to address the 5
overriding problems which we see and to offer some suggestions 6
for changes in lieu of this proposed amendment.
~nh7 My first point, lack of training does not seem to be N
j 8
the real issue here.
It is, instead, radiographer negligence.
O In the petition for rulemaking the NDTMA stated that c
10 it was referring to cases where the radiographer acts negligently 5
II on his own despite being provided proper training, testing, and a
g 12 safety equipment.
Our experience too, indicates that accidents 13 are not usually caused by lack'of training.
They are, instead, 3
14
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the result of carelessness and negligence on the part of the z
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Those radiographers often have received the 16 required training.
We have not seen any information to support
.h the opinion that a third-party licensing program would motivate l
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The second point, the proposed amendment would l
20 l
encourage abdication of licensee responsibility.
21 Under the present regulations there is no question O
22
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- The proposed system, though not intended to reduce the responsi-0
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authority.
It is, therefore, not practical to expect full
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accountability.
In the unlikely event in the future that some O
2 accident occurred and we felt that it was the result of an 3
inadaquate certification program, we would expect the third 4
party who performed the certification to bear legal and financial 5
responsibility.
3 6
3 The proposed amendment would further penalize those Nh7 licensees who fully implement the regulations.
n2 8
M We believe that it is impousible to legislate honesty.
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In the present circumstances Law Engineering Testing Company is S
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placed at a disadvantage in the market place in the states in
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12 3
safety training and strict internal certification in order to 13 g
meet the intent of the~regu1~atory requirements.
No matter what z
h rules are put into place there will always be those who find
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15 ways around them.
This proposed amendment would further
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penalize those who strictly adhere to the intent of the regulations.
The proposed amendment would encourage an entrepreneurial M
18 approach to radiography.
Under the present system, companies 19 j
involved in radiography are encouraged to have in-house expertise 20 in radiation safety in order to establish and administer the 21 training and certification requirements.
We have to act in a more O
22 conservative and safety-conscious manner because we have more assets and therefore more to lose.
The pr6 posed amendment might O
24 encourage individuals to practice radiography without sufficient 25 1y backup, both technical and fiscal.
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Instead of the proposed amendment, we would offer
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2 these suggestions.
3 First, more enforcement of existing requirements.
Many of the inspections performed by various regulatory agencies e
5 g
are nothing more than paper searches.
They could, for example, d
6 find out if radiographers in the field are knowledgeable in the N
7 areas in which they are supposed to have been trained.
If real E
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breakdowns have occurred, then existing regulations sh ould be d
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7-strictly enforced.
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Two, specify a minimum number of hours of training
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to be received.
At Law Engineering Testing Company we feel that d
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40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> is a minimum of safety training for radiographers.
This
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or some other number of hours could be adopted to heip assure 14 that sufficient initial training is obtained.
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Number three, require periodic refresher courses.
16 We feel that the real issue here is more related to carelessness 6
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and negligence than to actual lack of training.
With this in E
18 mind, periodic, perhaps annual, r e inforcement could be most
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beneficial.
l 20 In summary, we see very little connection between 21 third-party certification of radiographers and a reduction in over-l
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exposures.
The proposed amendment does, however, touch on a num-23!
ber of areas where the existing requirements could be improved or 24 i
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clarified.
We would like for these suggestions to be considered.
l l
25 q g
Thank you very much.
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ALDERSON REPORTING COMPANY, INC.
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MR. SINGER:
Thank you, Mr. Forbes.
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Do the members of the panel have any clarifying 3
questions?
4 MR. JONES:
I think I might would like to ask one 5
question, maybe two.
a 6
MR. FORBES:
Yes, sir.
R 7
MR. JONES:
Under the present system, any licensee N
8 8
can train and designate an individual as a radiographer once a
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9 the training program is approved.
Due to the fact that there
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are a number of licensees, and I would think the quality of
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we could have radiographers who have programs that are not quite c
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so, good who could go out' there and perform radiography unsafely I4 on that basis, the fact that they were trained in programs that r
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weren't very good?
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MR. FORBES:
Since our program is, good, it is hard h
I for me to comment on that.
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But do you see backing a third-party
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certification program on the basis that it would make the 20 determination of confidence by an independent body rather than 21 the company, who, like I know your program I am sure is out-standing?
MR. FORBES:
Seriously, after considering that, we
()
see some benefits outselves to this amendment, but we also feel 25 like people are going to find ways around any kind of require-ALDERSON REPORTING COMPANY,INC.
27 I
ments if they want to and in balance I think we see more, we see 2
it hampering our operation more than helping it.
3 MR. JONES:
Also, I have a problem understanding
()
4 how that could affect--as the third-party certification is 5
j visualized, it shouldn't affect your training program.
You said 6
that it would affect how you train individuals.
Your training ay7 should be exactly the same as it is now, so the only difference e.2 8
s would be that the final determination of competence would be d*
9
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by a third party, so that you were saying that this would affect O
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your training program, how you actually train individuals, so I
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I2 MR. FORBES:
No.
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That wasn't your point?'
m 5
I4 MR. FORBES:
No, huh-uh.
15 MR. JONES:
Okay.
d I0 MR. SINGER:
Cecil?
w h
I7 l MR. BROWN:
Yes.
I believe, you know, your 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />
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f 18 is kind of a standard requirement, so I don't think you are 19 j
unique at that.
20 Radiographers licensed in our state are more or less 21 required to have 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training plus, you know, experience
(])
up to three months as an apprentice.
23 l Since we are talking about reducing exposure, another
(])
area that we have been concerned with a long time is the odd 25 i
hours and long hours that radiographers work.
Is there any--I I
I ALDERSON REPORTING COMPANY,INC.
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28 I
would like to know what you think about this contributing toward O
2 overexposure and accidents and incidents?
3 Many times these radiographers will go off and work O
4 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> before they quit.
They are sent out to some far area g
5 from their home office and they, you know, are sent out on one 9
3 6
trip job, they go out and do the work and then come back.
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y MR. FORBES:
I am trying to recall any problems that j
8 we have had.
I don't know that there is a correlation between d
d 9
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the working long hours and the occurrence of any overexposure 10 or having any kind of problems.
There may be some.
