ML20245H369
| ML20245H369 | |
| Person / Time | |
|---|---|
| Issue date: | 04/05/1989 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8905030381 | |
| Download: ML20245H369 (110) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGUL-ATORY COMMIS SION 1
Titl6l BRIEFING ON CERTIFICATION OF RADIOGRAPHER 4
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LOCati0n:
ROCKVILLE, MARYLAND h&($l APRIL 5, 1989 PagGS:
68 PAGES i
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COURT REPORTERS AND TRANSCRIBERS 1323 Rhode Island Avenue, Northwest
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Washington, D.C.
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3 DISCLAIMER This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Commission held on 4
April 5, 1989, in the Commission's office at One White Flint ' North, Rockville, Maryland.
The meeting was open to public attendance and observation.
This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies.
The transcript is intended solely for general gm informational purposes.
As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the matters discussed.
Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of, or addressed to, any statement or argument contained herein, except as the Commission may authorize.
1 NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHoOE ISLAND AVENUE, N.W.
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UNITED STATES OF AMERICA
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2 NUCLEAR REGULATORY COMhjISSION-3 j
A BRIEFING ON CERTIFICATION OF RADIOGRAPHER 5
4 I
6 PUBLIC' MEETING 7
l l
8 Nuclear Regulatory Commission j
i 9
One White Flint North-10 Rockville, Maryland 11 i
12 Wednesday, April 5, 1989 gw_
U 13 j
14 The Commission met in open session, pursuant to
- 15 notice, at 2:00 p.m.,
the Honerable LANDO W.
- ZECH, JR.,
'i16 Chairman of the Commission, presiding.
17 18 COMMISSIONERS PRESENT:
19 LANDO W.
- ZECH, JR.,
Chairman of the Commission 20 THOMAS M.
ROBERTS, Member of the Commission 1
21 KENNETH M.
CARR, Member of the Commission 22 KE!!NETH C. ROGERS, Member of the Commission 23 24 25' STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
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STAFF AND PRESENTERS SEATED AT T9E COMMISSION TABLE:
1 0
/
2 SAMUEL J.
CHILK. Secretary 3
WILLIAM C. PARLER. General Counsel 4
HUGH L. THOMPSON.
JR..
DEDO 5
ROBERT BERNERO, NMSS
-6 GLEN SJOBLOM, NMSS 7
CARLTON KAMMERER. GPA/SLITP 8
VANDY MILLER. GPA/SLITP 9
10 ON BEHALF OF AMERICAN SOCIETY OF NONDESTRUCTIVE TESTING 11 (ASNT) 12 ROSS BECKELY. Chairman of the Board, ASNT h
13 BOB DOGGART, Chairman 14 Industrial Radiation Safety Task Group, ASNT l
15 DUKE DEWEY, Executive Director. ASNT 16 17 ON BEHALF OF TEXAS BUREAU OF RADIATION CONTROL 18 DAVID LACKER. CHIEF I
l 19 Texas Bureau of Radiation Control 1
20 21 ON BEHALF OF CONFERENCE OF RADIATION CONTROL PROGRAM 22 DIRECTORS 23 CHARLES TEDFORD. Chairman I
24 CHARLES HARDIN. Executive Secretary 25 RON WASCOMB. Louisiana (2021234-4433 NEAL R.
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2:10 p.m.
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1 2
CHAIRMAN ZECH:
Good afternoon, ladies and j
1 3
gentlemen.
The subject of today's briefing is the 4
Certification of Radiographer.
l 5
For many years the Nuclear Regulatory Commission 6
has been concerned about the number of radiation
)
7 overexposure among industrial radiographer.
A review of 8
overexposure incidents indicates that, among other things, 9
inadequate training may contribute to radiographer' 10 failure to follow safety procedures.
The issue of 11 radiographer licensing, or certification has been under 12 evaluation for sometime. The NRC staff has been monitoring g
13 industry initiatives in developing a radiographer's 14 certification program, which will be the topic of today's i
15 discussion, j
16 This is an information briefing.
In addition to 17 the scheduled NRC staff presentation, we received a number 18 of requests from other interested parties to address the 19 Commission on this subject.
20 First, we will hear from the staff, and then we 21 will hear from representatives of the American Society of 22 Nondestructive Testing, the Texas Bureau of Radiation 23 Control and the Conference of Radiation Control Program 24 Directors.
25 I understand that copies of the vu-graphs to be (202)234-4433 NEAL R.
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4 i
1 used in today's presentation are availab1'e as you enter 7'~~
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2 the room.
3 I would ask all of our speakers to please adhere i
4 to their allotted time because we do have a number of 5
- speakers, and we want to conclude the meeting as 1
6 reasonably on time as we can.
3 I
7 Do any of my fellow Commissioners have any j
1 8
opening comments before we begin?
9 (No" response)
I 10 CHAIRMAN ZECH:
If not, Mr. Thompson, you may l
11 proceed.
12 MR. THOMPSON:
Thank you, Mr. Chairman.
l 13 As you said, this is a major milestone in a 14 program that we believe is a very important one for the 15 nation's public health and safety with respect to the 16 industrial radiographer.
3 17 Before I turn it over to Mr. Glen Sjoblom, who j
j 18 will be doing the briefing today, I would juct'like to say 19 that both Glen and Vandy Hiller, who is on my right, have 1
20 been personally involved in this effort for us. And of 21 course the other members of the groups that are here today 22 have played a key role in reaching this level of agreement 23 on this very important pregram.
24 We have a program which we believe, if put in c,
25 place, will achieve a level of safety and improvement in l
1 (202)234-4433 NEAL R.
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1 the radiographer program that, if successfully 2
implemented, would be.one that we would probably recommend 3
to the Commis'sion down the road, that a rule be put in 4
place making radiographer certification a requirement for 5
all radiographer.
6 This is an important point that I would like the 7
Commission-to keep in mind, as we go through the briefing 8
today because, previously, in a previous Commission, an 9
approach similar to this was occurred with another 10 society, and the Commission, after posing a proposed rule, 11 changed its position at the end, between.the draft and the 12 final rule requiring certification of laboratories.
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13 And at that time the Society had suffered, I V.,:
14 guess, some financial burden because the Commission could 15 not reimburse that professional society for the l
16
' expenditure of resources, and that program did not 17.
continue on to success.
18 I am not aware of any concern by any of the 19 Commissioners of the support for this type of program but, 20 if there are any issues that you become aware of and want i
21 to make sure the staff is sensitive to, or the other 22 parties should be very sensitive to this program, because 23 that is a key element in the ultimate success of the 24 program, I think, as we view it today, i
25 There are a number of parties here.
We will (202)234-4433 NEAL R.
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probably ask Carl Kammerer, in the Agreement State, to 2
introduce the State of Texas people, as we leave.
So we 3
will be departing and I guess with that. Glen, I would 4
like to turn the briefing over to you.
1 5
MR. SJOBLOM:
Yes.
The first two slides just 6
.are providing an indication of what the briefing, as a 7
whole, will cover.
(Slide)
The first part will be our j
8 briefing here, the staff presentation on what the safety 9
issue is, then a brief background on the current 10 regulatory program in radiography safety, then our 11 thoughts on the benefits, the perspectives that we have 12 that relate to this industry initiative, and then our Qt 13 indication of what we think should be done on down the 14 line, as a matter of implementing this program.
15 The second slide (slide) again, merely 16 restates that the order of presentation by the other 17 parties, other than the staff, in the same order that the 18 Chairman already mentioned them.
The industry group is i
19 the American Society of Nondestructive Testing. Texas 20 involvement here is an important one, in that they have 21 one element of that program. namely. an examination which 22 would be folded into the nationwide certification program.
23 And then the Conference of Radiation Control Program 24 Directors, acting as a broker for some of the states, 25 would participate in giving some of the exams.
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So it is kind ~of a combined' effort.-And"we'want 2
you to hear from-each oflthose three elements.-
And then, 3
' perhaps, if ~ the Commission has any additional questions 4
after hearing all that, for the staff, we would be 5
available to come back up, if you like.
6 Let me turn then to slide three -- (slide).
The 7
fundamental problem in radiography is that one needs a 8
very high intensive radiation source in order to. expose 9
the film through the object being tested.
So, typically, i
10 we e.re' talking about 100 curies of Iridium 192.
And this 11 is in a device which provides the shielding necessary 12 while the source is not in use, but in order to expose the i
13 film, you need to drive the source out of the shield, IN 14 through a tube to the point where it needs to be located 15 in order to expose the object in question and the film 16 beyond it, to the radiation.
17 So, 100 curies of Iridium 192 at three feet can 18 provide a dose rate of about 50 rads per hour.
And this 19 means that if a person were there and the source was out 20 of the shield, if he was there for two minutes, he would 21 exceed a 5 rem in a year dose.
And if he were even 22 closer, say a foot, he could exceed that in 10 seconds.
23 So it is very important then that the source be 24 retracted before anyone comes back close to the 25 radiography shield.
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That then leads to the second bullet then, the
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basic causes of all of the overexposure events have either g,
3 to do with the. failure of equipment, if the source becomes 4
4
. disconnected from the pigtail'that is used to drive it in 5
and out, it can be left there, unbekn'ownst to the 6
radiographer.
The second' type of problem results when the 7
- staff, the radiographer, don't follow the prescribed 8
procedures.
And recognize how these people, the 9
radiographer, are operating out in field sites, many 10 times it is at night.
They are not under a lot of 11 management supervision, and they do this often enough that 12 they can become lax.
And they can fail to follow 13 procedures.
14 And if you fail to follow the procedure to do a 15 survey, when you are coming back towards the shield to 16 lock it and take it back in your truck, then you can get 17 overexposed very quickly.
18 So one single personnel error, in combination 19 with the source not being back in the shield, can cause a 20 significant problem.
21 Now the fundamental factor that we are trying to 22 work on with the certification program is to ensure the 23 adequacy of the training, not only in the technical 24 aspects, but in the appreciation the radiographer have as i
o -
25 to the serious consequences to themselves, if they fail to (202)234-4433 NEAL R.
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'2 So we are looking here at increasing the g
3 certainty with wh'ic'h' they understand 'what they are doing:
4 and really the bottom-line is the ' degree of p.
5 professionalism that this cadre of ' workers ~ has.
For-6 perspective', there is somewhere.in the neighborh'ood of 10-7 to 15.000 radiographer throughout the country, in NRC and E
8 Agreement. States. So that's the body of workers that we 9
are dealing with here.
10 COMMISSIONER ROGERS:
Excuse me, what is the 11 potential for the innocent bystander, in a sense, in this 12 kind of a situation?
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13 MR.
SJOBLOM:
There is a potential there, and 14 that is precisely why, when you set up in the field, the-15 radiographer-are required to set up a boundary and set up 16 a barrier that is defined, so as the radiation levels at 17 the extent of that boundary will be like 2 millirem in an 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> during the time --
19 COMMISSIONER ROGERS:
For a radiographer that 20 isn't all that concerned about their own personal safety, 21 would perhaps be even less concerned about public safety, 22 and that's another aspect.
