ML20054M716
| ML20054M716 | |
| Person / Time | |
|---|---|
| Issue date: | 06/17/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| FRN-47FR19152, RULE-PR-34 NUDOCS 8207140292 | |
| Download: ML20054M716 (59) | |
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PUBLIC MEETING CERTIFICATION OF INDUSTRIAL RADIOGRAPHERS
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DAS: June 17, 1982 PAGES: 1 thru 57 gm.
Chicago, Illinois i
U.DERS)X REPORTING f.
400 Virg d a Ave., S.W. Washin g::, D. C.
20024 d
Talachene: (202) 554-2245 sco-*140; m ame:
1 U:!ITED STATES 07 A:iERICA
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!!UCLEAR REGULATORY CO?!!!ISSIO:I 3
CERTIFICATIO!! 0F IIIDUSTRI AL RADIOGRAPHERS O
4 PUBLIC MEETI:iG e
5 Nuclear Regulatory Commission U
Americana'Conr,ress Hotel
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6 Chicago, Illinois R
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Thursday, June 17, 1982.
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The Commission met, pursuant to notice, at 9:00 dd 9
o' clock a.m.
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10 3EFORE:
E 11 BER!TARD. SINGER, Chairman of'the commission 38 JA!!ES JONES, Commissioner ti 12 13 s
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2 CHAIRitAN SINGER:
Let's start with the meeting 3
now.
My name is Bernard Singer.
I an chief of the certifi-4 cation procedures from the office of material, safety and e
5 safeguards o f the U.S.
Nuclear Regulatory Comnission.
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will be the chairman for this meeting, e
7 On behalf of the Nuclear Regulatory Commission, Z
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I welcome you to this public meeting on the third party dd 9
certifica. tion of industrial radiographers as an alternative b
10 to the present system of permitting radiographer licensees 3
5 11 training. designated individuals as radiographers.
radiographer certification program will insure the radio-l graphers who work out in the public are trained in safety, 24 how to operate during an emergency and those kinds of things that would be necessary for them to operate equipment ALDERSON REPORTING COMPANY. INC.
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safely.
It will be interesting to know whether the cresent 2
system does that or whether the third-party system could do 3
it better.
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!Iumber two, regulation is often discussed and g
5 I am sure we will get comments on both sides here.
The 8
6 third-party certification program will reduce the number R
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of over-exposures in the industry.
Some say it will and 8
8 some say it will not.
It will be interesting to hear your d
9 comments.about how you feel, e
10 Number three, would a third-party certification II program motivate radiographers who are working?
This was k
f I2 very questionable.
As a matter of fact, we have a contrac-13 tor who did a study'for us who said that it would not.
l 14 It will be interesting to hear what your comments on that
$j 15 subj ect are.
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I0 Four, what~ elements in the present system or in w
h I7 the suggested alternative are particularly desirable or z
18 undesirable and why?
Here, we are interested in hearing I9 8
what is good about the present system or what is bad about n
20 it.
The third-party certification system, what is bad about 21 that?
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Five, if a third-party certification system is 22 23 adopted, what items should be included in the standard 24 for determining the competency of indivuals to act as 25l radiographer 1?
Again, any certification program, of course, ALDERSON REPORTING COMPANY, INC.
11 1! will be based on a standard performed, what is going to be k-2 expected.
It will also be the basis on which any third part7 3
should work by.
It will be interesting to know what kinds O
4 of things you think should be in that standard, such things g
5 as should there be on-the-j ob training required.
Those are 9
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the kinds of things we will be interested in knowing what R
7 you think shooli be in the standard that will be developed.
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8 Number six, if a third-party certification program d
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is adopted, should it apply to individuals presently working ?
g 10 Again, this concerns individuals who are working and continu -
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II ing to work without certification.
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12 Number seven, if a third-party certification pro-(j d
13 gram is adopted, should certificates be issued to individual s m
l 14 for life or should there be periodic renewals of certificati or 15 Again, it will be interesting hearing views on that.
g 16 Number, when a third-party certification program w
h I7 affects the ability of a licensee to respond to variable z
y 18 manpower needs.
This is a key question. We know that a p"
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lot of radiography-firms have manpower on contract.
n 20 Number nine, since a third-party certification 21 program would likely be based en the costs recovered by a b
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(~f fee system, would the cost to the licensee for such a pro-23 gram be warranted?
Since we will have to do a proposed
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24 ruling on the impact of that statement, I am interested to 25 '
hear comments concerning third-party certification, what it ALDERSON REPORTING COMPANY, INC.
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1E 1! will cost.
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2 Mumber ten, what alternatives are there?
If there 3
are better ones, please explain.
This one was added pri-O 4
marily because it will be interesting to know if there are g
5 better ways of accomplishing what we really want to do to E
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increase the assurance that the radiographers out there R
7 are properly trained.
We have already ruled out the licensing:
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because of the government constraints on us.
So if there d
9 are other ways we would accompli.sh the same thing, it will h
10 be interesting hearing that also.
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II With respect to the two alternatives, what kind of 3
y 12 enforcement action could and should be taken against radio-E w
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graphers?
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14 What rights to radiognaphers have with respect to 15 such enforcement action?
It is presumed that any certifica-g 16 tion program system would be developed which would take w
h I7 some kind of action against a radiographer that continues x
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18 to act in an unsafe manner who doesn't follow directions or
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operating procedures.
We are interested in what kind of n
20 programs should be set up to accomplish that kind of system 21 and what rights radiographers have in enforcing the issue.
22 Number. twelve; when a small licensee,- because of 23 its size, bears a dispropertionate adverse, economic impact
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24 on a third-party system.
We asked this particular cuestion 25l because this would indicate what kind of impact this would ALDERSON REPORTING COMPANY, INC.
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have on a small firm or small licensee.
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2 you what you feel would be the impact on a small firm, a 3
small licensee compared to a large firm.
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4 Organizations that are interested in participating g
5 in any third-party certification program, what would be 9
6 the estimated cost to implement such a program?
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we are interested in hearing from firms that are interested M
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in participating in a third-party certification program.
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9 At this point, we do not have any firms that definitely say Eg 10 they are willing or interested in presenting a program to us E
11 as to how they could develope such a program.