I am just II not aware of any off the top of my head.
I don't recall it j
12 being a problem.
13 j
MR. SINGER:
I think to put it in perspective, Mr.
3 14 l
g Forbes and audience, a, good percentage of the industry are made
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15 up of momma and poppa outfits, not necessary large firms and we 16 have found in that, in those cases the competition is very tough, h
I7 the bidding for a job becomes a real problem and the concern for i
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day that is required by contract, and that is the type of thing 20 that gets involved in our interpretation and our concern, so that 21 the higher percentage of the radiography industry is not made up O
22 of very large stable outfits and this certainly shows in the 3:
migration of people involved in the industry, and that is the 24 kind of thing, for clarification, we are concerned with.
25 MR, FORBES:
Yes, sir.
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i ALDERSON REPORTING COMPANY,INC.
29 MR. SINGER:
Did you have a question?
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I wouta lix* 'o **stor* with you $u=* ^
2 bit your comment about abdication of licensee responsibility.
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O believe that the notice indicated that, felt that it would not in 4
any shape, form, or manner lessen licensee responsibility.
How e
5 E
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do you feel that an examination independent of one which you 6
o might give would affect your training so that a third party would 7
be responsible if you had, as Mr. Jones, would not anticipate 8
n j9 that this would change the scope of training that might be i
necessary in order to pass the examination and in what manner 10 ez would you anticipate that a third party giving the examination j
jj w uld provide for abdication of your responsibilities or any 12 iG O l is i w uld be concerned?
E 14 MR. FORBES:
Well, under the present system, we have 15 ti) 16 full resp nsibility and we are giving the test and we decide G
what to test people on.
It is easy enough to say that you still j7
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18 have full responsibility for whatever the licensee does, however,
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39 we are going to take part of this responsibility and shift it to 5"
someone else, which is what this would do.
The responsibility 20 f r testing for certification would actually be shifted away so 21 it is easy enough to say you have still got full responsibility, 22 23 '
however, we are going to transfer part of this over here.
I 4
just don't think it is a practical situation to hold somebocly, 24 l
to expect somebody to be fully accountable for everything that 25 4
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ALDERSON REPORTING COMPANY,INC.
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they do when in fact part of the responsibility is actually O
2 somewhere else.
That is where that is coming from.
3 I guess I just don't see that we could be held, or 4
I imagine we probably would be held fully accountable but 5
g in practicality part of the responsibility is somewhere else 9
6 and it is hard to see how it would be practical.
Eh7 MR. BASSIN:
Let me follow up on that.
Under what E
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circumstances would you send an individual off for certification d
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9 or to take the examination unless you felt reasonably sure that S
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they were sufficiently trained so that they could pass the
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effect might be to increase the scope of training or the intensity of training rather than diminish the training so that E
14 g
people might be better trained than they are under the current 15 system?
16 I am talking now in overall terms, not in terms of one particular individual who currently performs industrial l
18 radiography.
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19 j
MR. FORBES:
Well, it is easy to stand here and say yes, I think we would be better trained and I think from a 21 practical sense though what is. going to happen is people are O
.soins to be trained to eass the eese.
That 1 suse as a matter 23 i
of practicality I think what would occur and I don't know what O
is soins to de, unae wou1a de in this test and 1 aon't xno-25 that we are going to have control over how, you know, how h
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l ALDERSON REPORTING COMPANY,INC.
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31 practical the test is, so it is. going to--I think it is going to shift to more of a trend where I think we are addressing practical concerns in our training to one where we are training people to pass the test.
MR. SINGER:
Mr. Forbes, I appreciate your comments E
and they will be duly recorded and discussed.
6 E
MR. FORBES:
Thank you.
6 7
MR. SINGER:
I would like to call next as a speaker 8
j Ken K. Klindt, representing the Oak Ridge National Laboratory.
9 10 z
E MR. KLINDT:
I am Ken Klindt.
I work for the Oak 4
11 Ridge National Laboratory.
In that capacity, I do not represent 3
S a licensee.
It is not required that the Oak Ridge National Os
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Laboratory have a license.
We operate under the Department of 5!
is Energy who have their own rules, their own requirements; however, w*
I believe they are pretty much parallel to what the NRC requires.
16 g
I have worked at the laboratory for 25 years and t;.
17 prior to that I was in sales and service for x-rays manufacturers 18
_{g so in this period of time, I have had quite a bit of rubbing A
a quaintance with radiography and the safety and problems 20 associated with it.
21 The radiographers at Oak Ridge National Laboratory 22 O
are f rtunate in having a large number of Health Physicists l
23 i
i t
assist with any problems associated with radiation safety.
24 O
The training of radiographers is shared by the 25 i
ALDERSON REPORTING COMPANY, INC.
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1 32 I
industrial radiography supervision and by the Health Physics O
2 Department.
3 The very environment around ORNL generates a O
constant awareness of the need for radiation safety, since 5
g radiation is our business so to speak.
Not radiation, let me n
3 6
correct that--the correction of or problems associated with 6
7 safety relative to radiation.
j 8
The responsibility for personnel safety is assigned d
to the line organization.
The supervision must carefully select O
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radiographers, provide safety procedures, train the person and
=hII constantly emphasize safety over production.
Then the NI radiographer must play a major role in protecting himst.lf and O:
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others in the area.
The Health Physics Department is the I4 staff to the line organization in 5mplementing the total safety 9
15 0
program.
16 is Over the past 25 years, we have mad e a large number I7 of radiographs with radioisotopes in the shop and in the field.
18 In spite of strong safety training, some mistakes have been made 19 j
in handling sources but none have been significant.
These 0
incidents have been infrequent, were immediately detected, and retrievals were handled in a safe manner.
Some of the incidents O
22 were caused by equipment malfunction but the majority were caused 23 :
by not following a procedure.
O 24l
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No doubt the training the radiographer received helped 25 )
to hold down the frequency of accidents and certainly minimized a
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I the exposure received during radiography and retrieval.
There 2
is no substitute for a properly qualified radiographer who 3
understands his responsibility for safety.
The qualification 4
entails more than passing a written examination and demonstrating i
5 j
proper performance in an emergency drill such as might be a
f0 required by a third-party examination.