23 MR.
SJOBLOM:
Another reason for making sure 24 they are all properly tasined, yes, sir. But there is
' ~
25 procedure whereby thny do rope the boundary off and put (202)234-4433 NEA1 R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLANS AVENUE, N.W.,
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signs up, and they do post people you know, in
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2 complicated places where they are shooting, that does 3
require attention.
They do have to know what they are j
4 doing.
5 COMMISSIONER CARR:
Well, if he doesn't secure 6
the truck and if it falls off on the road --
7 MR. SJOBLOM:
Okay, again for background, let me 8
run through slide four (slide) -- what our current 9
regulatory program is in radiography.
10 First of all, we have a licensing program where 1.1 to practice and to use the material, they must receive a 12 license either from NRC c,r an Agreement State.
And with 13 regard to the radiography people, they'have to provide us
)
14 information on their training and qualification program.
15 COMMISSIONER ROBERTS:
The license goes to the 16 person who holds the source?
17 MR. SJOBLOM:
No, the license currently goes to 18 the company --
19 COMMISSIONER ROBERTS:
That's what I meant --
20 MR. SJOBLOM: -- not to a radiographer.
21 COMMISSIONER ROBERTS:
Yes.
22 MR. SJOBLOM:
And it is the company then who has 23 the responsibility to train and sensitize, and check up on 24 each radiographer.
i 25 We currently, therefore, approve the training (202)234-4433 NEAL R.
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programs on paper.
And when we are out doing our 2
inspections, which is the next~ bullet here, we'do. check up 3
on them.
It-is on an annual basis, and it is' annual, 4
which is our most frequent type of inspection, based on 1
5 this industry's the possibility for this kind of 6
occurrence and the track record that.they have had.
S o ',
7 we do inspect them~ annually.
8 COMMISSIO!!ER CARR:
Are we able to get to all of
'1 9
.those annually?
10 MR.
SJOBLOM: Yes, yes, we do. And we have a 11 requirement that each -- that at least 23 percent of our
)
12 inspections are in actual field locations, where
'l 1
13 radiography is being conducted.
14 MR. THOMPSON:
But I am not sure that that 25 15 percent actually. gets someone conducting the radiography 16 activities at that time.
Sometimes they may not be 17 setting up yet, but we certainly recognize the importance 18 of actually inspecting the operations that we are able to 19 do.
20 MR. SJOBLOM:
!Jo w,, I mentioned that one of the 21 key elements was equipment failures.
The Commission does 22 have an ongoing rulemaking in this area.
It has been 23 proposed for public comment, and the schedule for bringing 24 that back to the commission in final form is in May.
So, 25 in effect, by this certification action and by the (202)234-4433 NEAL R.
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1 Commission's rulemaking on the equipment' perf ormance, we 2
'will be attacking -- are attacking both of the problems.
3 Another element of our regulatory program is 1
4 strong enforcement.
There have been many enforcement 5
- actions, we have typically run six to 12 enforcement 6
actions a year in the radiography area.
7 COMMISSIONER ROBERTS:
But don't you not to 8
be critical of the NRC or the people out there, don't you 9
suspect that you may take strong enforcement when you know 10 it, but don't you think more overexposure, many more 11 occur than you have any notion of?
12 MR.
SJOELOM:
I think one would be reasonably 1
13 assured there are some, but we don't know how many that L_
14 aren't reported.
j 15 COMMISSIONER ROBERTS:
Okay.
16 MR. SJOBLOM:
Then we have some additional ways 17 of trying to communicate with licensees, that we have 18 increased in the last few years.
We do more information 19 notices in this area.
We also have been having workshops 20 with industry groups, and we have had two or three now 21 with the radiography community.
And then we have also 22 instituted the NHSS Newsletter.
And there is certainly 23 adequate coverage of radiography problems in those media.
24 If I could go back to the licensing piece, in 10 i
25 CFR 34 there is a sort of requirement defining what the (202)234-4433 liEAL R.
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t r a i n i n g.' a n d qualifications are for radiographsrs.
And 2
that entails a 40-hour,- one week fundamentals of radiation 3
protection.
And then a three-month, or 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of 4
practical experience, working as a radiographer assistant, 5
where he would get the on-the-job training in the 6
technical aspects of how to run the equipment, how to do 7
the surveys, how to rope the areas off.
8 It is those particular requirements which have 9
not always been, let me say adequately done by the 10 individual licensees.
And it is for that reason that a 11 third party examination and certification process can act 12 as a quality control on the entire nationwide training 13 p r c, g r a m.
And these inadequacies in training and g
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14 sensitization is not just a matter that small companies 15 have had problems with.
We have also had the US Testing 16 example where a nationwide program we found over 100 17 radiographer that were out there performing with 18 inadequate, and without any company certification from 19 time to time, because they did it as short-cuts, they 1
20 didn't have control.
t, 21 This way, if we have a certification, and once 22 it becomes -andatory, if we find a radiographer out there 23 and he doesn't have his certification card, that is an 24 automatic example where they haven't followed the program.
25 CHAIRMAN ZECH:
How does this third-party (202)234-4433 NEAL R.
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certification relate to our current regulatory program?
2 MR. SJOBLOM:
What, in fact, it would do -- and 3
this would of course be described in more detail by the 4
next set of speakers
- but, basically, they would 5
administer a test, a nationwide test.
In other words, we 6
would not be subject to the adequacy of the individual 7
licensee's exam.
We would have a nationwide test.
8 The next thing they would do is they would 9
examine the adequacy of the on-the-job training, and they 10 would do a background check.
11 CHAIRMAN ZECH:
Is this an amplification of our 12 current regulation, or is it something in addition --
(.},d 13 MR. SJOBLOM:
It is a supplement in addition to, 14 right.
15
-CHAIRMAN ZECH:
All right.
16 MR. SJOBLOM:
Now, once we have a certification, 17 we can accept that in lieu of our approving their 18 individual training program because we have the 19 independent check on their training,
- namely, the 20 examination.
21 MR. THOMPSON:
But it's a program that will 22 ensure that our current regulatory requirements are l
23 covered, and then some.
But it would encompass all of our 24 current requirements and have some added aspects to it--
25 some enhancements.
26 CHAIRMAN ZECH:
All right, thank you.
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Let's proceed.
2 MR. SJOBLOM:
That feeds into slide five then--
3 (slide)
-- that provides our perspectives on this 4
certification program.
It provides this assurance that we.
I 5
.are talking about, the training, knowledge, skills and the 6
hazard appreciation is met in every-radiographer, before 7
he is certified.
And it provides a certain degree of 8
professionalism in that group of people.
They will be 9
carrying a card, only after they are accepted, and not 10 just anybody is going to be able to pass that exam.
11 As you will hear, that ongoing testing.in Texas 12 has a certain failure rate. And if you fail the test, you 13 don't make tP* card, you don't make the. certification.
,y g.7 14 COMMISSIONER ' CARR:
It is a written exam, as 15 well as practical?
16 MR.
SJOBLOM:
There are both parts to the 17 program.
18 MR. THOMPSON:
The State of Texas one right now 19 is just a written exam, but the proposal would include 20 both.
21 COMMISSIONER CARR:
So it is really going to 22 provide us QC on the training program, per se, then?
23 MR. SJOBLOM:
That's right.
24 COMMISSIONER CARR:
Okay.
?;
MR.
SJOBLOM:
And another facet of it here is (202)234-4433 NEAL R.
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1 that the individual ~ radiographer will indeed f ee1~ more
{,
.2 responsibility for his own safety, more than:just whether 3
he is going to get hurt or not, or overexposed, but if he 4
doesn't properly carry out his function l, then he can lose 5
.his certification.
6 And once this program is,
- indeed, made 7
mandatory, if he loses his certification, he doesn't work.
8 And that is where.it will bring a certain degree of--
9 another factor to bear on his performance.
10 A'n d then as I
mentioned, a
standardized-11 nationwide testing effort.
12 N o w,. the next. slide (slide)
-- tries to 13 anticipate,-in general, what our intentions would be, once 14 the ASNT program is. submitted to the agency formally. As 15 you will hear, the ASNT board has just approved. that 16 program in its document, and that would be submitted to 17 the agency.
If that is then acceptable and we. can 18 conceptually agree with that, then the next issues become, 19 well, what will NRC and the Agreement States do to ensure 20 that this program becomes a viable nationwide effort.
21 And we felt that two steps would be required.
22 First of all, we feel we need to recognize the ASNT 23 program as providing the assurance that our basic training 24 and qualification requirements are met.
So we would 1
25 anticipate an initial rulemaking that would insert (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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1 directly 'in ~ 10 CFR'34.an NRC statement.that we accept an 1
2 ASNT certification, in lieu'of the licensee providing to
)
'3 us all the ' inf ormation about his training. program.
In 4
other words, that is an' initial step that we would --
5 CHAIRMAN ZECH:
That would be part of the 6
rulemaking?
7 MR. SJOBLOM:
That would be a rule -- a simple j
I 8
one because it would really be adding a very simple 9
statement to an existing rule.
10 I might add there are precedents for this in 10 11 CFR 35.
Some of the medical societies have had 12 certification programs ongoing, and those have been 13 recognized by the NRC directly, in 10 CFR 35.
So there G.
14 are precedents for this.
15 Now, the next step, once we get u little bit of 16 experience with this, once ASNT begins to put this in 17 during a one or two year period, and gains some experience 18 with this program, then we will have a basis on which we
]
19 can proceed to the next logical step.
20 In other words, if this proves to be a viable i
1 21 effort, it would be the staff intention that we would make 22 this a mandatory requirement, to have a third-party
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23 certification of all radiographer, so that we will have a 24 nationwide, consistent, compatible effort.
So that 25 radiographer that are operating in one state can go to (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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cnother state, and if they are: certified in this national-S l.-
'2 program, everybody'can feel a little bit more comfortable L:_
3 that.they have been given the proper-training and l
')
4
_ qualifications.
I 5
COMMISSIONER CARR:
I guess'I don't understr.id i
6 why you need to do that in two steps.
J 7
MR. SJOBLOM:
We would like to -- let me explain 8
a little bit.further.
It is going to take a little while t
9 for ASNT to get this program going.
They can't possibly
-l 10 test-everybody instantaneous' sly. There are 10-15,000-11 people, first of all, that's one factor, but we don't have i
12 all the. information because the program hasn't been 13
. started.
14 When the Commission makes the final decision 15 that this will stand the test of a cost-benefit analysis, 16 for example, a s' required by' our rulemaking process, we 17 will have to have more information on the costs and, 18 indeed, on the benefits.