So it will 3
y 12 be interesting to hear from-those kinds of firms and also l()
13 to hear from them, what kind ~of costs would be involved h
14 in this.
15 Those are the basic issues to which I would like d
16 to' discuss.
We are also interested in hearing comments e
17 on any other aspects of problems that we may have overlooked m
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18 Thank you.
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THE CHAIRMAN:
I will now ask Mr. Bassin to discuss n
20 current licensee requirements and policies for radiographer 21 training.
22 MR. BASSIN:
The regulations in 10 CFR Part 34 23 are designed to elicit information in three maj or areas
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24 which constitute a radiography program, one, the management 25 control and administration program.
Two, the operating ALDERSON REPORTING COMPANY. INC.
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I and emergency procedures which would be used by radiographer-3
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2 and radiographer's assistants.
Three, the training require-3 ments and the kind of information which needs to be included
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4 in entering the pre ram, 5
g This morning, I would like to discuss the require-9 5
0 ments and the kind of informati6n which needs to be provided R
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with respc:t to training personnel.
0 Section 34.31 of 11 B of 10 CFR Part 34 states that d
an application for specific licenses will be approved if o
h the applicant has had an adequate program for training radio
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f graphors and radiographer's assistants'and submits a schedul ed N
discription of such programs which specifies one, initial
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training.
Two, periodic training.
Three, on-t he-j ob t rain-E 14 w
ing, Four, means to be used by the licensee to determine 9
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the radiographer's knowledge and understanding of and u
ability to comply with commission regulations and licensing requirements and the operating.
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18 Five, names to be used by the licensee to determine
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the radiographer's assistant's knowledge, understanding l
20 an ability to comply with the operating and emergency proce-21 dures of the licensee.
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In a more specific manner, Section 34.31 of 10 23 CFR Part 34 deals with training requirements for radio-h 24 Q
graphers and radiographer's assistants.
For an individual 25 I
! to be designated as a radiographer, he must, one, be ALDERSON REPORTING COMPANY, INC.
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1 instructed in the subj ect s outlined in Apendix A of 10 CFR
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2 Part 34 Two, he must receive copies of and instructions 3
in NRC regulations.
The NRC license underwhich the radio-4 grapher would perform and the licensee's operating and g
5 emergency procedures.
Three, the individual must demon-N h
6 strate competence to use radiographic exposure license, R
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7 seal sources, related handling tools and survey instruments.
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Four, must demonstrate an understanding of the dd 9
topics in Apendix A by successful completion of a written Y
10 test and field examination. For an individual to desig -
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11 nated as a radiographer's assistant, he must, one, recieve k
i 12 copies of and instructions in the licensee's operating and s(e) 3 13 emergency procedures.
Two, demonstrate a' competence to u
l 14 use, under the personal supervision of a radiographer, 15 radiographic exposure devices, sealed sources, related handl g
16 ing tools.and radiation survey instruments.
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17 Four, demonstrate an understanding of these matters
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18 by successfully completing a written or oral test and a field F"
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examination.
n 20 The requirement that a radiographer's assistant 21 must demonstrate competency to work under supervision of a Oh/
22 radiographer in the context the recuirements are intensive 23 in 10 CFR Part 34 means that a radiographer must physically
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24 present in watching the radiographer's assistant when he is 25l using radiographic exposure devices, performing surveys l
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1' other than the surve.v to determine the perimeter of the
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2 restricted area and any other actions which a radiographer's 3I assistant must take which involves radiographic equipment
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4 and all exposure devices.
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The requirements of the agreements are essentially 9
6 the same as those in the NRC regulations.
The regulatory R
7 guide, 10.6 guide for preparation of applications for the j
8 use of
' seal sources and devices for performing industrial d
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radiography, training programs are discussed in greater 10 detail and guidances provided as to the type of scope of i
II information which should be included in training program 3
g 12 discriptions.
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13 Firstly, the narrative discription of the entire u
l 14 training; program should be provided.
With respect to the 15 training of a radiographer's assistant, number one, the j
16 detailed outline of the matters covered in the new training w
h I7 including topices in Apendix A and the approximate time 18 to be spent on each maj or area of instruction.
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Instructions should be provided.
We suggest and n
20 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 21 the formal portion of the training program.
There are 22 some outside service organizations which provide part of 23 the training, particularly in radiation and radiation safety
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24 topices.
25l If the application choooses t o ut-iliz e t he services ALDERSON REPORTING COMPANY. INC.
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I of one of these organizations, he should provide a name O
2 or names of each. organization so that we can be sure that 3
the program offered by the outside source organization O
4 has been reviewed by the.'IRC or in agreement state to 5
l, determine its adequacy.
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0 Since these outside service organizations cannot R*S 7
provide instruction in a particular licensee's operating g
O and emergency procedures, equipment and facilities, these d
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matters must be specifically provided for by the licensee 10 and the instruction which would be given in these ares, II should be fully described in the training program discrip-a g
12 tion.
- OE 13 Discription of the on-the-j ob training should be I4 provided.
That is that after an individual has become a 15 radiographer's assistant, when he is actually eligible to Ib use it, licenses and so on, the program should be fully h
I7 described and-.any matters which radiographers might~be z
IO responsible for such source exchange, inspection, maintenance s.-"
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of equipment.
These matters should be covered in another 20 job training and described in the training program discrip-II tion.
We recommend that as a memo, three months full time 22 equivalent should be. spent in on the job-trainining.
Finally, a copy of the examination which~would O
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consist of approximately 50 questions or more, covering 25l all items in Apendix A, should be submitted together with I
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I' an answer to the examination, the passing grade and an addi-7"T
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2l tional discussion which will be given in those areas where 3
the examination indicates weakenss on the part of the
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individual.
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For radiographer's assistants, the ma,Jor elenent 9
6 is the instruction which will be given in the applicant's R
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operation and emergency procedures and eouipment.
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should be fully described andthe amount o f time which will d
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9 be spent on this kind of instruction should be provided.
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10 A copy of the examination which will be given to test the
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5 II understanding of the operating and emergency orocedures a
g 12 and equipment together with the answer to the examination,
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I6 The examination for a radiographer's assistant w
I7 should be either w71tten or oral and should consist of x
IO approixmately 25 c.uestions.