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In response to the thirteen points which were n
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outlined, I would like to make the following comments.
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Number one, is the training provided to radiographers 0
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under the present system adequate?
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nor if it is the same for all licensees.
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here is whether or not some licensees have weak programs which 5
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could be approved compared to strong programs which are approved.
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Certainly the NCRP Report No. 61 describes an adequate training g
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program.
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5 18
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Number two, would a third-party certification program i
19 j
reduce the number of overexposures in the radiography industry?
l 20 Depending on how the third-party certification program i
21 is set up, it could have minor effects in reducing the number of
(])
overexposures, primarily because of the increased attention to 23 l safety.
(])
Number three, would a third-party certification 25 1 program motivate radiographers to work more safely?
d ALDERSON REPORTING COMPANY, INC.
34 4
I Again, this depends to a great extent upon the
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2 program.
If the certification was from a professional organi-3 zation recognizing competent and qualified individuals on a
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4 voluntary basis, some pride in his profession would motivate the individual to strive for excellence.
If the certification 3
6 is a prerequisite for holding his job, the motivation is gone ED as soon as the certificate is received.
s 8
8 Number four, what elements in the present system o'
d or in the suggested alternatives are particularly desirable 5
10 3
or undesirable?
Why?
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the licensee holds the responsibility for determining which c
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person as certified relative to radiation safety, the licensee 16 j
has the freedom to use that individual even if he works in a d
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careless manner.
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An undesirable element of the present system is the s
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lack of concern for safety on the part of some licensees.
I'm 20 certain no one is more aware of this than the NRC.
The statement 21 has been made that verification by the NRC of the radiographer's O
22 training program is difficult and the primary means of deter-23 '
t mining this is by examining licensee training records.
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Five, if a third-party certification program is adopted, what items should be included in the standard for l
ALDERSON REPORTING COMPANY, INC.
1 35 1
determining the competence of individuals to act as radiographersi 2
The first obviqus step is to examine the radiographer's 3
knowledge of safety rules and procedures.
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4 ru1es is, very sma11 measure of his competence.
,here shou 1d 5
y be a minimum of one year experience as an assistant before a v
6 person can assume the responsibilities of a radiographer.
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competence on a daily basis as an experienced assistant is best a
8 8
evaluated by his supervisor.
A certification from his supervisor d
9 relative to his performance in a safe manner should be a pre-c 10 requisite to any third-party certification.
An emergency drill II in which the examinee takes the responsible role should be is f
12 witnessed by a third party to verify the supervisor's opinion.
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'3 Six, li a third-party certification program is adopted, m
5 I4 should it apply to individuals presently working as radiographers b
15 or only to new radiographers?
16 in I feel it should apply to all radiographers old and h
I7 new since none of them are presently certified on radiation f
18 safety.
It should also include radiographer's assistants, old e-"
19 8
and new.
n 20 Seven, if a third-party certification program is 21 adopted, should certificates be issued to individuals for life O
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Safety is a ALDERSON REPORTING COMPANY, INC.
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matter of practice, not knowledge, and everyone needs an
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2 occasional refresher.
This review only at the time of 3
recertification would not be adequate in a strong program.
4 Eight, would a third-party certification program affect
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the ability of a licensee to respond to variable manpower needs?
8 6
3 It would if he presently uses inexperienced 8"
personnel during peak manpower needs.
In other words, a5 8
certification would shut that off.
However, if he is not willing a
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j to compromise on using only experienced persons in responsible O
10 roles, then certification would not affect his operation.
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likely be based on cost recovery by a fee system, would the cost 3
13 to the licensee of such a program be warranted?
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that licensee's employees avoiding an overexposure that would T
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However, I do not have confidence in H
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the effectiveness of a third-party certification program and
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therefore feel that the added cost is not warranted.
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Number ten, which alternatives of the two discussed.-
l 20 l
(present system, third-party certification) is preferable?
Why?
l 21 Are there other better alternatives?
If so, please explain.
l 22
()
Since a program for third-party certification has not i
23 been formulated in detail, that is not to my knowledge, it is not 24
' ()
l possible to evaluate it; however, my feeling is that the present 25 ). system is potentially the better alternative.
The increase in l
l 1
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!I l1 ALDERSON REPORTING COMPANY, INC.
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the number of overexposures in the last few years indicates, 2
however, that a change is needed to motivate the licensees and 3
his employees toward safer operation of radiographic equipment.
O 4
in a1ternative exists which has mot been mene1oned and 5
that is the modification in the design of equipment to make it j
6 more foolproof.
Electronic radiation sensors could be built E
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into the source containers such that a preprogrammed series of j8 events must occur before an interlock would unlatch the d
9 source tube for removal.
h 10 Another modification which has been added to our
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equipment is the spring-loaded shutter that closes tihe source j
12 exit port unless the source tube is attached.
Other possibilities O-l'3 exises which cou1d maxe the surveying of the source container an automatic built-in operation and eliminate the need for I
manual surveys after retracting the source.
16 in I have dealed for some time on this subject and I feel hI it is something that needs :to be looked at very closely.
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5 18 would make the equipment more expensive but more foolproof and
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it might be more cost effective.
20 With respect to the two alternatives--that is number 11,--what kind of enforcement action could and should be taken O
against radiographers who do not operate equipment safely or 23 follow established procedures?
What rights should radiographers O
h ve with respect to such enforcement actions?
~
25 The fear of disciplinary action is already a deterrent I
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ALDERSON REPORTING COMPANY,INC.
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38 I
to reporting radiation encidents.
Radiographers do not want
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2 their mistakes reported.nnd will cover up unless they know they will get caught.
Deliberate or repetitious unsafe acts
()
4 should be dealt with by the employer.
NRC has the rights and requirements to deal with the 9
3 6
licensee.
R 7
h Number twelve, would a small licensee because of its E
8 M
size bear a disproportionate adverse economic impact under the 0
6 9
g third-party system?
c t
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This depends, again, on how the service is charged.
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A fixed fee per certificate would not penalize the small d
12 g
licensee.
It would be the same per radiographer no matter how OE 13
.many, how big it was.
E 14 Question 13, for those organizations that are interestec
=
9 15 g
in participating in a third-party certification program, what 16
.l would be the estimated cost in implementing such a program?