19 Certainly it is our anticipation that that will 20 be - the case.
But as Hugh Thompson pointed out at the 21 outset, we do have to have the facts when we make a final j
22 rule that requires this as a nationwide thing.
l 23 MR. THOMPSON:
The other aspect is that we and 24 the Society believe that grandfathering is not the i
25 approach to take with the individuals out there.
In other (202)234-4433 tiEAL R. GROSS & COMPA!iY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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I words, anyone who goes through the program to become j
i L-2 certified will have met the requirements of the approach 3
setting out, as opposed to an approach where you make it a 4
requirement, but grandfather everybody who is out there.
5 So I think those two, in combination -- that is, 6
it is going to take a while to get the program --
7 CHAIRMAN ZECH:
Say that again, you are going to I
8 grandfather, or you are not going to grandfather?
9 MR. THOMPSON:
Right now the Society does not 10 intend to grandfather them, and that is just to make sure 11 that you are going to have --
12 CHAIRMAN ZECH:
So everybody has got to take the S
13 training?
4 14 MR.
THOMPSON:
They are going to take that 15
- training, they are going to pass the exam.
- And, so, 16 anybody who, in fact, is certified has met the standards 17 that are established by the Society.
18 CHAIRMAN ZECH:
Good.
19 MR.
THOMPSON:
And we think that's the right 20 approach to go, which we want to give full faith and 21 credit to those who have done that, as opposed to --
i 22 CHAIRMAN ZECH:
Right.
23 COMMISSIONER CARR:
But you could handle that by 24 making it as of 1991, everybody has to be certified, or 25 whenever you want to -- if you are going to do this in two (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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20 1
years, you can just say as of that yacr, and that takes 2
care of your grandfathering concern, however long it takes 3
to get everybody examined.
That's right, we could do it that 5
way.
I guess our --
i 6
COMMISSIONER CARR:
I just hate to see two i
7 rulemakings when we could do it in one step.
It is hard 8
enough to get one rule passed.
9 MR.
THOMPSON:
- Well, we see the first 10 rulemaking, quite frankly, as a fairly short, easy 11 rulemaking to do, probably taking six months, since we are j
i 12 not establishing a new requirement. The cost-benefit 13 detailed regulatory analysis is not as substantial, and we 14 would anticipate going through the whole process of a very 15 short public notice, and being able to get that done very 16 promptly, once the program is submitted to us for review.
17 So we don't anticipate -- I,.now our experience 18 in some rulemakings, it would -- may be, you know, five 19 years before you get the other rule out. So, we would see 20 that being done very promptly, and have in place a 21 Commission approved regulation today that would do that.
22 That is not to say if the Commission wants to 23 take the other approach, we could certainly take the other 24 approach. But that may be something that we would be more
)
1 25 than happy to discuss with the Commission in more detail.
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- MR.
SJOBLOM:
ASNT, in fact, in polling all the
.2 members, has' detected that there isn't total support for:
~3 this in the industry.
And there would be --
4 CHAIRMAN ZECH:
There is or there is not?
5 MR. SJOBLOM:
There is not total support.
6 COMMISSIONER CARR:
We haven't put out a rule 7
yet'with total. support.
8
. Laughter)
(
9 MR.
SJOBLOM:
We would anticipate a'
certain 10 degree of opposition, once we make a proposed --
11 CHAIRMAN ZECH:
We are not running a personality 12 contest, we are involved with public health and safety.
13 And so we are trying to make the right decision.
Not
/.,
b 14 everybody agrees with most of the decisions we make, but 1
15 we are trying to make the right one, and that's what is 16 important.
17 MR.
SJOBLOM:
What I would want to do is not 18 have a ' problem developing the cost-benefit information, 19 and thereby delaying our endorsement of this effort.
And 20 we think that by doir:g it in the two-step process, we can 21 endorse it in the first instance and get it on the road--
22 CHAIRMAN ZECH:
All right, we understand.
23 COMMISSIONER CARR:
Some rules we don't have t-24 have a cost-benefit.
o 25 MR.
PARLER:
The backfit rule doesn't apply (202)234-4433 NEAL R.
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.(
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-l
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.here', but I am. told by one of.my colleagues sitting back 1
-i I.
2 there that it is not a backfit problem,.it's a -- the
- t.1.
3 problem is created by.the fact that small businesses are-1 4
' involved.
J 5
COMMISSIONER. C ARR:
The people who get over 5 j
l 6
rem. total exposure over 50 percent of them get it this R,,
7 vay, though.
That's a public health and safety problem.
l 8
CHAIRMAN ZECH:
Mr.
Eernero, do~you have a.
i 9
comment?
10 MR.
BERNERO:
Keep in mind the fundamental 11 difference between the two.
The recognition rulemaking, 12 the short, quick rulemaking that can come at the beginning i
13 recognizing this as fulfilling regulatory responsibilities 14 is a quick NRC rule. And then the mandatory part of the 15 rule does involve all the Agreement-States, as well.
16 So it has a broader scope, and it is necessarily 17 a tougher rulemaking to do.
So, that is why the staff has 18 this'two-step approtsch, recognize it immediately and then 19 20 CHAIRMAli ZECH:
Well, as Commissioner Carr said, 21 could you do it in one step?
22 MR. BERNERO:
It would take notably longer.
23 CHAIRMAN ZECH:
It would take notably longer, 24 longer to do it in one step than to do it in two steps?
I 25 MR. THOMPSON:
To get a final rule in place, we (202)234-4433 NEAL R. GROSS & COMPAliY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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23 1
.could.' ge t a' final rule.in. place endorsing'the program in 2
about six months.,
If we had to go to the.-full rulemaking, 3
we would anticipate it would.take a minimum of two' years.
'4 CHAIRMAN ZECH:
Well',
you are going to-5' eventuelly go to full rulemaking, are you not?
5
~ COMMISSIONER CARR:
The final rule is still 7'
going to take the same length of. time, if not longer.
8 MR.
THOMPSON:
The final final rule would
.9 probably-take the same length of time.
i 10 CHAIRMAN-ZECH:
It would be shorter to do it in 11 one step then, right?
12 MR.
THOMPSON:
If the ' inf ormation f or u's to t}
13 develop the supporting justification for the rule is 14 available.
15 CHAIRMAN ZECH:
All right.
All right, let's If proceed.
17 MR.
THOMFSON:
- Well, I think' that kind of 18 concludes where we.were with respect to our proposed 19 future actions.
We anticipate that the other parties here 20 today will give you a very quick briefing as to where they 21 are with respect to the support of this program.
And we, c
22
- again, will be prepared to respond to any particular 23 questiens you may have at the end.of the briefing, unless 24 you have some now.
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'COMMISSIOllER ROGERS:
I just have one question i
o 5,
l zy; t- ' -
'2 that relates to how much we know about overexposure.
Is.
- j i
a 3
there any either requirement or at least request f rom' 11RC 1
4
.that we be informed'of any evidence of radiation exposures 5
by. hospitals?
6 MR. SJOBLOM:
By hospitals?
7 COMMISSIO!JER CARR:
The same way if the guy l
I S
turned in to the hospital, like a bullet wound?
.9 COMMISSIOllER ROGERS:
That's right.
I mean, i
10 there is a gunshot wound requirement of reporting.
Is 11 there. any have we made any requests, or thought of 12 making requests to try to get a handle on'this?
h 13 MR.
SJOBLOM:
No, but my sense of it is if 14 someone is exposed to that degree and our licensees know l
15 about it, they would'immediately tell us about it.
-16 MR.
T H O M P S o ll :
- Yes, we typically get that 17 information either through the emergency -- the states in 18 their emergency response.
If somebody comes in 19 overexposed, we usually hear about it.
But I can't say 20 that we get them all because of a reporting requirement.
21 COMMISSIONER ROGERS:
I just question whether 22 this might be possibly another way of improving our 23 confidence in --
24 COMMISSIO!!ER CARR:
I would say if he got 25 seriously enough exposed he had to go to the hospital, we l
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~ would know abou t. i t'.
. But those guys who only. get 5.or 2
10R, we probably wouldn't know about it.
3 MR. THOMPSON:
We hear about' people who ' think' 4
.they saw something radioactive and go to the hospital and,
'5 you know, as far as we'know the'r e was really no exposure 6
at all.
7 MR. SJOBLOM:
We had one call in, just recently, 8
whereLsomeone had taken urano acetate, the report is, in 9
trying to hurt himself, trying.to commit suicide, perhaps.
10 And we heard about that one right away, i
11 CHAIRMAN ZECH:
All right, any questions'from my.'
d 12 colleagues, before we.ask the staff to' conclude?
13 MR. THOMPSON:
I might ask Glen.to introduce the 14 next group.
'15 (Whereupon, the staff left the table and the 16 representatives of ASNT came to the table.)
17 MR, SJOBLOM:
The next set of speakers are--
18 let me mcve down here, so they can join us
-Mr.
Ross 19 Beckely, who is the Chairman of the Board of ASNT; Mr.
20 Duke Dewey, who is the Executive Director of the American 21 Society of Nondestructive Testing, and Mr.
Bob Doggart, 22 who is the Chairman of the Task Group that developed the 23 ASNT program.
24 CHAIRMAN ZECH:
Welcome, gentlemen.
25 You may proceed.
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MR.
BECKELY:
Good afternoon, Mr.
- Chairman,
.. I L-2 gentlemen.
3 Our purpose here,today is to provide you with a 4
overview of the program provided by the American Society-5 for Nondestructive Testing.
We will provida you with a y
I 6
kind of a historical review, some information on the 7
implementation costs, and finally, the summary of the 8
proposal.
9 From an historical perspective, the cause of i
10 concern over-radiation safety using industrial 11 radiography, is based on number of exposures as-a function 12
- of percent of licenses; ASNT response to regulatory
'{h 13 concerns and p o t e ri t i n i
&dvance Notice of Proposed 14 Rulemaking; ASNT's experience in certifying NDT 15 professionals; the approval by the ASNT Board of Directors
'16 of the program that you have in front of you, in 17 Charlotte, North Carolina, on March 24th of this year; and 18 some information of course on the implementation issues.
19 As an overview of the proposed program, you will l
20 see that the proposed program is entitled ASNT 21 Certification Program for Industrial Radiographer 22 Radiation Safety Personnel, consisting of three parts:
23 the Certification Requirements; the Rules of Conduct and 24 the Program Complaint and Hearing Procedures.
i 25 (202)234-4433 NEAL R.
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1 Certification for industrial radiographer would
?
2 be offered in.either or both Isotope Radiation Safety I
3 Practices or X-Radiation Safety Practices.
Basically, the 4
certification is evidence that an individual satisfies the
.i 5
training and experience requirements, has successfully 6
completed a State of Texas written examination and 7
recognized practical examination and, of course, has 8
agreed to the Rules of Conduct as provided by the Society.