If an oral examination is P"
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given, it should be wriitten 'out for purposes of oroviding n
20 the NRC with thet kind of information.
2I Many firms hire persons who have had previous 22 traini,ng and experience with another licensee.
It is the 23 licensee's responsibility to make his own determination
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24 of competency of each individual who acts as a radiographer.
25 Therefore, information should be provided in detail concernine I
ALDERSON REPORTING COMPANY, INC.
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I instructions which will be given in the licensee's operating
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and emergency precedures and equipment and the needs that 3
will be used to determine competency of that individual
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4 to act as a radiographer.
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There is a requirement for periodic training, and 8
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we suggest that this be conducted at least annually.
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information provided should include a discription of the s
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content of the periodic training course which would be d
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for the purpose of insuring that the knowledge and proficien :7 i
h 10 of radiography personnel and regulations, procedures,
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5 II policier and equipment, is current and up to date.
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I2 An important aspect of any' training program of f)g 13 e
the instructors who will' provide the training, we ask
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l 14 that the instructors in the training program be specifically 5
15 designated by name and a discription of the qualifications, d
16 radiation and radiation safety and the use of seal sources e
h I7 and devices in the performance of the industrial radiographe r
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18 be presented.
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As a minimum, instructors should have aualifications n
20 that are at least equivalent to those of a radiograoher and 2I have experience beyond the minimum rec.uired for a radio-k'D C
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grapher.
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In the event a radiographer certification program
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24 js adopted, it vould no longer be necessary to provide in-25 formation and the detail I have described.
It might be ALDERSON REPORTING COMPANY. INC.
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necessary that some information be submitted which yould U
'2 be limited to those matters which a third carty could not 3
provide testing for.
For example, instruction in operatinz 4
and emerr;ency procedures.
This outlines briefly the current 5
g training requirements and the regulations and the kinds of e
6 information which will be provided in training discriptions.
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Thank you.
3 8
8 THE CHAIRMAN:
Our commentor will be Marty Simmons, d
9 representing the State of Illinois.
He is the manager of e
h 10 the program for the Illinois Department of Nuclear Safety.
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II MR. SIMMONS.
First of all, I would like to point is y
12 out that the State of Illinois does support and go along b
O* j 13 with the conference of radiation program directors' ad hoc I4 committee in support of certification testing programs for 15 radiographers.
We have been considering in the State of g
16 Illinois for a number of years this type of program.
es I7 Presently, within the state, there are roughly 18 670 X-ray radiographers and 240 radiographers.
Of course,
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the ran radiographers are going to be t he ones called n
20 X-ray also as well as ram.
One of the reasons why we I
got involved is that from my cwn information, what I J
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found out from a regional representative is that the 3{ individual radiographers are not that knowledgeable of
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what they are doing, how they are performing, why they 25 are doing what they are doing.
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The usual one is one who has maybe had a high O
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2 school education.
Actually, the average education of a 3
radiographer is the 10th grade.
They are brought in and
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4 it is said, All right, you are a radiographer. Press the e
5 button and do this and that.
If you have a film to develop, h
6 develop it.
Know exactly what you are doing.
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There has been no training, specifically, on safety,
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8 They may know performance-wise.
They may have training d
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on that.
As far as safety aspects and what is radiation, g
10 etcetra, they are not knowledgeable in that respect.
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11 We feel, and we have been requiring in certain facilities 3
j 12 in the Stat.e of Illinois that training be improved for 5
) y 13 radiographers.
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14 A good example of some of the problems we have run 15 into recently, we h.ad one radiographer receive a 15-ram d
16 exposure.
What happened was the particular x-ray unit w
l 17 was r.ot operating so he locked the door, entered the facili-
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18 ty and went over there to x-ray.
And fortunately, he did
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have certain equipment.
The next thing he knew, this audib1 e n
20 was going and he quickly got out of there.
21 What had happened was that the radiographer should f
22 not be working with that particular x-ray unit.
He should 23 l be trying to prepare that unit.
He does not understand
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24 it.
I do feel, and our department definitely feels that 25 radiographers should be certified to a testing program that L
ALDERSON REPORTING COMPANY. INC.
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1.s adecuate and that is universal.
One that could cover
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2 everybody.
The State of Illinois would like to have the 3
testing program proposed by the '!RC to be for both x-rays G3 as well as gamma since all radiographers out there are e
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going to be doins both to begin with, and they should N
6 be knowledgeable of the safety procedures.
They should have E
7 some health physics knowledge, as far as I am concerned, N
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as well as safety.
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10 of Illinois is that they have a transportation, per se',
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being conducted on state police.
They are doing enforcement d
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of these programs.
It is concerning the transportation
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of radiographer materials in the State of Illinois.
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14 have stopped numerous, I should say, radiographers. The z
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questions asked by the state troopers to these radiographers
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16 have elicited responses of, " Gee, I don't what amount, 17 a
what size source they have here."
They really are not x
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knowledgeable.
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And if you notice in their operating emergency 20 l
procedures, it doesn't tell them anything about transporta-21 tion safety requirements.
Unfortunately, they are really
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22 not that knowledgeable of transportation.
We found out i
23 that these people are not going to be doing it. So we do
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24 support the testing program.
25 We advocate a third-party certification program.
ALDERSON REPORTING COMPANY, INC.
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There should be something on the grandfather clause.
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should be renewed over a five-year period.
And the people 3
who are in the realm right now, that we take 20 percent b) 4 the first year and 20 percent the second.
And after five e
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years, all.of the people will have been tested.
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That is my particular philosophy of our depart-n 8
7 ment, and we do advocate this.
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THE CHAIRMAN:
Thank you.
Do you have any question s' d
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g MR. JONES:
No.
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10 THE CHAIRMAN:
Our next commentor will be Harold z=
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T.
Graber, representing Babcock and Wilcox.
He is a d
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radiation safety officer for Babcock.
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'J-a 13 MR. GRAPER:- Thank you, Mr. Chairman.
My name is E
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Harold Graber, and I am a radiation safety officer for the 2
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Nuclear Equipment Division of Babcock-Wilcox company which 16 is a McDermott company.
G 17 McDermott is incorporated as a leading international wz l
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energy service company.