6 17 g
The cost would depend upon the method of determining E
18
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a radiographer's competence for issuance of a certificate.
s E
19 y
Also, whether the third-party provides training 20 as well as certification and who would provide the enforcement 21 action to determine that only certified individuals are used?
22 O
An estimate of cost cannot be fixed until the proposed program 23 l is better defined.
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In summary, I would like to say the need for 25 l
adequate training for personnel is obvious in the performance of k
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ALDERSON REPORTING COMPANY, INC.
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39 I
radiography using radioactive sources.
There is no question 2
about need for training but this training should be the 3
responsibility of the licensee, as it is now.
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4 The description of what constitutes adequate training 5
3 should be better defined.
Certainly a minimum requirement shoult; N
s 6
1 be minimum specified period of time working as an assistant to E
y gain experience, that is an apprenticeship period.
The training E
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program should be described by NRC to introduce uniformity to d
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7-the licensee's requirements.
0 10 3
This I understand now is pretty well done.
The f
details of the program could perhaps be spelled out a little d
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better.
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'd 13 This final point here, many overexposures which have s
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been attributed to the radiographer not following a written
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procedure could also have been attributed to equipment that was not designed to prevent inappropriate action.
A new look at f
17 equipment design for built-in safety could be very cost-effective.
li 18
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Manufacturers could be encouraged to do this.
ANSI could write s
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the specifications.
20
'The third-party certification might produce a minimal 21 improvement in prevention of re.diation overexposures, but less
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costly methods would also work.
A first step might be to require 23 '
that the employer give each radiographer a certificate of O
competency regarding radiation safety prior to his assignment as 24 25 a radiographer and then officially send this certificate or a ALDERSON REPORTING COMPANY,INC.
40 I
copy of the certificate to the NRC.
This is slightly different 2
than*an assignment or a designation.
I am speaking of an actual 3
piece of paper that says I certify that John Doe is competent 4
to act as a radiographer.
l Awareness of the need for safe action should be made 6
a part of every radiographer's environment.
Encouragement and E
7 motivation are essential.
I am sure things are being tried on j
8 this but one thought that crossed my mind is would a nonthly d
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of individual acts, mailed to the individual radiographers be
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worthwhile?
In other words, a little radiographers newsletter d
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I feel that improvement in safe source handling must E
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come from the operating personnel through pride in their 5
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profession, peer pressure, and motivation or whatever other
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16 systems might be involved.
If third-party certification will >
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provide this, then it would be worthwhile.
E 18
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MR.- SINGER:
Thank you, sir.
Does the' panel have s"
19 l
any statements or gynstions relativa to the paper given by Mr.
20 Klindt?
21 A1* rig c, I thank you very much, i
O 22 The next speaker will be Mr. Al Moberg representing 23 the Newport News Shipbuilding.
Mr. Moberg.
O 24!
l MR. MOBERG:
Thank you, Mr. Singer, ladies and 25 gentlemen.
I am Al Moberg and I am the Industrial Radiation l
I 1-ALDERSON REPORTING COMPANY,INC.
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41 1
Safety Officer for Newport News Shipbuilding.
2 To give you an idea. of our involvement, we have 54 3
qualified radiographers and made 98,000 radiographs in 1980.
O 4
certification andfor testing is on1y one portion of 5
y the effort that goes into the overall competency of the 9
6 Radiographer, the others being training, both classroom and R
b 7
practical; auditing, this is on the job site inspection; a
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discipline for infractions, which includes revoking his 0
9 qualification; supervision, monitoring, annual retraining and 10 testing.
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5 II In the case of Newport News Shipbuilding, our safety is g
12 program is built around the total aspect of performing each O l
'3 exposure in a safe manner.
I4 The testing and certification of the radiographer IS is only one, and a relatively small one at that, of this total 16
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I7 Our program also includes the use of x-rays from f
18 various machines, the largest being a 7.5 MEV Linatron.
Our s"
19 j
operating procedures incorporate unique aspects of our license 20 and those special conditions that are specific to our plant.
21 Consequently, any testing and certification would of necessity O
neve to inctuae these conaition -
3, In your supplemental information you state, "The 24 most critical element in the conduct of industrial radiography 25 is for the radiographer to return the source to its shielded i
l ALDERSON REPORTING COMPANY, INC.
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42 I
container after each radiographic exposure and to verify that
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2 the source is in its shielded position."
All the testing and 3
certifying would not insure that the radiographer would do this.
Internal controlE and auditing are needed to drive this point home.
9 3
6 3
You further stated that in the petition from the NDTML 4
N 8
7 they indicated the radiographer acts negligently on his own E
8 despite being provided proper training, testing and safety a
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Consequently, training and testing does not seem E
10 i
to be the problem.
It's the company that needs..to provide
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certification.
Therefore, any increased effort would seem to o
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be needed in the control of the licensee., not the radiographer.
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It would also seem that a third-party certification 5
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would reduce the responsibility of the licensee by providing i
16 g
him another excuse or a convenient outle;.
d 17 If any change is needed it is in the enforcing the xx 5
18
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company, the licensee, to abide by the existing regulations.
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If more money is to be spent, it should be to enhance the 20 auditing portion of the program.
We at Newport News Shipbuilding 21 are opposed to third-party certification.
Thank you.
22 O
MR. SINGER:
Thank you.
Does anybody on the panel 23 '
have any questions?
I 24 i O
{
Thank you, sir.
25 We will have a statement now from Jerry Wade from 9
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ALDERSON REPORTING COMPANY, INC.
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43 I
the Charleston Naval Shipyard.
Following this statement, we 2
will have a brief break and then open the meeting to the 3
attendees.
O 4
xR.,xos, 2hanx you, xr. Sin,er.
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First of all, Charleston Naval Shipyard welcomes the a
3 6
spportunity to attend this meeting.
We do agree with the Nuclear u
'f 7
Regulatory Commission that the present system in certification 8
of radiographic personnel results in a wide disparity in the aj competence of individual radiographers.
This is substantiated 9
10 by the number of industrial radiography overexposure incidents.
fII In regards to the problem areas related to the present NI method for radiographer certification, the Charleston Naval 13 3hipyard determines the problem to be' twofold.