9 As part of the prerequisite qualification l
l 10 requirements to obtain the examination, of course, would i
11 be the :,ubmittal of application that would be verified and 12 the fee specified by the Society, and meet the following
(
13 training and experience requirements provided for both X 14 and gamma radiation, which is 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of classroom 1
15 training provided by a recognized institution, and 520 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of actual experience in each category sought.
17 The examinations provided would be by either the i
18 Society ASNT, or the CRCPD proctored State of Texas 19 written exam.
Practical examinations administered by a 20 recognized institution at locations and times approved by 21 ASNT or the CRCPD.
22 Certification would then be provided on the 23 basis of both the written and practical examinations being 24 completed and passed within six months of each other, 25 except as granted in this case by the Executive Director.
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' Candidates who-fail, of course, would be' allowed.
l.
. t. -
2 to resubmit new applications, and. candidates who satisfy 3
the requirements would be notified in writing.
l.
4 The fees would be established and approved by I
.5 the ASNT Executive Committee.
.The State of Texas /CRCPD 6
fees, in addition to the.ASNT fee.
7 Agreement to the ability to take the 1
8 examination,- of course, would also be predicated'on the 9
agreement by the candidate, to the Rules of Conduct 10 I~ provided'by ASNT and ASNT's right to revoke and/or suspend 11 their privileges; attest that the applications are true a
I 12 d correct, and of course, the hold harmless clause.
i gj 13 Certifications would be good for five years.
14 Applications for renewal would meet the original i
15 application requirements, renewal of applications would be 16 provided the personnel are active for 24 of the last 36 17 months in radiography', and the category of certification; 18 or active for six of the last 12 months; eight hours of 19 documented training per year by an ASNT recognized 20 institution.
Renewals will also be available by 21 examination, plus the eight hours of training per year by 22 an ASNT recognized institution.
23 The program addresses the revocation, suspension 24 and expirations.
Certifications would be no longer valid j
25
- when, naturally, the certification has been expired; (202)234-4433 NEAL R. GROSS & COMPANY, INC (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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certification is suspended by ASNT, or revoked by ASNT'or, 2
of course, if the individual by his own request requests 3
to get out to the business.
i 4
Rules of Conduct, describes Rules of Conduct for 5
not only the candidates, but -the personnel who would j
6 eventually, take the examination
- and, hopefully, 1
7 successfully complete it.
8 Rules of Conduct:
Maintain the high standard of i
9 skills and knowledge; assume the responsibility that is i
l 10 expected; inform proper authorities of deficiencies; i
11' minimize the exposures to the ALARA concept; wear and' 12 maintain their personnel dosimetry; properly document
{.'
13 activities.
And some of the others that we would like to 14 hone in on are avoiding conflicts of interest and refusing 15 tc accept gratuities or bribes.
16 Also, never to misrepresent the qualifications; 17 stay away from associations with fraudulent or dishonest 18 ventures; refuse to falsify documents, and not operate 19 equipment under the influence of mood altering substances.
20 Sanctions would be provided for violations of 21 the foregoing and would result in sanctions which could be 22 suspension and/or revocation.
)
23 Part III, the Complaint and Hearing Procedure:
24 We, the Society, believes that it provides for fair notice 25 and hearing; would provide published reports, and made (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W..
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' available to - the public; annual reports of revocations I.
L-2 and committee responses to the status of the industrially l
3 radiographer's safety work.
4 Complaints and investigations could be provided
)
5 by any person, may submit a complaint.
That being the 6
- case, the ASNT Executive Director would prepare formal 1
7 complaints; the Ethics Committee would disposition, and 8
the Ethics Subcommittee would close the file for lack of 9
evidence, or prepare for a formal complaint.
10 The Executive Director would provide the date 11 for the hearings.
The respondents would have the 12 opportunity to. provide their response within 45-days.
And
.h 13
'we would allow the Executive Director to modify any of 1:
14 those dates-for good cause.
15 Prehearing procedure, prehearing conference with 16 interested parties would be followed by a written report.
17 A prehearing conference may result in proposed ruling and 18 Ethics Subcommittee information; adjudication without 19 formal hearing must be agreed to by both parties.
20 Provides for the panel makeup of three 21 individuals, including the presiding officer appointed by 22 the chairman of the committee; hearings are private, 23 except for unanimous agreement to the contrary.
The i
24 Society Board of Directors may participate in the 25 hearings.
The Ethics Committee members when complainant, L
l (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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shall not be on the panel; respondent may defend self and, 2
basically, then the panel should assure that the following 3
would take place:
4 Full development of the issues; disallow, when 5
appropriate, evidence; protecting the rights of the i
6 witnesses; allowing evidence in written form, and all 7
objections to the evidence, of course, would be recorded.
8 The presiding officer would then assist in the 9
appearance of witnesses, enjoin witnesses to tell the 10 truth and control subpoenas and testimony under oath.
11 Witnesses would be subject to cross-examination; hearings i
12 would be conducted within a year, or dismissed; and l
13 presiding officer would advise respondent of the 14 communications.
15 In order to save the Chairman and the 16 Commissioners time, you have on page 17, the rulings as 17 the panel would adopt them.
You will note that the 18 Society has adopted severity levels, Severity Level III 19 being the least significant, II being the level for 20 persons or property are deemed at risk, that would be an 21 automatic suspension for 30 to 180 days.
With a Severity 22 Level I,
being the most significant, deemed to cause or 23 threaten serious injury, or property damage, which would 24 result in revocation of an individual's license to 25 practice for at least one year.
( 202 ) 2 3 4-4 4 3 3 11E AL R. GROSS & COMPAliY, I!!C. (202)232-6600 1323 RHODE ISLA11D AVEtJUE, 11.W.,
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y 32 f
l 1
s.There 'is anJappeals, process, and the respondent.
i.
A, LL.
2 has tho ability to provide his appeal within 60 days.
~
'3 Sanctions against non-ce r ti fied. indi'liduals
~
4 claiming A SitT ' 'n a ti on a l certification, such complaints l
5 would be forwarded to the Executive Director of the 6
Society for disposition.
The Exe cu ti.v e Director would 7
then through our legal, direct the offender to cease, or; 8
be subject to court action.
And if the offender is'an 9
-ASNT member, formal complaint and request for forfeiture 10 of his membership would be requested.
11 Implementation Costs.
Basically, the
-12 implementation costs for this brief is based on - about
~
13 12,000 radiographer from the Level II perspective.
We're 14 looking at, currently, having a fee of $100 per person.
15 There is -- it is recognized that there 's. other related 16 costs to.the industry.
For example, wherever these q
l 17
' examinations may be given, of course, the cost is borne by
-18 industry to get to that particular location air fare, i
1 19 hotel, room, board, et cetera.
20 It's been considered that we'll utilize the 21 State of Texas examination that has currently been 22 developed, and that a fee to the State of Texas would be l
l 23 paid, approximately $30, and you'll note'that the $30 fee 24 is included in the original $100 fee.
25 COMMISSIONER CARR:
Does those costs take into (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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l 7
1 effect the cost of training and the. additional eight hours l
2 a year -- the initial training of those --
y4
]
3 MR. BECKELY:
No. sir, that's a separate item.
{
t 1
4 COMMISSIONER CARR:
Who pays'for that, normally?
5 HR. BECKELY:
TheLcompany.
1l 6
COMMISSIONER CARR:
The company does.-
7 HR. BECKELY:
And/or if the individual is his 8
own license, then he is the person --
9 COMMISSIONER CARR:
But that's a current cost',-
10
.except for.the eight hours, I assume?
11 MR. BECKELY:
-Yes, sir.
12 The CRCPD administrative costs were deemed to be
. ([,.
13
$10 per applicant, with the-total impact on the industry 14 at this point in time predicated to be $6.02 million.
O l
1 15 In conclusion -- would you pass these around to in. conclusion, upon ASNT Board of 16 the Commissioners 17 Directors' approval of the finances, ASNT will institute a 18 national certification program for industrial 1
19 radiographer. utilizing the State of Texas examination j
l 20 that would be proctored by ASNT or the CRCPD, for those l
I 21 states that are interested.
j 22 Where states proctor examinations, the CRCPD i
23 would broker the tests without ASNT involvement.
The 24 remainder of the states will be served by ASNT dealing 25 directly with the State of Texas.
Examinations to be (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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'l offered through cooperation between. interested public and I;
t5.
2 private organizations.
i 3
.ASNT agrees-to certify individuals examined by-4 states upon receipt and approval of an application and fee
)
5 from each' individual, including those previously examined-6 by the State of Texas.
7 ASNT would be the national certification
-r.
8 organization, with states recognizing the certification; 9'
ASNTs.'13 years of experience in certifying personnel will 10 assist in assuring uniform qualifications of the 11 industrial radiographer.
12 The above proposal is contingent on the concept
[
13 that the regulatory community will assure the viability cu.-
14 and effectiveness of ASNTs program, by developing rules 15 such that ASNT certification would be required in' all 16 states.
17 As an aside, the' Society believes that what has 18 been presented to you gentlemen this afternoon is 19 consistent with the staff regulatory position regarding 20 the subject matter.
Thank you.
21 CHAIRMAN ZECH:
Thank you very much, appreciate 22 it.
Questions from my fellow Commissioners?
Commissioner 23 Roberts?
24 COMMISSIONER ROBERTS:
A quick, obvious one, and
^ ~
25 I know the people in Texas will be here very shortly, but (202)234-4433 NEAL R.
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is the Texas test applicable to all the other 49 states?
2 Would it be just as proper for Alaska as Illinois, or 3
4 MR.
BECKELY:
From its technical content, sir, 5
yes.
6 COMMISSIONER ROBERTS:
Okay.
7 CHAIRMAN ZECH:
Commissioner Carr?
S COh'MI S SIONER CARR:
Yes.
That last paragraph 9
you've got there says that you're assuming we're going to 10 require everybody to do this, to make your program viable.
11 How do you stand on our one rule, two rule proposal there?
12 Wouldn't it solve your problem if we go in one step, a lot 13 easier than if we go in a half-step --
q 14 MR.
BECKELY:
I, personally and these 15 gentlemen can comment also, if you'd care to -- I don't 16 have any problem with the Commission adopting a rule that i
17 would provide the substance to have these people start 18 volunteering to do it on their own, followed by a rule 19 that makes it mandatory.
20 COMMISSIONER CARR:
Would that give you enough 21 assurance if we just said that meets our requirements for 22 qualification right now, and then somewhere down the pike, 23 when we get to that second rule, it will require it?
24 MR. BECKELY:
Well, we also recognize that if it 25 took too long to have that second rule come in, these (202)234-4433 NEAL R.
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things become old hat, a n d.. p e o p l e. n o longer want to L
1
. LL 2
' volunteer,.and you lose your substan'ce then.
3 COMMISSIONER CARR:
Okay.
4 CHAIRMAN ZECH:
All right.
Commissioner Rogers?
5
. COMMISSIONER ROGERS:
Well, just, really,'the--
6 it is a Texas test.