The company has subsidiaries that
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provide engineering and construction services for the off-20 shore oil and gas industry and manufacture stean-generating l
21 equipment, tubular products and insulating products.
O 22 Domestically, the overall company employs some
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23, 50,000 men and women in 35 locations. Babcock and Wilcox i
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24 Company has various manufacturing and construction facilitie s
25l operatin5 under licenses for industrial ~ radiography issued I
ALDERSON REPORTING COMPANY. INC.
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issued by the NRC or applicable agreement states.
We appre-O 2
ciate the opportunity to make comments in review of this 3
advanced notice proposed rule making.
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Not knowing what the exact details of the third-5 g
party certification program would consist o f -- sometimes, 9
6 it is not too easy to be obj ective in making comments to R
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the program.
My presentation here today, I intend to sl 8
respond to the 13 questions that were proposed in the df9 federal regulations, and I will go through them as follows.
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10 The first question is, Is training provided to the
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II radiographers under the present system adequate?
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12 We beleive the training regulations as specified
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j in 10 CFR Part 34, paragraph 3411 and 3431 as mentioned by l
14 Mr. Bassin this morning is more than adequate to provide 15 the necessary and training.for an individual to perform j
16 as a radiographer.
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I7 Possibly, a significant omission in the regulation a
f I0 is the lack of identifying specific hours for both in I9 l
8 the class room and on-the-j ob training.
As Mr. Bassin i
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indicated, they do identify a suggested mininum, 21 As far as the recomnendations are concerned, as t
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Ir far as the necessary hours of instruction, we certainly 2
l suggest that possibly a consideration should be given (3
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l to those facilities which are fixed facilities and those 5 !
facilities which operate under fixed conditions as well as ALDERSON REPORTING COMPANY,INC.
23 I ' in the field.
Certainly, there are ocassions that come A
2 under federal conditic*s that don't necessarily come up up 3
under operations that are in a fixed facility.
4 The third question was, Will a third-party certifi-g 5
cation program reduce the number of overexposures in the 9
0 radiography industry?
We believe certification programs R
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do not prevent overexposures.
Overexposures are prevented 3
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by an ambitious safety awareness program by the licensee df9 whereby radiographers are monitored by supervisory nersonnel 10 on a frequent basis, periodic refresher training on a
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h II frequent basis and re-examination and re-testing on a fre-a quent basis.
[ ()i 0 13 Again, the frequency is somewhat arbitrary.
Will E
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a third-party certification program motivate radiographers 9
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to work more safely?
Motivation, as we see it, certainly x
I0 is dependent upon the rules of the program.
If a radiograph er 6
17 j found guilty of a violation, no over exposure incident, was ax b
IO his certification would be revoked and he no longer would be E"
19 j
permitted to perform radiography.
20 It is also assumed that loss of certification would 21 be just cause for discharge.
Disciplinary action for over-i(
22 exposure can be administered under the existing program.
23 We're strong advocates of disciplinary action and we include
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24 it in our' radiation safety program.
25 What elements in the present system or in the ALDERSON REPORTING COMPANY, INC.
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suggested alternative are desirable or undirable and why?
2 The present system, as we see it, is adequant with the 3
recommendation the commission address the strengthening O
4 of those e1emente end come1e1ons pre 1ous1y mene1onee.
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That is training, supervision and safety awareness programs.
6 This syste-is highly desirable for those licensees which R
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operate in fixed facilities such as the license that I Ml 8
particular work under.
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Affixed facilities have management controls over o
h 10 the personnel and administration, the total radiation E
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safety program.
g 12 A field operation, a radiographer operates with mini-( LG 0 13 j
mal management direction.
So certalhly, emphasis needs to 14 be placed as far as management controls and field operations 15 g
We believe that the proposed system, that is the third-z 16 party certification under facilities such as ours or a h
I7 company such as ours, my particular facility operates with 18 approximately 40 or 60 radiographers that are involved in a s"
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radiation safety program.
O Radiographers and radiographer trainers are all I
personnel and members of a bargaining unit.
As a result of the company union agreement personnel must be certified and qualified before being awarded a position.
A third-party j
O 24 certification program would add significant impact due to delays and getting personnel certifying and costs involved ALDERSON REPORTING COMPANY,INC.
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I with outhouse certification.
2 question five, if a third-narty certification pro-3 gram is adopted, what items should be included in the 4
standard for determining the incompetence of individuals g
5 acting a radiographers?
We would like not to conment on 0
3 6
this question because we are not in favor of third-party R
7 certification.
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Question six, if a third-party certification pro-d q
9 gram is adopted, should it apply to individuals presently z
h 10 working as radiographers or only the new radiographers?
E II If a third-party program is adopted, it would have severe D
I 12 implications for those organizations involved with unions, 13 particularly those organizations that have radiographers l
14 who have previously held that position.
15 An extensive negotiation with the union would be d
16 required in the event those categories mentioned failed to
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17 pass certification examination.
One could also speculate
$i 18 that if a significant number of radiographers failed the i:
h 19 certification examination, the employer would be forced to n
20 shut down his operation until a successful candidate was 21 obtained.
22 Question seven, if a third-party certification 23l program is adopted, should certificates be issued to O
24 1md1,1dua1, fo, 11f, o, shou 1d there se a period 1= remova1 25 I 6f certification?
If a third-party program is adopted, i
ALDERSON REPORTING COMPANY, INC.
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ij the prc,qram should provide rules for periodic renewals.
2 The suggested format one would be to re-examination by the 3
employer; or two, re-certification by the third-party
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4 requiring the radiographer to submit for all documentation o
5 providing evidence of continued satisfactory performance.
En 3
6 Question eight, does a third-party certification 1
7 program affect the ability of a licensee to respond to man-A 8
power needs?
A third-party certification program would dd 9
have significant impact on any licensee who must increase i
h 10 his staff on a relatively short notice to unforseen cir-El 11 cumstances.
This is based upon the assumption that a third-3 y
12 party certification would only be offered on a periodic
()5 13 basis.
Thus, the employer.must wait until the scheduled l
14 date of the examination.
2 15 Question nine, since athird-party certification 5
g 16 program would likely be based on a cost ~ recovery by a e
6 17 fee system, would the cost of the licensee of such a program 18 be warranted?