I4 Allowing each organization to designate personnel to I
act as radiographers without certifying the qualifications of the individual in the employ of the organization who in turn h
certifies the organization's radiographers.
In other words, the
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19 j
bestows certification on the radiographer, at the present time 20 there is no control over that.
Secondly, the qualifications of each individual O
radioeraeher throushout the entire radiation safeer eroerem 23 '
vary substantially because they are not evaluated to a minimum O
- (standardorreautremeatwhich,ifmet,wou1densuretheindividua 25 would meet a basic qualification requirement.
ALDERSON REPORTING COMPANY, INC.
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We have a list of recommendations here and all of these recommendations are in essence based upon this third-3 party program coming into effect, if it does.
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First, to establish a branch of the NRC Or a third party, whichever it is deemed possible to do, to certify an a
3 6
individual in the employ of each organization to act as an B
examiner who will in turn certify the organization's radiographern E
8 to establish standards.
We don't feel it is very practical a
ed 9
because of scheduling problems and so forth for this third g
I O
10 E
party to come to the organization and certify each individual
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radiographer.
We presently at Charleston have probably as d
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many as they have at Newport News Shipbuilding.
I believe we
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thave about 49 radiographers on board'right now and for a third
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party agency to come in and certify each one as we have a class 9
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every two months or to send these radiographers to an agency,
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for certification, we feel like that would be very, very hard 1
p 17 on our schedule.
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Secondly, the radiography industry as a whole must 19 l
establish qualification requirements for the organizationAs:t 20 examiner to meet, and also a method for his certification.
21 In addition, the radiography industry must establish
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minimum requirements for the education, the on-the-job training, 23 and the classroom training for the qualification of radiographic
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personnel.
25l Fourth, guidelines for this examiner to use must be l
l ALDERSON REPORTING COMPANY,INC.
45 I
formulated for the examination stating, for instance, the number O
2 of questions in the written exam, the type questions to be used, 3
the scope of the practical examination and an important factor is 4
a minimum passing grade.
I would venture to say if we check in j
the room here, we probably could find three or four different N
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minimum passing grades in the different programs represented here y
today, but a minimum passing, grade, a 68 passing, grade, 70 or 80, 0
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Number five, a requalification and/or length of O
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certification time must be established for all radiographic
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certification is satisfactory, O!'
who s1xeh recommendation 1s once the cereification E
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program is in effect, an audit program should be performed by E
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the examiner on an unannounced, on-site basis of the radiography y'
16 opeartions.
This audit would serve to identify weak areas of 17 !
the organization's radiation safety program related to operating I
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18 procedures and would identify personnel who may require
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additional training and this all vsuld lead to the possible 20 prevention of overexposures.
21 Our comments to the thirteen questions, number one, d
is the training provided to radiographer's under the present 23 l system adequate?
J The training may be adequate but certification should 25;l I
ALDERSON REPORTING COMPANY, INC.
46 I
not be granted simply by going through a training course and the O
2 radiographer not meeting a minimum qualification requirement.
3 Number two, would a third party certification program O
4 reduce the number of overexposures in the radiography industry?
5 Yes, we feel it would have an effect on the number of a
3 6
i overexposures by all radiographers meeting this minimum qualifi-g 4
7 cation requirement upon initial certification the entire radiation E
8 safety program will be upgraded.
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Would a third-party certification program motivate 0
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radiographers to work more safely?
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What elements in the present system or in the l
suggested alternative are particularly desirable or undesirable
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The present system we feel is undesirable because of the wide range of qualified personnel directly results in 21 overexposures.
The present system desirability is that there O
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program, personnel would be more knowledgeable, and direct
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2 results would be less overexposures.
3 Number five, if a third-party program is adopted, what 4
items should be included in the standard for determining the 5
3 competency of individuals to act as radiographers?
3 6
Our feelings are a minimum education requirement, on-o "e
the-job training, classroom training and demonstration of n
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practical abilities should all be included in the standard for a
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9 a certification of a radiographer.
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Six, if a third-party certification program is
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adopted, should it apply to individuals presently working as d
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radiographers or only to new radiographers?
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Our reply to that is present and new radiographers.
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The present ones are the ones involved in the statistics 9
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bearing the high overexposure rate.
T 16 y
Seven, if a third-party program is adopted, should i
17 certificates be issued to individuals for life or should there w
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g We feel there should be a definite periodic renewal 20 of certification and training.
The recertification could be 21l combined possibly with recertifications for other methods of
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nondestructive testing.
23 Would a third party certification program effect the 24 O
ability of a licensee to respond to variable manpower needs?
25 1 j
This would really have no effect as long as the l
l ALDERSON REPORTING COMPANY, INC.
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48 I
third party certifies only the examiner in the organization.
O 2
Nine, since a third-party certification program would 3
likely be based on cost recovery by a fee system, would the cost O
4 to the licensees of such a program be warranted?
5 Yes, we feel it would be warranted.
Also, the 6
certification of the organization's examiner could be combined R
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with the annual audit, where possible.
Cost for certification i
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8 could be eliminated by the NRC providing certification at each d
9 activity during the annual audit.
This in-house testing for sl 10 certification would provide a more meaningful practical exam
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12 with the actual equipment to be used at the organization.
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g 13 Which alternatives of the two discussed is preferable?
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14 Why?
Are there other better alternatives?
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b IS Our response to that is there may be better alternatives x
16 Ei other alternatives but as a minimum, radiographers should be us h
I7 required to meet a qualification standard, even if the examiner x
f 18 qualification or certification is not performed, the radiographer e-h I9 should meet this standard and evidence of this qualification n
20 must be kept on file.
21 Number eleven, with respect to the two alternatives, l 0 22
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ALDERSON REPORTING COMPANY, INC.
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I Some action should be taken against radiographers 2
on violations resulting or could result in overexposure ranging 3
from reprimand, suspension to disqualification.
As far as the 4
rights the radiographers have, that would be a legal aspect that 3
I would not care to comment on right now.
6 Would a small licensee, because of its size, bear a R
7 disproportionate adverse economic impact under a third-party N
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system?