It's just the proctoring would be--
7 could be done by ASNT or CRCPD, is that it?
the same.
8 test, but it's.just a question of who would proctor-it?
9 MR. BECKELY:
Yes.
10 COMMISSIONER ROGERS:
No difference in the test.
11 MR. BECKELY:
No.
12 COMMISSIONER ROGERS:
Just a question on the G
13 term of " mood altering" substances.
Is that now the 14 accepted term f or ' misuse of controlled substances, or 15 alcohol?
16 MR. BECKELY:
Alcohol, drugs.
17 COMMISSIONER ROGERS:
Well, what's the status of 18 that characterization?
Is that the term of art here now 19 that's being accepted, or isn't it?
To me, it was a 20 little bit different from what we've seen in some of the 21 things that we've looked at.
.22 MR. PARLER:
I don't recall the term being used 23 in our fitness for duty -- in the Commission's Fitness for 24 Duty Rules So, it was new from that standpoint.
I don't
' ~
25 think it's new, it's just that --
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COMMISSIONER CARR:
I like it.
IL.-
~2 COMMISSIONER ROGERS:
Well, is it -- I guess I'm 3
not so concerned about whether it's new or not because 4
that may iust simply be whether I'm' familiar with it or 5
not, but whether it has an accepted meaning or not.
Is 6
there a certain vagueness to this that creeps in here?
7 MR.
BECKELY:
It was not our intent to make 8
anything-vague.
We certainly would have no problem 9
adopting the term that the Commiss!an --
10 COMMISSIONER ROGERS:
Well, no, I know it may 11 not be your intent, but how well established is the 12 meaning of what a " mood altering" substance, in fact, is?
h.
13 I mean. nave we got a list of them, or how does one know 14 what that is?
I mean, we know, maybe.
15 COMMISSIONER CARR:
My personal opinion, it's 16 more inclusive than drugs 9fd alcohol.
It would take in 17 glue-sniffing, for instance.
18 (Laughter.)
19 CHAIRMAN ZECH:
Mr. Doggart, do you want to 20 comment?
21 MR.
DOGGART:
- Yes, sir.
We included that 22 definition -- it's a new definition, we left it up to the i
23 Ethics Subcommittee to decide what mood altering 24 substances were, based on the due process rules that we've J
25 included in the program.
(202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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Historically, some ' radiography personnel have l-I 2
been under the influence of alcohol and'other drugs, and 3
we' feel like that has been part of the reason why.some of.
4 the accidents have-happened.
5 So, it's not clearly defined.
We don't have a 6
list.
I think when we are forced to deal with the-issue, 7
we will develop that list and decide upon it at that 8
point.
9 We do 'have a field process where, if an 10 individual objects to a decision by the Ethics 11 Subcommittee, the Board of Directors ultimately makes the 12 decision, and that decision is final at that point.
13 CHAIRMAN ZECH:
All right.
Thank you.
14
- COMMISSIONER ROGERS:
So, you're going to face 15 it when you have to face it, I guess.
16 MR. DOGGART:
Yes.
1 17 CHAIRMAN ZECH:
Anything else?
18 COMMISSIONER ROGERS:
No, I guess I have no 19 other questions.
20 COMMISSIONER CARR:
Can I have one more 21 question?
22 CHAIRMAN ZECH:
Yes, please, go ahead.
23 COMMISSIONER CARR:
I was a little bit concerned 24 about automatic renewal.
Do you ever plan to retest?
7._
- ~
25 MR. BECKELY:
Yes.
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. COMMISSIONER CARR:
A guy has been an active, 2
-practicing guy, he just comes in. and applies and says--
3 shows he's got his eight hours of. training and --
4 MR. DOGGART:
In the certification section, sir, 5
we have some requirements on continued participation in 6
the industry.
If an individual meets those requirements, 7
I believe it is 24
.I the last 36 months before 8
decertification is viewed --
9 COMMISSIONER CARR:
I saw that.
10 MR. DOGGART:
-- six of the last 12 -- we feel l
11 like he's involved where he doesn't need to go through the 12 examination process again.
(
13 COMMISSIONER CARR:
And you count on the eight 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> a year continuing training to keep him up-to-date in 15 case things change then, huh?
16 MR. DOGGART:
That's correct.
17 MR.
BECKELY:
It's not a situation that one 18 should look at and say that it's an automatic renewal, 19 based on just a couple of things happening.
One would 20 look also at the industry that these people represent, and 21 look at their applications in detail, et cetera, and 22 obtain additional pieces of information that would lead an 23 individual to the proper conclusion, that the activity has 24 been there. and safe practice --
l 25 COMMISSIONER CARR:
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as long as the guy's-an honest wot ker, he's been working l
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2 for the last.three years in the business and. continuously, 4
3 then he would expect his application to be renewed when he 4
paid his $100.
5 M R'.
DOGGART:
Upon verification that the 6
application is correct.
7 COMMISSIONER CARR:
Yes.
8 MR. DOGGART:
We verify the experience and go 9
'through references, the procedure that we've used for 13 10 years in other areas.
11 CHAIRMAN ZECH:
Commissioner Roberts?
12 COMMISSIONER ROBERTS:
My question is'for Bill f,
13 Parler.
Did the agency h&ve any difficulty in t --
14
. establishing within our regulations, one entity to perform 15 this service?
16 MR. PARLER:
You mean that would be applicable 17 everywhere?
18 COMMISSIONER ROBERTS:
Well, how do we know 19 there's not another -- maybe I'm being too hypothetical--
20 somebody other than the ASNT who is dying to do this?
21 COMMISSIONER CARR:
Competing operation.
22 MR.
PARLER:
Oh,
- well, that's a kind of a 23 problem such as Mr. Thompson alluded to at the beginning, 24 and the Commission went through that in another context
'~
25 some years ago, so that would be something that would have (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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to be looked at.
2
_Normally, if we are dealing - with somebody, if 3
there are others that are interested in doing it and we 4
are responsible for the program, you go out and, in 5
effect, solicit entries of proposals, and then make your.
6 selection on the basis-of applicable criteria.
I don't 7
know whether there is other interest or not.
I thought 8
the question you were asking me is, onco we put the 9
program in effect, could we make it a uniform requirement 10 for everyone, including Agreement States, which is a 11 separate question.
12 COMMISSIONER CARR:
But is this any different
_g 13.
than buying an ASME standard and buying an ASNT standard?
14 COMMISSIONER ROBERTS:
I don't know, I just 15 asked the question.
16 MR. PARLER:
What's that?
17 MR. BECKELY:
Yes, there is some difference.
18 MR. PARLER:
I would say we're talking about an 19 approach by an organization to perform a service for an 20 industry, which is important.
21 COMMISSIONER CARR:
Well, I was thinking that 22 they are really providing a standard for the industry.
23 MR.
PARLER:
Coming up with a program which 24 would satisfy a requirement for training which we now have 25 in the regulations.
The question was put to me, whether (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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and the answer to that is, I do not know.
Maybe Mr.
3 Thompson and his colleagues know.
I do not know.
4 COMMISSIONER ROBERTS:
I want to pursue this.
5 MR. PARLER:
And if we don't know, how do we 6
proceed?
7 COMMISSIONER ROBERTS:
Thank you.
8 CHAIRMAN ZECH:
All right. Anything else?
9 COMMISSIONER ROGERS:
Yes.
Well, maybe this is 10 the-point, but that our staff noted in the March 11 Commission' paper, that the ASNT Board of Directors delayed 12 its decision on the certification of the program earlier,
'A9 13 due to certain legal concerns raised by your attorneys.
23 14 Could you share with us what they were, or are they not 15 relevant to what we're looking at now?
16 MR. BECKELY:
Mr. Dewey?
17 MR. DEWEY:
I don't believe they're relevant.
18 It was a matter of education of our legal department, on 19 how certification programs work, and once we understood 20 how these things work, we felt that in addition to our 21 excellent history with our current program, that we would 22 have minor problems minor legal problems with the 23 program.
24 COMMISSIONER ROGERS:
All right.
25 CHAIRMAN ZECH:
Any other questions?
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2 All right.
Thank you very.much, gentlemen, we 3
appreciate it'very much.
'4 (Whereupon, the representatives of ASNT left the 5
table and representatives of the Texas Bureau of. Radiation 6
' Control and Conference of Radiation Control Program 7
. Directors were seated at the table.)
8 M R..
KAMMERER:
Chairman Zech, Commissioners 9
Roberts, Carr and Rogers, we're pleased to be here this 10 afternoon. My role is twofold:
one, to congratulate Vandy 11 Miller on a superb job on this issue, both on its 12 continued success and, more importantly, since he's become g
13 Assistant Director for Agreement States in our office, and 14 to introduce the speakers at the table here.
15 On the left is Lacker, and he'll give what the 16 Texas experience has been on the test and, on right here, 17 Chuck Tedford, whom you know, Mr. Chairman, as the Chief 18 of the Radiation Control Program in Arizona, and also the 19 Chairman of the CRCPD, and he has with him two other 20 individuals who may wish to add answers to questions, 21 Chuck Hardin, the Executive Secretary, and Ronny Wascomb, 22 from Louisiana.
23 CHAIRMAN ZECH:
Thank you very much.
Who wants 24 to begin?
25 MR. KAMMERER:
Mr. Lacker.
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Mr. Lacker, welcome.
You may
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3 MR.
LACKER:
It's a pleasure to be here, Mr.
l 4
Chairman and commissioners.
I'll give you a brief'
,5 overview of-our experience with our testing program.
l l
6 In January of 1987, our Bureau of Radiation 7
Control became the first entity to implement a cohesive 8
testing program for industrial-radiographer as a means of 9
improving and verifying knowledge and awareness of 10 radiation safety.
11 This testing program requirement was one of many 12 major changes made to our Texas industrial radiography 13 rules which became effective in October of 1986.
The 14 requirements concerning the testing program and
.15 radiographer qualifications were adopted in direct 16 response to the radiation safety record of the industrial 17 radiography industry.
18 Investigations by Texas, the Nuclear Regulatory l
-1 19 Commission and other Agreement State inspectors have 20 in'dicated that inadequate training of r,adiographers may be 21 the significant contributing cause to the reported 22 overexposure incidents, and these are high, as you know.
23 The new Texas rules address this problem in 24 several ways.
- Now, a radiographer trainee must have
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handling any sources of radiation.
Possession - of an ID p
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card alone does not mean that an individual is a qualified 3
radiographer.
4 To be recognized as a radiographer by the State 5
of Texas, an individual must complete all the training 6
required, submit the. appropriate documentation and pass-7 our exam.
The purpose of the Texas industrial radiography 8
safety exam is to assure that each and every ' individual j
9 authorized to work at an industrial radiography site has 10 the basic information and knowledge to work safely.
l 11 To date, over 2,200 exams have been administered-12 to more than 1800 individuals.