Obviously, this third-party certification 0
19 program would add another cost to the NRC licenses.
It is R
20 suggested that the entire fee system for licensing be 21 reviewed for reform.
Specifically, it is suggested that Il 22 one basic fee be established for licensing, licensing
%d 23, renewwals, compliance audits and other services that the I
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24 ' commission provides for the licensing consideration.
25 i This would eliminate the unnecessary administrative ALDERSON REPORTING COMPANY, INC.
l 25 j aetivities that are presently existing, question ten, which
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2 alternatives of the two discussed in the cresent system 3
third-party certification as referral, why?
Are there other O
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alternatives?
If so, please explain.
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3 6
would be receptive to changes, provide the responsibility E
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reason for this preference was previously expressed.
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g Question 11, with respect to the two alternatives, og 10 what kind of enforcement action would be taken against z=
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radiographers who do not operate the equipment safely or 6
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follow established precedures?
What rights should radio-()@
13 graphers have with respect to such enforcement actions?
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The 11censee radiation safety program should 9
15 j
address disciplinary meacures for radiographers who are T
16 found guilty of violating operating instructions and pro-p 17 cedures.
The disciolinary action should be structured such w
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to discipline administered.
20 The disciplinary action plan should include pro-21 visions for discharge of a radiographer, the nature and I
22 (3) seriousness of the incident ifarranted.
23,
Also, the radiographer should be granted rights
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24 l to complete the case to prove his innocence if he has been 25 lunj ustly accused by his employer or any other party, i
l ALDERSON REPORTING COMPANY. INC.
30 1
individuals or members of the union.
2 Would a small licensee because of his size have 3
a disproportionate adverscly common impact under a third-
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We decline to comment on this because we g
5 consider our company not to be adversely affected as a 0
6 small licensee.
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Thirteen, for those organizations that are interest <ec Al 8
in participating in the third-party' certification program, d
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what would be the estimated cost in implementing such a, 10 program?
Again, we decline to comment since we are not in 11 favor of third-party certification, m
I 12 That concludes our response to the thirteen ques-(">g y
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5 J3 tions as indicated in the pro'osed requirement. I would p
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18 over-exposures?
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industrial licenses that are issued today, which I have M
20 information to indicate that somewhere around 400 licensees 21 are out there.
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24 every time an exposure is made, the potential exists for an 25 incident.
I ALDERSON REPORTING COMPANY, INC.
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So I think, that all in all, the track record of 2' the industry, although some seem to think that it is not 3
cood, if we would take and determine how nany regular routes T'/
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would find that the number o f incidents is pretty small.
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10 a certification program is going to reduce the number of z=
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Thank you.
g 12 MR. BASSIN:
If there is a situation where you migh t
i rm S 13 kJ j hire a person who has had previous t' raining, which is sone-14 times the case, is there a mechanism that you might have 9
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or anyone out there who would have for determining, previous a
d I0 work by persons?
That is, what their performance has been w
hI at another licensee facility even though they might con-m 18 tinually possess the recuisite understanding?
Is there some s"
19 8
nechanism that you have for determining past work habits n
0 of personnel who might apply for, jobs as radiographers?
21 MR. GRABER:
I will respond to that question in
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22 the way that I administer my program is that I don't accept 3l past work experience for an individual coming into our pro-1
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have to learn the way we do things and they go through ps sJ 4
the same extent of classroom instruction and training as g
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as a radiographer.
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MR. JONES:
Does Babcock and Wilcox perform all d
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radiographer inhouse or do you sometimes turn to other firms 2o 10 to perform it for you?
E 11 MR. GRABER:
There are some ocassions where Babcock 3
y 12 Wilcox, the construction facilities for field type applica-(l 3 f
/5 13 tions does in fact hire outside services, yes, they do.
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Do you have any feeling for how the h
15 level of competency and training of these radiographers x
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18 MR. GRABER:
Dennis Rocket is here who is with p
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Babcock-Wilcox of the construction division.
I will let him n
20 answer that.
21 MR. ROCKET:
My name is Dennis Rocket, and I am k'g)
N 22 an officer for Babcock-Wilcox construction group.
I want 23 to go on record as saying that the construction group 24 wholeheartedly supports Mr. Graber's croposal of a third-25 ' party certification.
In answer to 'tr. Jones' question, like ALDERSON REPORTING COMPANY, INC.
33 1
Mr. Graber said, we do use such radiographer groues.
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2 this, we need a copy of their license with the NRC or the 3
state in which the radiography is being done.
In addition,
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5 we feel that their training is inadequate, then we will 0
6 give them additional training for our programs.
But in nost R
7 cases, they operate under their own licenses, so we hold them j
8 responsible for their actions and the certification of the d
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radiographers.
10 MR. BASSINi One thing, do you monitor the perfor-11 mance of other firms which come to Babcock and Wilcox and 3
j 12 do you look to see that they are indeed following their
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13 operating emergency procedures to be sure that your per-l 14 sonhel will not be subject to unnecessary radiation as a 2
15 result of adverse. actions by this outside contractor?
j 16 MR.
'G R A B E R :
Actually we don't.
We hold that w
d 17 responsibly to the licensee himself.
If they are working 5
5 18 in conj unction and we are also on the sight, they are looked 5
3 19 at somewhat in their exposure personnel and stuff of that M
20 sort.
A similcr course would be looked at and that sort 21 o f thing.
12 MR. TRION:
I am Ray Trion of Beloit, Wisconsin.
23 I am chief metallurgist and a radiation safety officer.
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24 would like to respond to the question about bringing in 25l outside radiographers.
ALDERSON REPORTING COMPANY. INC.
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some times when we need to use outside radiography because gy
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( 12 very bad things happen.
These are radiographers that know
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It is because they 15 are careless or they are going to do a dumb thing or they 16 g
are in haste or just plain sloppy.
But it is not lack of M
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18 A certification program will not' make them more c
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20 want to comment later upon discipline and things like that.
21 THE CHAIRMA:I:
Thank you, sir.
I would like to
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22 call an additional speaker, and then we will have a brief 23, recess.
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24 Our n ext commentor will be '4r.
Joe O.
Brown.
25 MR. BROMIT :
Thank you, Mr. Chairman.
My name is ALDERSON REPORTING COMPANY, INC.