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system and we cannot comment on that at the present time, but
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again, when the individual or the third-party simply certifies d
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an examiner in the employ of the organization, that cost could
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For those organizations interested in participating E
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estimated cost in implementing such a program?
h Without the finalized plans for certification, costs M
18 cannot be computed at the present time.
19 j
This is our comments on the certification, the third-20 party certification.
Thank you very much.
21 MR. SINGER:
Thank you, Mr. Wade.
I would like to O
take a fifteen-minute dreak at this poine in time and then I v111 23
open the meeting up to the attendees to either ask questions or O
"(makestatements.
We will take a break at this time.
25 f.
(Short recess.)
ALDERSON REPORTING COMPANY,INC.
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MR. SINGER:
We will resume the meeting at this O
2 time.
3 Any of you who would desire a list of the attendees O
4 could see our receptionist and give her your name and she will 5
g be sure to send you a copy of all the attendees at the meeting.
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6 Before I ask the audience to make their statements l
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or questions, I would like to briefly enlarge on some of the n
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things that were said by Mr. Jones in his opening address.
We, a
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for some time, at the Commission have worked on a number of the 10 areas that have been mentioned here during the course of the II discussion so far.
I: happen to chair a group that has a
g 12 five members of the agreement states that represent the council 13
- of all the directors of all the.2'6 agreement states and six of
.lm I4 us have worked on a number of issues which includes radiography
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15 certification.
We have also had put together an incident 6
reporting system which permits incidents arising and found in h
the field in any of the 26 agreement states and the 24 non-x M
18 agreement states be put into a computer and if there is any s"
19 j
indication that this is a generic type of thing, will get notices 20 of the bulletins out to all of the radiography licensees and let 21 them know the types of problems we are starting to notice.
In addition to that, we have looked at the possibility 23 '
of going to rulemaking and having the licensee provide locations O
"j of where he wi11 de during his 303 stees.
our uRc types of 25 inspectors don't know where you are when you are there and by f
l ALDERSON REPORTING COMPANY,INC.
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the time he gets there, you are--you will know that he is on his 2
way long before he gets there so that when he gets inspection 3
history in spite of all of these things, you wonder what the G( /
4 multiplier would be were he there unannounced and unexpected 5
y and we are working on that basis also.
6 We have had an extensive amount of work on the R
7 establishment of performance specifications for the camera.
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8 This thing has gone through public meetings and has gone through r) i 9
a number of iterations and is still up in the air because there 10 is a number of intangibles involved, it would mean, should we 5
II be able to get a rule change which required performance is g
12 specifications as stipulated by our best understandings, it
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'3 wou1d cerea 1n1y be of eome considerah1e cose to some of the m
I4 people involved.
We think it would be worth doing that and 15 we are pursuing it and we are going through the normal kinds iE I0 of things that go on in Washington to try to get the thing us h
I7 through, but there are a number of separate issues that are f
18 currently involved in trying to find ways of reducing the I9 8
overexposures in radiography and we have not found any really n
20 simple solutions to any of these things; so, anything, any 21 thoughts you have other than what we are concerned with here O
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would be happy to receive your comments.
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- l This meeting, however, is on certification and we 25 will confine the discussion to those elements.
Is there anybody
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in the audience that wishes to make any statements or ask any O
2 questions, you may do so at this point.
3 State your name, please, and representation.
O 4
MR. BERRY:
I am Francis Berry with Chicago Bridge 5
and Iron Company.
I met Mr. Jones before when he made his 9f0 presentation to the American Society for Nondestructive Testing E"
here in Atlanta a year ago.
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8 My question is, would it not be more beneficial both d
f to the public and the NRC and to the licensee if NRC would S
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concentrate on the review of the training material that was
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third party in jeopardy as far as legal action was concerned?
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MR. BASSIN:
If I understand your question, are you 6
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- a
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MR. BERRY:
Our company now has what we think is one 20 of the best training programs in the business as far as licensing 21 our radiographers, very much as the other one described here l O 22
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present a program to NRC for review.
Now, as I told Mr. Jones, l
0 ALDERSON REPORTING COMPANY, INC.
53 I thought that this was one place that the NRC could control 2
what the man is taught inasmuch as if this program incorporates 3
all the necessary items of safety and then by an unannounced
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4 audit, determine whether these people are doing this or not.
j I am sure you couldn't do it for everybody but on a spot basis 3
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a licensee would never know when he would be audited and it E"
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at less cost than what we are talking about here.
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individual radiographer, the time constraints involved.
- John, b
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do you have any comments on that?
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16 MR. POTTER:
Yeah, well I think that in general we i
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of hours; it is not a matter of regulatory requirement, perhaps 20 it should be, but one of the problems we have in an inspection of 21 radiographers, as in the case of numerous other licensees, is O
where should we allocate what few resources we have and I think 22 23 l in the areas of radiography we have found that trying to do a
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number of unannounced field inspections has been very time con-25['
suming unless:the firm is large enough to have a continuous l
I ALDERSON REPORTING COMPANY, INC.
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radiography program and it is very difficult to catch radiographers
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2 in the field even though with the 241 system, we have notification s
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4 Many times you go out there and you find that things have changed 5
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radiography problems versus many other categories of licensees.
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MR. BERRY:
My only statement was that if you have E
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accomplish anymore toward this audit than you are able to do T
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through the NRC at the present.
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to the penalties involved for those using them or misusing the_
20 isotope in the field rather than trying to have somebody go for 21 a license like you go to get an automobile license, that doesn't
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keep you from going out and having an accident if you are going l
23 to be careless with it.
There is no way to insure without 24 O
supervision, and that supervision has to come from the company 25 '
that is using it rather than a third party.
i ALDERSON REPORTING COMPANY,INC.
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MR. SINGER:
Thank you, are there any other--
O 2
MR. JONES:
I would like to make a comment.
3 MR. SINGER:
Okay, fine.
O 4
MR.,0,ES, I thinx there wou1d be a 11tt1e bit o, 5
confusion about the third-party certifier and exactly what kind 6
of possibilities a third-party certifier would have.
That is R
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r it, I don't think the third-party certifier would take any N
8 responsibility away from the licensee.
All a third-party 0
certifier would do would verify every radiographer out there 10 had certain minimum competence but it is still the licensee's fII responsibility to make sure that when someone is using sources NI under their control that they use them properly.