These numbers include j
g 13 individuals from 17 states in addition to Texas.
All of-i 14 the agency-administered exams are developed from a bank of 15
. validated, safety-related items.
The items were created 16 by the Bureau staff members and collected from training 17 courses utilized in industrial radiography, from other 18 regulatory agencies, and from various training materials 19 utilized in radiation safety courses.
I 20 This is an ongoing process as the agency 21 continues to expand and improve the item bank.
Exam items 22 relate only to radiation safety and, thus, all the items j
23 in the bank are categorized according to those subjects of 24 instruction outlined in our Texas Regulations for Control 25 of Radiation, the suggested State Regulations for Control (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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and the 10 CFR 34,. Appendix A.
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portion of the item bank was' developed with monetary aid 3
from the NRC, which we appreciate.-
4 Now, the current status of our testing program,.
5 for ' each session, three different exams are created, or.
6 can be created..One contains safety items related only to 7
the use of radioactive materials, one deals only with 8
safety items related to x-ray machines and the third has 9
items'concerning both x-ray and radioactive materials.
10 Each exam consists of 125 four-choice multiple-11 choice ' items.
Twenty-five items on each exam are 12 provisional.
The provisional items are those that 'have 13 not been va'lidated.
They are randomly distributed l
14 throughout the exam, and the radiographer are not aware 15 of which ones they are.
These provisional items are not f
16 graded but are analyzed using psychometrics procedures, so 17 in this manner new items may be continually validated and 18 the item bank expanded.
Thus, each radiographer's score 19 is based upon 100 active or previously validated items.
j 20 Exams are now administered in Austin once a 21 month and an average of 50 people attend each session.
22 The overal.
average failure rate is 18 percent.
The 23 overall average score for the radioactive materials exam 24 is 75.
The average score for the x-ray machines exam and 7
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25 the exam for both testing devices are 79 and 82, (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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(2 Changes we.' ve seen due to the. testing program.
3 We' began testing -- began issuing notices' of violations 4
for non-compliance concerning:the safety-exam in' March of b,
5 1988.
There has not been suf fician't ' time elapsed since
'6 then'toLdetermine any valid' correlations between trends in:
7
~ inspection reports and. the testing : program.-
However,-
8 there' have been several situations in which an agency o
9 inspector terminated operations at a' job site because the 10 individuals did.not have ID cards in their possession.-
^11 Agency inspectors have reported observing
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12 individuals studying resource materials on the job site.
13 This is very encouraging in terms of increased knowledge 14 and awareness of radiation safety.
The Bureau of.
15 Radiation-Control has suspended one individual's ID card-16 and.is currently considering suspension of two more.
In 17 each case, our inspectors have' documented a willful intent' 18 to violate rules.
19 Similarly, there has not been enough time 20 elapsed since January 1st,
'88, which was the date by 21 which all radiographer must have been tested, to 22 determine what impact the testing program has had on 23 overexposure incidents.
However I've given you two 24 figures and Figure i shows the number of exposures i
25 greater than 3 rem per quarter reported to the agency from (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 l
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1979 to 1987, and Figure 2 shows the reported exposures V[
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greater than 25 rem per quarter.
The figures include 3
- 1986, the year in which the training and testing
(
)
4 requireme.its became effective.
i j
5 In both figures, the shaded areas represent 6
exposures to " assistant" radiographer.
I now have '88 7
figures and for greater than 3 rem, tn re were ten total 8
reported overexposure greater than 3 rein per quarter, and 9
zero greater than 25 rem in 1988 and 1987.
l 10 The agency feels that the downward trend in 11 overexposure is due to two things.
With the decline in 12 oil prices, the Texas economy and, therefore, available 23 jobs in the radiography industry also declined.
In 14 addition, when the new rules were adopted.
individuals 15 began preparing for the state exam.
People were being 16 trained and retrained, creating an increased awareness of 17 job safety.
18 The agency also believes that the decrease in 19 the number of exposures to what were then assistant l
20 radiographer is directly related to the new rules.
We 21 don't have assistant radiographer as a class anymore, we 22 have radiographer trainees.
These were previously those 23 as in the regulatory business as helpers or assistants, 24 and these must now pass an agency-approved safety training p
c, 25 course before handling sources of radiation.
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1 COMMISSIONER ROGERS:
Before you leave those 2
graphs, do you have any comments on '83 being so low?
l 1
3 MR. LACKER:
No, sir, it's sort of an anomaly.
4 The reason I couldn't really -- we don't have a valid' data i
5
-- a reason for that, but I think it is significant that j
6 starting with 1984 there's a continual downward trend, and j
7 that was when the industry 'in Texas first became aware 8
that we were going to have this rule that would require i
9 certification, and the trainers, those people. providing l
10 training in the Appendix A radiation safety thing, started 11 upgrading their training programs, and not really making 12 the answers to their exams available prior to the test.
g
.13 That's our personal opinion, but' there has been a steady 14 decline.
As I said, we're not really ' positive how much 15 impact the economy decline due to the oil crisis impacted 16 that but, certainly, in 1988, the economy was beginning to 17 stabilize and, yet, we had no over 25 rem exposures and 18 only a very few greater than 3 rems in~a ten l
19 quarter.
20 As I mentioned earlier, the possession of an ID i
21 card alone does not mean an individual is a qualified l
22 radiographer in Texas or that he or she will not be 23 overexposed.
The new Texas rules are meant to correct a l
24 lack of knowledge and training, and provide a means of l
l 25 determining compliance with the training requirements.
l l
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The future of our testing program.
We're.
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planning to continue to test industrial radiographer 3
working in Texas.
Many other ' Agreement States have 4
expressed an interest in adopting similar rules, including 5
a testing program.
The agency is currently negotiating 6
with the Conference of Radiation Control Program 7
Directors, to provide extm development and administrative i
8 services to radiatien control regulatory agencies.
9 Those regulatory agencies would, in turn, 10 administer the exams to those radiographer they regulate.
11 With this type of program, all exams would be developed-i 12 using..the same validated item bank.
Not only would this 1
.i 11 provide a nationwide consistency in testing, but I
14 reciprocal recognition of radiographer across state lines 15 would be made simpler.
16 We have also received a proposal from the ASNT 17 concerning their administration of an industrial 1
18 radiography safety exam.
The proposal calls for us to be j
19 the sole provider to ASNT of exams and grading services, 20 There would also be reciprocal recognition by ASNT of the 21 Texas test and vice versa.
We are prepared to proceed 22 toward formalizing the proposal in contract when the 23 Commission approves a National Certification program.
24 The interest in our testing program shown by the 25 Commission and other Agreement state regulatory agencies (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6630 1323 RHODE ISLAND AVENUE, N.W.,
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concern over the safety history of industrial radiographic commi tmen t j. to iraproving# that record.
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operations and a L.
4 Thank you.
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CHAIRMAN ZECH:
'Thank you gery much.
Anything
)
6 else, gentlemen?
1 r
7 MR.
KAMMERER:
We'd be happy to entertain 4'
8 questions of them, or go right to Mr. Tedford.
9 CHAIRMAN ZFCH:
All right.
Fine.
Let's go
{
10 ahead with Mr. Tedford.
First,. Chairman Zech, I'd like to 12 thank you, Commissioner Carr, Commissioner Roberts, g
13 i Commissioner Rogers, for the invitation to attend and 14 brief-the Commission today, and it's a pleasure for me,to 15 address the role of the Conference of Radiation Control 16 Program. Directors,'for which the acronym is CRCPD anEl to 17 which I will refer from now on as the Conference in my 18 short presentation, and to address the role on testing of 19 industrial radiographer of the Conferenet.
20 The Conference is comprised of the Directors of j
21 the Radiation Control Programs of the 50 states, the l
i 22 District of Columbia, New York City, and Puerto Rico.
The 23 Conference considers the issue of national certification 24 of radiographer to be of great importance.
In large 25 measure, the health and safety of our citizens depend upon (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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ths aucesosful resolution of thic mottor of mutual
.ET-E U-2 concern.
3 History has shown that a high percentage. of 4
radi'ation incidents and accidents have occurred in the p
5 field of industrial radiography.
Many of these incidents l
b 6
'and accidents were' caused by the lack of proper training 7
by those who actually perform the radiographic procedures.
8 The thrust of this program is to recognize and 9
certify individuals who have demonstrated an understanding 10 of radiation protection principles and practices in the 11 use of radioactive sources.
The states and, in 12 particular, those states which have an agreement with the 13 NRC.and the NRC have recognized the need for a national 14 program since 1975.
Accordingly, the Conference applauds 15 the NRC for the effort to develop a national industrial 16 radiographer certification program.
17 Just a word to the side here, on something that 18 doesn't principally concern this Committee that is, l
19 it's not in the field of radioactive materials, but it's a
)
i 20 vitally important topic and it's been addressed earlier, 0
21 and that is that machines produce radiation -- that is, x-22 irradiation is also used for industrial radiography.
23 The Conference is as concerned for proper safety i
24 from machine-produced radiation as for radiation produced l
g--
l 25 from radioactive materials, and any national program is I
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encouraged to place equal importance on both types of 2
radiation sources.
The certification program should 3
encompass and 'qualif y the individual for machine and 4
radioactive material sources, both.
5 It should be noted that the Texas Radiographer i
6 Testing Program has established a positive precedent for 7
this area of concern.
They have developed exams for the 8
x-ray and for the radioactive material part of the 9
program.
j 10 Gentlemen, the Conference i' in a unique 11 position relative to this issue, since Conference 12 represents all states, both Agreement !
.tes which g\\
13 currently now number 29, and non-Agreement States.
14 Additionally, the Conference is not restricted to 15 particular radioactive materials covered by the Atomic 16 Energy Act, but can address all radioactive materials, 17 including Naturally Occurring and Accelerator Produced 18 Radioactive Materials, NARM, which you are quite aware of l
19 our concern in this area as well, and machine-produced 20 radiation sources.
21 And because of this unique position, the State 22 of Texas has requested the Conference to consider 23 brokering the Texas-developed Industrial Radiographer Test 24 to those states with an interest in administering the 25 test.
And the executive board of the conference has i
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4 purpose.
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_ primary negotiator. and arbitrator in this area, and so 6
he's sort of on the oroad end, and one,of the reasons he's 7
here today is because.he's done most of the work in this
.8 area for us.
9 I want to spend just a minute on the basic l
10 concept of how we and the states envision this program 11 would occur.
The basic concept of the conference role is 12 as follows.
When a state has an interest in. administering 13 the Texas test, the program director of that state, who is 14 also'the member of the Conference, will.act on behalf of-
.15 the conference in administering the test.
Texas will 16 train state proctors.
The state administering the exam 17 will' subsequently establish a testing time and place, and 18 determine the number of individuals to be tested.
19
- Then, through the Conference, the interested 20 state will receive the specified number of tests from the 21 State of Texas.