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Brown. I will attempt to address the a.uestions as they m
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2 have been presented in the Federal Register and possibly 3
have some additional comments.
I have reviewed this with F) ks 4
a number of people.
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6 and the regulations.
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In response to number one, I feel that the training j
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13 The second point, the third-party certification l
14 would in no way reduce the number of over-exposures.
Only 2
15 strong management controls and audits will tend to help g
16 to achieve this goal.
I think it was a step forward when e
6 17 the NRC put into the regulation for a cuarterly office 18 even though even though my program had' semi-annuals.
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3 19 i commented that I thought that was adecuate.
But I think 5
20 that unannounced, unscheduled audits on the part of the 21 licensee are the way to control this.
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22 The third-party certification would not motivate 23 lradiographers to work more safely.
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24 provided driver's license make us drive very much more safely; g
come from management control, 25 [ I think the motivation must ALDERSON REPORTING COMPANY,INC.
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from the licnesse's activities, whether it be NRC or safety.
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Number four, the s tigge st ed alternative is undesir-3 able since it would probably increase costs without contri-gmC 4
buting the safety. It was mentioned this morning that you 5
g must review the economic impact.
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6 Five, the present system requires tests to assure R
7 that individuals have understood the training material.
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h 10 There are some people that are participators and there are
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I2 pass some of the tests that come to them, r S h5 13 Humber six, all radiographers must be qualified m
l 14 to the same standards, recognizing that experience is more 15 often more important than your questioning.
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phers.
But their lifetime exposure is very, very low.
n 20 Some over-exposures, yes.
I don't know really how to res-2I pond to this grandfather clause, but I think that we must 22 be very careful in consideration of that, not to proclude 23 competent people from continuing in their. job.
24 Number seven, duration of a certificate will not i
25 affect safety.
Probably, re-certification would be a ALDERSON REPORTING COMPANY,INC.
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desirable thing to consider.
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Number eight, the third-party certification wonld 3
probably limit the ability of most licensees to rescond O'
4 to variable manpower needs.
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5 very similar to Mr. Graber's.
We operate in shops under h]
6 participation and two, under the State of Oklahoma and R
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The cost of the third-party certification d
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would not be warranted based on the strong belief that bg 10 it would not contribute to safety.
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11 Number ten, the present systen, although obviously 3
g 12 not perfect, it is prefe.rable for reasons I wil? try to
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m 14 Number eleven, neither alternative's.have provisions E
15 for enforcement of safety procedures.
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16 should be held accountable.
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20 believe, as I do, that without some disciplinary procedure, 21 either within the licensing process which we have or within s
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Again, the new process would have to be
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25 Number twelve, small licensees would probably be ALDERSON REPORTING COMPANY, INC.
I 30 I
adversely affected by the cost of third-party re-certifica-2 tion although I am not qualified to comment on that.
3 Number thirteen, I have no. comment to the question 6PN
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because I know nothing about the program.
That was the 5
response, Mr. Chairman, I have written out prior to this a
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I think that some other things have been brought 8"
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A ouestipn Mr. Jones had about the compentency of d"
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party certification would add anything to radiation safety.
2 15 m
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Finally, I was very must interested when the gentle -
6 17 man from Illinois, who apparently has a program for X-raying wx 18 needs.
The NRC does not.
I think this is one important
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area that needs control.
It is in the state'of Texas and 20 it is in the State of Mississippi.
We do not have this 21 progran.
We have no reasons to train people for X-rays; I'/
T 22 43 but where that is used, having had medical experience and 23 j a lot of X-rays, ask.the' technician for her film badge f)-
24 and she doesn't have one, gentlemen, it bothers me.
25 THE CHAIRMAN:
Thank you very much.
I want to ALDERSON REPORTING COMPANY, INC.
3; I
make a couple of brief comments, and then I will recess.
O 2
We have recieved a number of reports, mostly through ss 3
state inspections where the state inspector has a better
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than do the insoectors in the non-agreeing states.
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6 non-agreement states, 24 states, there are essentially R
7 30 people who do the inspecting of all the radiographers a
8 8
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involved.
z 10 There are roughly eight odd thousand licensees and II they have 3u inspectors who try to recover all of the hos-3 f12 pitals, well loggers, radiographers, radio pharmaceuticals,
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What they have found is that a number of the x
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16 termed mama-pappa outfits where there are small -- one, w
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They sat in one training programs, eight-hour P
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20 ten minutes of attentiveness.
It is very difficult for 21 people at the level of high school education to listen to l
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24 40-hour lectures.
y 25 We received notification that they give a 40-hour ALDERSON REPORTING COMPANY, INC.
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lecture, they pass all their tests, and the basis of the
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2 basis of the regulatory agency is to accept the word of the' 3
licensee.
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5 commission of all of the henious things that are being per-0 6
formed in the industry on the basis that we do not do enough R
7 Because these were rather contrary, the :IRC had a A
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meeting.
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11 cared less.
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(% a 33 have no feeling or under. standing of what that means, and
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14 that is why we are concerned.
15 We found the large companies had a more stable j
16 workforece~,- had good training programs, had good supervision s
17 under the things that had been stated here, but that it is 18 a small part of the 20,000 radiographers that are out there 19 g
with a horrendous turnover ~because some of the, Jobs are very n
20 short.
They finish with one place and then go to another, 21 and that is part of the reason we are here is find some
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24 does the proper thing to protect himself as well as others.
25 l Mith that, we will take a 20-minute recess.
Do l
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ALDERSON REPORTING COMPANY. INC.
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'Sha t you need to do and then we will resume the meeting.
O) 2 Thank you.
3 (Recess) 4 THE CHAIRMAN:
If we have everybody back, I would 5
j like to resume the meeting, please.
Our next commentor n
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will be Ollie Bush of Gamma Industries.
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MR. BUSH:
We have covered what I had to say pretty j
8 well.
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2-THE CHAIRMAN:
In that case our next commentor will h
10 be Mr. Trion, Ray Trion.
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II MR. TRION:
A lot of the things have been touched N
upon and very well, pdrticularly concerning Mr. Graber.
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15 In the pages from the Federal Register, there is x
g" 16 an interesting statement.