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b board who set that certain minimum qualification which is all the x
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18 or something but I really don't see as an objection to the s"
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system how it would actually effect or minimize the responsibility 1
20 of any of our licensees.
I MR. SINGER:
I think one of the major problems we O
face in going to any form of certification was to determine who 23 l would be representative of the industry.
The most disparate
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unified organizational aspect.
The ASNP said that they couldn't O
2 be representative of all the radiographers.
fr.It was just one 3
part of their total problem and they would not be a very subtle O
4 representative for.
yo,,A is a sma11er out,1t that we ta1xed j5 about earlier that sent in a petition, I believe they have 9
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something on the order of 89 members, and they didn't come up R
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with any feeling that anybody would be representative, certainly a
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they wouldn't be and that is part of the real issue and part of 0
the thing we are trying to explore in these public meetings, just 10 who would be a third-party that would represent the industry.
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II Most of the things, as Jim just got through remarking on is f
12 physicians, they are Board certified through a group of their O i is peers who are recognized for eheir. competence and have set up -
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15 and things of that nature for those people to become Board certified.
Our reporter is Board certified by a number of her h
peers and when I say that, those of you who have,given papers,
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Arnold so she can have it for her records.
But that is part of 20 our problem in coming to you with these public meetings is to 21 determine who could represent you, who would represent you, how 22 O
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23 before we go any further than we already have.
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4L we xnow that there are a 1 arse voeu1ation out enere 25,
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that are sending in good training programs that are written by O
2 contract.
We find that there are a lot of things that we 3
receive in writing that aren't necessarily representative of 4
what's actually being done.
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Now that is not true for many, and especia11y those 6
organizations that are we11 established, we have some of those E"
represented here.
We are not suggesting that you peop1e aren't Nk 8
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that you do, but you are a small minority.
Most of the outfits 5
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are sma11.
Very highly competitive as I said earlier and we are
=hII very distressed.
In a meeting in Odessa, Texas where there was 12 accusations made of all types not worth relating at this meeting, Oi' due there were wives of rediographers that got ug end said that E
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they were concerned about the fact their husbands were working ie 9
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in radiography and didn't understand anything of radiation and i
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didn't give a damn one way or another about it, and this sort of h
brought it home to us that maybe all this training didn't have
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persona 11 zed understanding.
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We asked some of the radiographers, most of them were 20 at the high schoo1 leve1, if they understood the latent affects l
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and trting to get the understanding of latency to a high schoo1 1
O graduate was e shore fa11 1ese1f end thee is rare of the prod 1 ems 23l that you peop1e are very fami11ar with.
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concern that we have in trying to be assured that those youngsters 25 ]I or oldsters as the case may be who are working in the fie1d have l
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a minimum understanding of radiation effects to themselves as 2
well as others.
3 Are there any other people that wish to make statements
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4 this morning?
MR. RUMRILL:. :
I just feel compelled in a meeting of U
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this sort to get up and speak even if I ramble a little bit.
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7 MR. SINGER:
Would you identify yourself, please?
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8 MR. RUMRILLt-Yes, I am David Rumrill.. I am with dd 9
Law Engineering Testing Company in Atlanta.
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Several comments that were made by the representative
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of our company at the beginning and I heard other comments d
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suggested a regulation for enforcement of requirements, minimum
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training periods and minimum requirements and I heard the E
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far as the NRC requirements are.
I have heard recommendations 16 and I have heard other gentlemen say requirements.
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18 requirements in how the individual examiners or the NRC Board
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members of the agreement states enforce those when they are 20 reviewing a licensee's proposed program and say well this meets 21 our recommendations or not.
If they are indeed, going to be O
22 requirements, make them requirements as far as training programs.
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The other comments I would like'to make relative to O-24 the third-party system, if implemented as I am hearing several 25l of the gentlemen on the panel speak, would be in a manner similar I
i ALDERSON REPORTING COMPANY, INC.
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I to other related aspects of our industry:. int.that there are
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2 some other testing and certification programs that test a 3
minimum competence level.
They are all written tests.
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4 Written tests have some drawbacks in that you can't impeach the test or impeach someone who passed the test.
It at least a
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2 gives some general feeling throughout the industry that at h
least for someone to past that test or be certified at that n5 8
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minimal level.
It would still be up to the company, the g
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responsibility for them to perform that work correctly.
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One of the last items, and I think really the under-d 12 tone of all of this is that you again can't legislate honesty 3
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of the overexposure incidences are.
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the people are if they are not observing your operating T
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emergency procedures properly and taking shortcuts, I can see d
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individual doing the work that hey, I have got a. code of ethics 20 to follow, I may or may not have some civil penalties that would l
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come directly home to me, I have gone outside of my company and
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both taken something that is tested to at least the minimal 23 '
qualifications I have got and I am recognized.
Regardless of 24 i O
whether we as a company had an internal program before to also 25 l
qualify these people to some of these same levels, and this has i
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served to hit home to the individual where I have found cases that he seems to take that responsibility a little more seriously and a little more heavily because it is not bestowed hLa by the l
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company no matter how rigid the program is.
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5 Finally, one of the comments we were asked to comment M"
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on was would this impose a hardship in response to work in:
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industrial radiography; yes, if there were only certain times n
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of the year that the examinations were given to certify as o
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radiographers.
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type audits of a firm, but if that w'ere implemented I would make 14 "s
this one suggestion to keep from impacting too heavily on 9
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responding to radiographic operational demands and that would be T
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that this third-party system certify the radiographers and that d
17 the company be able to certify radiographer assistants.
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is required not only to be instructed in those procedures but to 23,
be instructed in radiation safety and e x amined by the company
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currently.
This would transpose directly over to a third-party 25 j system and again, the third-party system would have nothing to 1
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do with instructing an individual or determining his competency
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2 in that company's operating and emergency procedures, so if the 3
i company was able to establish a base of radiographers, and I
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4 think generally companies would agree that their radiographers, 5
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going to stay with them, then they could respond to manpower R
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radiographer.
Those are my comments.
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MR. SINGER:
Thank you.
Yes, sir?