The conference member in the interested 22 state, or designated representative, will administer the i
23 test, using'this trained proctor.
The state will collect 24 the completed tests and mail them to Texas for grading and
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The results of the test will then be sent to (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W.,
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V yMN i:- ), [ ' 55 JM I 1 the national certifying body, the ASNT in this case,'with j j ~; 2 copies of the results provided to the state which 3 administered the test. The state member of the conference { 4 will have responsibility for the security of the tests. i 5 Gentlemen, the Conference strongly believes that-l 6 states who desire to administer the test should be given 7 the opportunity. The use of the Conference as a broker 8 will provide for an expedient procedure in obtaining the 9 test from Texas With the Conference as the broker, a 10 separate contractual document will not be necessary j 11 between Texas and the other states, all the other states 12 desiring to use the test. (g 13 Again, gentlemen, please accept my sincere l 14 appreciation and compliments for the concerted, stellar l 15 efforts by the NRC to establish a national certification 16 program for individuals performing industrial radiography. 17 I would be remiss if I did not mention some of 18 those who have been down in the pits, and I think most 19 directly involved for the NRC, and they are Glen Sjoblem, 20 Mr. Kammerer to my left here, and Mr. Vandy Hiller. Those 21 people are the ones that where the rubber has met the road 22 with the Conference, and they've done a stellar bit of 23 work, Mr. Chairman. 24 CHAIRMAN ZECH: Thank you, appreciate knowing 25 that. (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
+ d lsh.'^' a f .ly.y;; 56,q .: 9 -. o 1 MR. TEDFORD: The establishment of a national W f-2 certif ying/ testing ; program for industrial radiographer 3 has been under consideration for the last several months 4 by the NRC, the State of Texas, the American Society for 5 Nondestructive Testing, ASNT,.and the Conference. 6 In summary, Mr. Chairman, the Conference will 'i 7 cooperate in making this national certification effort an 8 effective, workable program. l 9 I'll be pleased to entertain any questions that 10 you or the other Commissioners would have, and I have the 11 two individuals with me Mr. Wascomb is from the State 12 of Louisiana, I should add. He is also representing the 13 29 Agreement States, and he's also on one of our 1 14 committees that is principally involved in radiography j 1 f 15
- work, 16 CHAIRMAN ZECH:
Thank you very much. Does that I 17 conclude the presentations? 18 MR. KAMMERER: That concludes the presentations, 19 Mr. Chairman. l 20 CHAIRMAN ZECH: I would ask any questions from 21 my fellow Commissioners? Commissioner Roberts? 22 COMMISSIONER ROBERTS: No. I 23 CHAIRMAN ZECH: Commissioner Carr? 24 COMMISSIONER CARR: No. o - 25 CHAIRMAN ZECH: Commissioner Rogers? (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
1 i {- ' s dM g E r.* p + 4 L. 3- @ @ 4e 4^ t' -W< y;: t - 5.7 ; 1 COMMISSIONER ROGERS: Weil, I don't know. I'm a -p - L f_ 2 little confused here as to how this whola thing is 3 supposed to work, with the Conference and the ASNT, or 4 whether it's not supposed to work together with the two, 5 and do you see yourselves in conflict with the point of i 6 view presented by the ASNT in terms of how these tests i 7 would be administered? 8 MR. TEDFORD: No, sir, I do not believe we're in 9 conflict. I believe that the vote, as I understand it, 10 incurred with ' ASNT, is that ASNT would get those tests ] i 11 from Texas for the states that did not desire ' to 12 participate, but that the states that desire to 13 participate, I've just covered the mechanism whereby that i 14 could occur, so I think both are covered. 15 COMMISSIONER ROGERS: So, you'd cover the gap of 16 those states that would want to do this themselves?. 17 MR. TEDFORD: Yes, sir. 18 COMMISSIONER ROGERS: In other words, you'd be 19 the broker for them. 20 MR. TEDFORD: The Conference would be the 21 broker, yes, sir. 22 COMMISSIONER ROGERS: The Conference would; I 23 see. So, basically, you have three organizations involved 24 in this the State of Texas, the ASNT and the i 25 Conference. (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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i; u.33y ? .g.c 4 4,m -e .gg 58q g 4 1 MR. TEDFORD: Yes, sir, you might look at it in 2 that perspective, or there would be two involved the other J 3 way, or two each way you would look at it. 4 COMMISSIONER ROGERS:
- Well, they're linked 5
together in various ways, 6 MR. TEDFORD: Yes, sir. 7 MR. LACKER: Mr. Chairman? 8 CHAIRMAN ZECH: 'Yes, go ahead. 9 MR. LACKER: If I might address Comraissioner 10 Rogers,-from Texas' pr.rspective, we have the exam. It's 11 validated using appropriate test methods to validate test -12 questions, and our major input here would be that we're 13 prepared to deal with the Conference, AShT, to provide 14 that test and the grading and that sort of thing, and our 15 test is a dynamic test that we're continually developing 16 new valid questions, so that it is not just a -set of 17 questions. Right now, we have over 600 items in our 18 questions. 19 COMMISSIONER ROGERS: And you'd propose to 20 continue this process of 125 questions with 25 new ones 21 that are invalidated and a way of validating those. 22 MR. LACKER: We intend to continue to validate 23 new questions, and those questions requiring calculations, 24 we would change the numbers and maybe change -- we do ^ ~ 25 that. This is just a -- (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
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y 'jgy; Unift{ $ { r p, ;.59, aJ 1 COMMISSIONER ROGERS: It sounds like ' a. good e-; ,2 technique.. i 3 _MR. LACKER: just to' keep the test f rom - 4 getting stale. 5 COMMISSIONER ROGERS: Yes, of course. Well, it 6 does seem to me that, you know, the initiative shown by 7 the State of Texas here is a.very commendable one, and 8 that it's a real. leadership effort that you've stepped out 9 and done something in an area that needed something to be. 10 done,-and I think we really are'very,much indebted to that-11 . kind:of a forward look and forward initiative. I 12 MR. LACKER: Thank you. -({$ 13 COMMISSIONER ROBERTS: And I want to make sure 14 you understand, I wasn't implying any deficiency in your 15 l 16 MR. LACKER: Oh, I understand. I understand, 17 COMMISSIONER ROBERTS: You are obviously the 18 leader. 19 COMMISSIONER CARR: Each state then would have 20 its own practical exam? 21 MR. LACKER: No, sir. 22 COMMISSIONER CARR: Who does -- who -- 23 MR. LACKER: The ASNT would take care of the 24 practical exam requirements. All we would be doing, the 25 states, would be -- well, I can only speak for Texas -- we (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 j
i n 9 2, requireme[ritis.'foresrtification woulN'$e done %yl !- l 3 CHAIRMAN ZEC': %You'd give the written tes't. H 4 MR. LACKER: We'd give the. written test. 5 COMMISSIONER CARR By some ASNT-blessed entity m 4 t in the state. 6 \\ 7 MR. LACKER: Yes. 8 COMMISSIONER CARR: Somebody wouldn't. g go around to the various states, but they'd t' have some -- ,T 10 u.;.- l I'm not sure those details havej.' s 11 MR. LACKER: a 12 been worked out, on how they plan to -- [. 13 MR. MILLER: I can answer that.
- 4 f.I i 14 CHAIRMAN ZECH:
Go ahead. i f,J 7. 15 MR. MILLER: ASNT would put h, C
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18 licensees who have good practical tests already and,2if, j g ll 19 ASNT blesses those, then they would be,%he ones that would ii do the practical test for ASNT. 20 - s 3 CHAIRMAN ZECH: All.right. Thank you. 21 r How many Agreement and non-Agreement States 22 23 license radiography operations now? l 24 MR. HARDIN: Ted, do you have your list? l 25 MR. TEDFORD: The list I have here, Mr. ) l i
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.y qg-t .n m;p,61 - j 1 Chairman, may not directly answer that question, but we ] I k L-2 have conducted a survey and, of those Agreement States, j J } 3 the states that would give a test, 25 would give a test 4 and 20 would use the Texas test and, Mr. Hardin, how many 5 6 MR. HARDIN: I think the question was, how many 7 actually are licensed, and this particular number doesn't 8 address that, but those in our inquiry and our survey, we 9 found that 25 of those did have interest in administering 10 a test. 11 CHAIRMAN ZECH: Twenty-five Agreement States? 12 MR. TEDFORD: Of all states. { 13 HR. HARDIN: No, sir, of all states. 14 CHAIRMAN ZECH: Total. Total number of states, 15 25 have an interest in administering this test? 16 MR. HARDIN: Yes, sir, 16 of those are Agreement 17 and nine being non-Agreement. 18 CHAIRMAN ZECH: How about the other states? 19 HR. HARDIN: They have either indicated that 20 they had no interest in doing it or, in some cases, they 21 had some qualifications that they wanted to have further { 22 consideration before they made a decision. 23 CHAIRMAN ZECH: Well, by saying they have no 24 interest in it, could you speak to that a little bit? 25 MR. HARDIN: Yes. It would be the assumption (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 / )
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~fPY .E'i? W, = yff*fhhh fv ' yu } i e k ' >:3f* ' Ly'[(. j ' \\ '4j 4.? ,e h ~, 1 that for-those who did not have the desire to give the Q I 2 test, then the ASNT or -- 3 CHAIRMAN ZECH: The ASNT would give it? o 4 MR. HARDIN: Would give it in those particular l 5 6 MR. TEDFORD: It's either/or. 7 CHAIRMAN ZECH: I see. I see. All right. 8 COMMISSIONER ROGERS: Could I just pursue this a 9 little bit -- 10 CHAIRMAN ZECH: Please, go ahead. 11 COMMISSIONER ROGERS: because when we start 12 talking about tests, there really are two kinds of test. h 13 There's the practical examinations and then a written 14 test, and when we're talking about this, I want to make 15 sure I understand the differences between those with 16 respect to the roles of the states, the role of the 17 Conference and ASNT. 18 Now, are you saying that you would be brokering 19 up the use of a test by a state that wanted to give a 20 written exam? And what about a practical exam in that 21 same state? 22 MR. TEDFORD: As I understand it, Commissioner 23 Rogers as was covered in the ASNT briefing ASNT 24 would give the practical examination in all states, for 25 all states. ASNT would do the background investigation (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