Investigations of over-exposures incidents by NRC and agreement state inspectors have also x
18 indicated that inadequate training of radiographers may be
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19 a s16nificant contributing cause in many of the over-exposure 20 incidents.
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I don't think that the probacility'is very high.
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24
' hat is the case for inadequate training meaning to be a I
25 contributing cause in these incidents which is why we are ALDERSON REPORTING COMPANY. INC.
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really here today, trying to solve the over-exposure.
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The over-exposure incidents were caused by inade-4 quate training.
Then I think we should be doing something 4
to improve, to eliminate inadequate training.
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exposures that I have read about, at least recall, most 8
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What we are talking about is a certification pro-h 10 gram which is trying to make sure that the person knows that
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in 12 I would also like to comment, as far as the 40-hour s 13 of training which we do.
I think it would be very difficu'lt 14 in 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training not to have covered a number of 15 times the things that people have done wrong that caused the id I0 over-exposure incident.
We go through 4 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of training; as h
I7 but frankly, when we do, there is a heck of a lot of repiti-z b
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that appraoch because we are commited otherwise.
3l I think what the radiographer really needs is 24 motivation.
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to do it right.
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43 I
ment and management being on their tail, letting them know
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2 that if they do goof up, they get caught and it is going to be very painful in the pocket.
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4 Also, there should be some sort of a disciplinary 5
provision set up if where they do do wrong, then they are 0
disciplined whether they are suspended for a certain length 8
3 of time or whether they are removed from being a radiographe r indefinitely.
d But there is a difference between certification to H
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a person's training and the disciplining could come under
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than a certification which applies only, as I understand (3 0
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certified by people, if they goof up, I am not going to call 2
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the outside certifier back in to say, All right, now I am 16 disciplining you.
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17 are adequately trained because he was adequately trained, wz 18
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ing just because they have done something wrong.
0 You don't because they have done something wrong, 21 and that would be some sort of a licensing application
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I would like to see 23,
! the NRC keep a list of people who have goofed up, and on ID 24
\\d the good up list, they suspend people.
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have a certification in because a man could come in and ALDERSON REPORTING COMPANY. INC.
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I be re-certified by a different organization without any
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18 unnecessarily rigorous.
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test your people or to train them, if you haven't trained them -- but if he comes in, he is going to have some way l
21 of making you feel that he has earned his money.
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Thank you.
I 25
. open the i
m 'J r CHAIRMAM:
Thank you.
I would like to i
1 i
I ALDERSON REPORTING COMPANY, INC.
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j floor to anyone in the audience that wishes to go on the O
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record in response to any of the things that have been 3
stated or give any of your own ideas. I mi.?ht say that f3 kJ 4
Mr. Trion cuts down a number of things that are are of some e
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establishing a national registery which permits accessibilit y
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body is removed for whatever cause, he would be there.
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are the things that are part of a national registery.
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what radiation is all about.
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have a j urisdiction over.
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5 industry to find some way to police itself to assure that 9
3 6
there are knowledgeable people doing the j ob, both from R
7 the standpoint of safety as well as determining assurance sl 8
what they are out there primarily for, those things would dy 9
be most useful, and it would get the government' agency Eg 10 out of the picture to the extent greater than it is new.
11 It appears, on the one hand, that people are saying S
Y I2 we need more governmental inj ection by having more inspec-ya 13
_5 tion, severity of the non-compliance items should be s
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14 increased, and the way you get the people is to shut down 15 for periods of time and fine in sufficiently large amounts j
16 so that there is a definitive reason to do something about e
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I am not sure that is what you really want.
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5 18 when I speak to you individually, it is almost a 100 percent 9"
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affirmative that that is not what you want.
All we hear here 1
20 is that certification does not sound like it is the way to 21 go.
22 The alternatives haven't been mentioned to any 23 l degree so that we have anything to work on.
We have on (f
24 record everything you have said, and we will study it very 25 car.efully.
But I suggest that you think in terms of these ALDEF:50N REPORTING COMPANY, INC.
l 47 I
other things that have not been said we find with 30 inspec-o/
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2 tors and a number of violations that indicate pecole are not 3
knowledgeable as suggested here that they are.
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y we find 15 people who have been over-exposed, then that v
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number certainly is multiplied by a very large factor of G
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those that we don't find.
I think anybody on the inspect-al 8
ing staff here would approve that understanding.
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h 10 opportunity to express your t hought s, and you have already
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I suggest that if you have not looked S
f II at the 13 questions thoroughly and haven't respondad to i
c f13 them, I would hope that you do~ so.
We do need that kind l
14 of input for making our own determination of where to go.
15 I would like to request that you send your comments or j
16 suggestions to the Secretary of the Commission, the U.S.
w 17!' Nuclear Regulatory Commission, Washington D.C.,
- 20555, C
18 l x
Attention, Docketing and Service branch.
If there are no other statements that any of you i
O wish to make, I want to thank you for your attendance and 21 articipation.
The meeting is closed -- pardon me, there f
22 are nore statements.
I 23l MR. DURAN:
On record, I would like to say that i
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24 we are opposed to certification.
I agree with the principles ALDERSON REPORTING COMPANY, INC.
48 1
1 Graber and Mr. Brown regarding these 13 points.
The NRC
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2 will receive a written response from our corpcration in the
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3 very near future.
It seems to me when you talk about O
4 incidents, you talk about -- I am not saying all large 5
firms; rather, reputable firms.
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the way they are laid down.
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to find a way around certification the same as they find d
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ways around the present regulations.
10 The economic impact is not going to justify the ll rule.
We will have higher wages than we are presently paying 3
N I2 which in turn we will pass along to our customers.
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I4 U.S.
world market would j ust add to that burden.
One 15 gentleman suggested a central file on radiographers.
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h I7 a new
. hire practice that you check this register to see 18 if this person was involved.
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19 Radiation safety depends on management control.
n 20 That depends on motivation.
How we do that depends on the 2I incident. It could be outright dismissal, it could be warn-22 ings or time off.
In summary; I would repeat again, that 23 l we are opposed to the certification program.
Thank you.
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24 MR. JONES:
Maybe the certification program has 2f, not really come through that clear.
There will be a nationa l ALDERSON REPORTING COMPANY, INC.
40 1
registery kept o f all certified radiographers.