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MR. CRABTREE:
My name.is Donald Crabtree and I am E
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with Combustion Engineering, Incorporated in Chattanooga, i
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g Tennessee.
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responsible for radiation safety program at our plant and w
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during this ten-year period, I would estimate that we have
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l hade between eight and ten thousand exposures using isotopes 20 and during that period we have not had a single overexposure 21 of as much as 5 rems to any person.
In fact, we have had only
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one exposure that was in excess of 1-1/4 rems.
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I think that this is a good program, a safety program 1
j 24 record and we are proud of it and I would like to state that I i
25 think that our record is a result of an overall strong safety 1
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program and it has already been said here that the training and O
2 ehe testin, is 3u,t a sma11 part of that program, and you have 3
to have a strong overall program and good management support, O
4 ehen you writ have safety.
If you don e have thae, you won e 5
g have safety no matter how many agencies test your people, so 9
6 I am against third-party testing.
I don't think it is the answer R
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to the problem.
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8 I do have a question while I am on the floor here.
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9 The information that we received from NRC talked in percentages.
5 10 I would like to have some numbers about how many incidents 5
II actually involved exposures of more than 25 rems and how many is I
involved exposures of more than 5 rems.
I think that if you Oi' look at some of the numbers and the amount of. activity that we m
I4 have in our industry, then the overall record is not all that 15 bad.
After all, there are some industries that kill thousands ij 16 of people every year and I don't think our industry is doing us h
I7 that.
f 18 MR. SINGER:
Do you want to respond to that?
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I9 MR. JONES:
Okay, the record we have from the year n
20 1971 to 1980, for the overexposures greater than 5 rems, there i
21 were 84 total, 52 radiography.
Of those exposures greater than 22 25 rems, 18 overall, 15 radiography.
23 MR. CRABTREE:
Thank you.
24 MR. SINGER:
Any further?
25 i
MR. MOBERG:
Al Moberg again, Newport News.
I wonder ALDERSON REPORTING COMPANY, INC.
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along the same line of statistics of those exposures, is there
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2 anyway of determining whether a lack of training or improper 3
testing was a factor, so that we might have some feel for
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4 whether certifying would help or were most of these carelessness e
5 or violations of existing rules?
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MR. ? OTTER:
Well, we have some publications on R
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radiography overexposures.
I guess most of you have probably a
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seen them.
This book here (indicating) was distributed.
I am 0d 9
not a statistical analyst of the causes of these things but ioy 10 just talking with people over the years, it appears that most of 5l 11 the time an exposure occurs because the radiographer is either a
j 12 working long hours or under a deadline of some kind or he gets E
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'some kind of equivalent malfunction or he takes a short cut and.
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15 he has got a problem and shut down the whole construction site, 5
j 16 he will try to figure some way to get that source back in its e
d 17 shield.
A lot of them don't have what I call emergency kit for E
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. handling these disconnects and jad2 sources.
I think that if.:more 5[
19 radiographers carried a couple of bags of lead shot and a shovel n
20 with them, they could stabilize the situation pretty quickly with 21 temporary shielding and the rest of the construction work or 22 maintenance work could go on in the plant for a long time until 23 ;
somebody arrived better equipped to recover the source, but I i
24l think some radiographers don't want to get too involved in that
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and they had rather try to get it back in a hurry and other
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radiographers don't want to carry the survey meter with them at O
2 all times because they have got three other things to carry, 3
a roll of masking tape and film, and some other items and they O
4 don't have enough hands to carry everything so they leave the j5 survey meter behind.
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6 Other radiographers probably if they carried a dual R*E 7
measuring system, a chirper, one of the small band held rate s
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meters in addition to a pocket meter, with an alarm on it, would a
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avoid these problems.
10 I think most radiographers, if they get in trouble, 5
II are experienced, most of them have been around for several years k
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?2 in the business, I think they know what is correct.
They don't 13 do it because they get in a hurry.
Sometimes familiarity with t
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risks breeds contempt or hazards and I think that certification 15 or licensing of this industry is about like occupational licensing j
16 in maybe a hundred other industries.
At the state level in w
h 17 Georgia occupational 1?!1icense s6me.80 businessesaand professions.
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Whether or not occupational s"
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licensing really improves the safety record is questionable.
We 20 license everything from barbers to morticians to cosmetologists.
21 It is debatable.
Some of you perhaps have seen the contractor
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study done for NRC by a psychologist from the University of 23 Florida in which the literature weuld indicate that it is t
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questionable whether occupational licensing of any profession 1
25 (i! really reduces the risks to the public.
I think in some cases l'
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ALDERSON REPORTING COMPANY, INC.
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the old caveat emptor rule still applies and it's important that O
peop1e he aware that there are other remedies outside of the 2
3 occupational licensing process.
4 MR. SINGER:
Thank you, John.
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Any other statements?
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Since there is no other presentations, I am going to R
8 7
close the meeting.
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8 I believe that we have had a very useful session.
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would like to thank all of you for coming.
10 I would like to request that any of you that have 5
l 11 not responded to our questionaire, beJsure lo do so.
You may is j
12 submit your comments or suggestions to the Secretary of the r
E O j 13 Commission, U. S. Nuclear Regulatory' Commission, Washington,
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20555, attention Docketing and Service Branch.
So, with 2
15 that request, I want to again thank you for your attendance and s
j 16 participation and this meeting is closed.
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17 (Whereupon, at 11:20 a.m.,
the public meeting was 5
M 18 closed.)
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ALDERSON REPORTING COMPANY,INC.
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l C _E _R T _I F_ _I C A_ _T E_
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This is to certify that the attached proceedings i
3 before the NUCLEAR REGUIATORY COMMISSION in the matter of:
4 THIRD-PARTY CERTIFICATION OF INDUSTRIAL RADIOGRAPHERS, 10 CFR i
PART 34 5
j Date of Proceedings:
June 8, 1982 n
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Docket No.:
Public Meeting N
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Place of Proceeding:
Atlanta, Georgia E
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Were held as herein appears, and that this is the original N;
9 transcript thereof for the file of the Commission.
v.
Oy 10 s
II ROSE ARNOLD, CVR, GCCR No. A-8 S
Official Reporter (Typed) 12 j
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Official Reporter (Signature) e E
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