Although 2
ther certified would actually do the certification, a listins' 3
would be kept by NRC of all individuals certified by that 4
certifying organization or organizations.
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have reported cases where they didn't safely perform.
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who did not have certification.
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10 MR. DURAN:
I just want to make myself clear.
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14 MR. BASSIN:
Along with this line of registery of 15 bad apples or whatever, here is the mechanism that is used d
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h 17 the work habits of people of someone who might have been' N
18 involved in an incident who may have been displined by P
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We need to establish something 22 for this purpose.
23,
itR. BAUFELD:
My name is Earl Banfeld, and I am (G
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24 a radiation officer.
25 Presently, under our oresent program, when an i
ALDERSON REPORTING COMPANY, INC.
50 1
individual hires with us, we contact their past employer to O
2 determine their status of employment, whether they were 3
radiographer or assistant radiographer and their training.
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Y 12 they may end up in a suit.
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Any other 3'
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Thank you.
18 THE CHAIRMAN:
Thank you.
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MR. CHANEY:
My name is Richard Chaney, and I am n
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It seems to ne 21 that there is a need for some kind of a registery for 22 radiographers, whether it be on a scale that would say that 23 i all radiographers be registered or one that would have
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24 incidents.
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25 i house through which the employers or potential employers ALDERSON REPORTING COMPANY, INC.
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' can go to determine whether or not this person has had 2
incidents or some kind of over-exposures when it comes to 3
being hired.
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the time, it should be mandatory that they have additional e
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what might be considered adqsquate t."aining.
That's my jcg 10 comment.
Thank you.
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Yes.
Blue shirt.
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MR. NORTH:
My name is Bill North, and I am here
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office.
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certification would in no way reduce the number of over-6 17 w
exoosures in industry today.
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good work habits.
He feel that this is a responsibility 20 the radiographer himself, super-o f two or three people 21 I visor and or the radiation safety officer, if they are (3
22 different people.
We also feel that over-exposure, and 23
! the records that I get from the NRC, that most of the over-()
24 I exposures came from field operations.
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I ALDERSON REPORTING COMPANY, INC.
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by develocing systems, warning systems and alarms and so g
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third-party certification program.
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Catipillar Tractor company will shortly send a formal answer g
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6 comment period expires.
Thank you.
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MR. JONES:
I would like to make one comment.
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think advanced notice is somewhat misleading that it appears d
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exDosure.
Over-exposure is not the only issue that third-n 20 party certification is supposed to address.
2I MR. TRION:
I would think that the NRC's primary
()w) 22 goal would be to improve the safety aspect o f t his, and 23 that is all they are supposed to be dealing with, not ID 24 j concerned with high level o f training.
It should not be 25
- the need or the desire of the NRC to get the oeople who are I
ALDERSON REPORTING COMPANY,INC.
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are certified.
Thank you.
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Well I think that I made it clear i
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So our concern is safety.
I don't
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Let me repeat earlier what I said C
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The regulatory body has been
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In any case, 2
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24 receive a volume from each of you, covering everything i
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i ALDERSON REPORTING COMPANY,INC.
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Tascite of all that, when we go out and talk to FS CJ 2 ' t he individuals, they don't even understand the basic fun-3 damentals.
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15 on supervision; that it's a very competitive outfit out a
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18 In these series of public meetings, we try to find E
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20 employ to help the individual who is not being represented 21 here, who isn't here because he couldn't a f ford to take the
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((_s) 22 time off from the j ob to get here, we are still going to be i
23! doing something about that.
We hope that through these (s) 24 discussions, what we do will be useful and will not have 25 an adverse affect on the impact, on the industry as a whole.
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1 ALDERSON REPORTING COMPANY. INC.
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55 1
And most of all, it will increase the safety of the 2
industry and the people that are in it.
Are there any Other 3
comments that either of you would like to make at this time?
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4 MR. TRION:
I would like to know the tyce of pro-e 5
grans that are in Texas and Louisiana.
Have you looked at q
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them?
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MR. BASIN:
They do have a certain type of certifi-M]
8 cation program.
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requires training by the individual to the state.
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16 fully implemented.
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17 licensing of radiographers as opposed to the third-party
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THE CHAIRMAN:
Both have protective effects from n
20 this certification --
2I IIR. BASSIN:
What did occur was that there was an 22 emphasis placed on inspecting radiography in-states of 23 Texas and Louisiana.
It was one of these horror stories tha':
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24 ' led in good part to the public meetings.
I 25,
1R. CHANEY: I also have a question regarding l
ALDERSON REPORTING COMPANY, INC.
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l licensee renewal.
Do you look at their training program O
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In general, we ask for complete re-qV 4
submission of an application at times of renewal.
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in the guide which is very basic and might be considered d
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here is the NRC official training guide.
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14 to be that at all, but rather, here is information which might 15 be useful to the industry for training of its personnel.
ij 16 MR. CHANEY:
Thank you.
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II THE CHAIRMAN:
Thank you, a:
18 MR. GRABER:
Is there any consideration by the I9 g
commission to give these recuirements into single documents 0
and the revisions that go along with it so as not to get scattered throughout the --
Ah THE CHAIRMAN:
Yes, one thousand tims or more.
l We are currently, in my particular. function, involved O
24 in reviewing the exceptions, reviewing the general license 25 ' and reviewing the specific licenses.
When we get through ALDERSON REPORTING COMPANY, INC.
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I with those, we will have a very comprehensive revision.
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I am not (;oing to hold my breath until this all gets 3
printed, however.
O Are there any other questions that anyone else g
5 would like to ask in this case?
I uant to thank you ac:ain N.
0 for your attendance and partfcipation.
At this time, I R
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will close.
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ALDERSON REPORTING COMPANY, INC.
NUCLEAR REGULATORY COMMISSION This is to certify that the attached proceedings before the O
sucicar neau1atory Commission in the matter of: Public ficeting on Certificption of Radiographers Date of Proceeding:
June 17, 1982 Docket !! umber :
Place of Proceeding:
Chicago, Illinois were held as herein oppears, and that this is the original transcript thereof for the file of the Commission.
Keith James Official Reporter (Typed)
D KnxJu Gsnaw L&uno V
Official Reporter (Signature) h i
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