1[ 'r *[ 'j, 3 e 63 s.4 1 for all states.- Those states that desire to b'roker the D i k-2 exam through the. Conf erence, would administer the exam, I 3 and'those that did not, ASNT would get this directly from 1 I 4 Texas and would administer the exam, i 5 COMMISSIONER ROGERS: Okay. I think that helps 6 to clarify the picture. 7 CHAIRMAN ZECH: Could someone address the issue 1 8 of how do you look to the problem of a radiographer who I 9 may have had a license suspended in one state. How is 10 that information transmitted to other states so that you 11 can prevent someone who is not doing a good job in one 12 state, from all of a sudden showing up in another state? 13 MR. TEDFORD: Yes, Mr. Chairman, we have a 14 reciprocity requirement across the states, generally 15 speaking. This was another thing of interest that I had 16 not heard, was the civil penalty that would be levied from 17 the ASNT because civil penalties are also applicable in 18 certain states, if you will. 19 CHAIRMAN ZECH: But you do have a system, and-- 20 MR. TEDFORD: Yes, sir. 21 MR. KAMMERER: Texas will have a computer-based 22 information system. 23 MR. LACKER: Our database for this testing 24 program has all that data, and we can -- i. 25 MR. TEDFORD: It will be conveyed. (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600
"9 ighkkwgqi{gyh-ph t gap 4y 7,Jy;: j. p.4 ,6p V - p c,g .Qg ,3 1 MR.- LACKER: ,we can send it to the ?') ' 2 appropriate authorities. 3 CHAIRMAN ZECH: 'It will'be transmitted to other g 4 states. '5 MR. TEDFORD: -And we do. have a reciprocity j 6 program in even industrial radiography licensing. 7 CHAIRMAN ZECH: All right. Thank you very much. 8 MR. MILLER: Mr. Chairman, we have to keep in 9 mind, though, that there's only going to be one national 10 certification, and it's the issuing agency that is the 11 only one that can revoke that certification, so it would 12 be ASNT's record that showed that an individual has had I h 13 his certification revoked, and that information must be 14 made available to all regulatory bodies. And that's not 15 quite worked out yet, but that will be worked out. 16 CHAIRMAN ZECH: That's intended? 17 MR. MILLER: Yes, sir. 18 CHAIRMAN ZECH: All right. Thank you. 19 MR. TEDFORD: I think, Mr. Chairman, the bottom 20 line is that we haven't worked out all the fine 21 particulars in the case, but I think that the general 22 thrust and the intent is here of what we'd like to do and, 23 if we can sit down at the table and work out the pictures, 24 I think they will come out. 25 COMMISSIONER CARR: We'll be licensing the (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
,yg 5 .q,.hh[k yjys ' W 14%s$@rc T 7 4p g 6N y 1 holder, they'll=be licensing the operator, as I understand FLi 2 it. 3 CHAIRMAN ZECH: All right. Any other questions '4 from my fellow Commissioners? 5 COMMISSIONER CARR: I think it's a.very 6 commendable approach on all their parts, to get something 7 moving. I wouldn't be surprised that Texar is the only 8 outfit licensing anybody right now, as far as operators. 9 MR. LACKER: Let me clarify one. thing. We do 10 not - certif y the radiographer. We issue n. photo ID to 11 each person who has passed our examination, and we have in 12 our rules the right to revoke that and all the appropriate ] 13 hearing procedures. 14 COMMISSIONER CARR: Is it illegal.. in Texas, to 15 hire somebody without one of those? 16 MR. LACKER: Now, as of January 1st of 1988, and 17 this, we think it was necessary because, in the past, we 18 could order a company to suspend a radiographer, or he was l 19 suspended from doing work because he had a bad safety 20 record, but he could go down the street and get a job. 21 Now, if he loses that ID, under our rules, he 22 would be -- 23 COMMISSIONER CARR: He has to go across the 24 border now. 6 _ 25 MR. LACKER: -- he has to go to some other l (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 l 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005 i L r
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f l Q;; s 66 .a I state. 2 COMMISSIONER CARR: Right. 1-3 MR..TEDFORD: The' follow-on to this, 'Mr. 4 ChEirman, if'I might, is that the states do need to get' 5 laws'on-line and rules to implement ~this national program 6 that is brought about, and that will be a down-the-road 7 state. 8 COMMISSIONER CARR: Compatibility. 9 MR. TEDFORD: Yes, sir. 10 CHAIRMAN ZECH All right. Any other questions?- ( 11 . No. response.) 12 Does this conclude the' briefing.this afternoon? h 13 MR. KAMMERER: Yes, sir, unless. you want the '14 staff to come back. 15 CHAIRMAN ZECH: I don't know. there 's any need 16 for that, is there? No, I think not. 17 MR. KAMMERER: No. 18 CHAIRMAN ZECH: Well, let me just, on behalf of 19 the Commission, thank all of our presenters here today. 20 e It's been a very, very informative briefing on a very 21 important subject. 22 I'd like to especially thank the representatives 23 from the American Society of Nondestructive Testing, the 24 Texas Bureau of Radiation Control, and the Conference of 25 Radiation Control Program Directors, for taking the time (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, EC. 20005
l, 9-L ys. + j$gg. g QQ[ Q[ y .$, g c.5,gy$ m 1 to parti ipate'today in our meeting. F 2 I'd like to thank the staff for their pursuit of 3 this important matter, all of those involved. Radiation 4 safety is an area of concern to the Commission, and one 5 that we are continually seeking ways to improve in. 6 The Commission really recognizes that we have 7 more people injured in the area of nuclear materials than 8 we do in the area of nuclear power reactors. That's facts 9 and shown by -- 10 COMMISSIONER CARR: At least radiated. Maybe 11 not injured, but radiated. 12 CHAIRMAN ZECH: -- potentially injured, and h 13 occasionally injured, I think, and not very often, we 14 know, but it's certainly the potential is there. So, 15 it is a very important area which we want to try to 16 improve in, and this is why the Commission, itself, has 17 been addressing itself in recent months, more aggressively 18 to this area. 19 In the area of radiography certification, I l 20 personally believe that a certification program could 21 better assure that individual radiographer meet the 22 minimum training and experience criteria in order to have 23 an acceptable knowledge of radiation safety in order to 24 better protect themselves and the general public. 25 I would like to ask the staff to carefully (202)234-4433 NEAL R. GROSS & COMPANY, INC. (202)232-6600 1323 RHODE ISLAND AVENUE, N.W., WASHINGTON, D.C. 20005
~, t' y 68 1 ravisu tha ' final ASNT certification program and ' issues 2 .we've discussed here today, and provide a recommendation 3 to the Commission at the appropriate time. 4 ~ I'd like to particularly thank the individual .5 presenters here, all of you, from all the societies, who 6 have individually and collectively contributed so much 7 to this important effort. It is, indeed, an important 8 program for our country, and the Commission is grateful 9 for your personal efforts. 10 My personal sense of the Commission is that 11 we've had enough talk in this area. I think the 12 Commission, if I read the sense of the Commission 13 correctly, we generally feel that the time is now for i 14 action, and that we should do something about it. So, 15 I'd say, let's get on with it, and move forward in this 16 very important area. 17 I do think that if the staff comes forward 18-with a well thought out presented recommendation, that 19 the Commission would receive it favorably. So, we'd ask 20 you to get on with it. ~ 21 Any other comments? l 22 COMMISSIONER CARR: Hearl Hear! 23 CHAIRMAN ZECH: All right. Thank you very 24-much. We stand adjourned. 25 (Whereupon, at 3:38 p.m., the meeting was adjourned.) NEAL R. GROSS COURT RfPoRTIRS AND TRANSCRIBERS 1323 RHoof 15 LAND AVINUI, N.W. (202) 234-4433 WASHINGTON. D.C. 20005 (202) 232 6600 r*D_^ __-_r
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f-p ,m, CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting i of the United States Nuclear Regulatory Commission entitled: TITLE OF MEETING: BRIEFING ON CERTIFICATION OF RADIOGRAPHER PLACE OF MEETING: ROCKVILLE, MARYLAND DATE OF MEETING: APRIL 5, 1989 j were transcribed by me. I further certify that said transcription is accurate and complete, to the best of my ability, and that the j-transcript is a true and accurate record of the foregoing events. _1A A4s s i - - V a .,?; Reporter's name: Phyllis Young i J NEAL R. GROSS COURT REPORTERS AND TRAMSCRitet$ l 1323 RH000 h AVINUf, N.W. gg zu.uss wAsHmefou, or 20005 (202) 232m
<t 8 4/5/89 SCHEDULING NOTES TITLE: BRIEFING ON CERTIFICATION OF RADIOGRAPHER . SCHEDULED: 2:00 P.M., WEDNESDAY, APRIL 5, 1989 (OPEN) DURATION: APPROX l-1/2 HRS PARTICIPANTS: AMERICAN SOCIETY OF NONDESTRUCTIVE TESTING (ASNT) 20 MINS - ROSS BECKELY CHAIRMAN OF THE BOARD, ASNT _ BOB DOGGART, CHAIRMAN INDUSTRIAL RADIATION SAFETY TASK GROUP, ASNT TEXAS BUREAU OF RADIATION CONTROL 15 MINS - DAVID LACKER, CHIEF TEXAS BUREAU OF RADIATION CONTROL - RUTH E. MCBURNEY j CONFERENCE OF RADIATION CONTROL PROGRAM DIRECTORS 5 MINS - CHARLES TEDFORD CHAIRMAN - CHARLES HARDIN NRC 15 MINS - HUGH L. THOMPSON, JR., DEDO - ROBERT BERNER0, NMSS - GLEN SJ0 BLOM, NMSS - VANDY MILLER, GPA/SLITP
' + ;. :: x I ['., d' ./' THIRD PARTY CERTIFICATION OF RADIOGRAPHER TO IMPROVE - SAFETY OF RADIOGRAPHY OPERATIONS BRIEFING OF THE COMMISSION APRIL 5, 1989 r ..s 1 l
I: - y. ..1 - t i 4 r OUTLINE OF BRIEFING STAFF PRESENTATION O RADIOGRAPHY SAFETY' ISSUES 0 CURRENT REGULATORY PROGRAM ON RADIOGRAPHY. SAFETY 0 STAFF PERSPECTIVES ON L TESTING / CERTIFICATION O PLANNED FUTURE ACTIONS ON CERTIFICATION-SLIDE 1 .m __. - _ _.J
(; s 4 (' j l i OUTLINE OF BRIEFING (CONT'D) INVITED PRESENTATIONS 0 OVERVIEW BY AMERICAN SOCIETY OF NONDESTRUCTIVE TESTING ON PLANNED INDUSTRY INITIATIVE FOR CERTIFICATION O.0VERVIEW BY TEXAS BUREAU OF RADIATION CONTROL ON RADIOGRAPHER TsSTING 0 OVERVIEW BY CONFERENCE OF RADIATION CONTROL PROGRAM DIRECTORS ON STATE PLANS SLIDE 2 I
T ~..,.- - 5 j 4 / f I 1 I / J l i e I RADIOGRAPHY SAFETY ISSUES 0 HIGH RADIATION LEVELS WHEN SOURCE OUT OF SHIELD 0 BASIC CAUSES'0F OVEREXPOSURE EVENTS 1 EQUIPMENT FAILURES FAILURE TO ADHERE TO PROCEDURES SLIDE 3 l _.-1-..
.5 "g r ), ' 4-6 i i '{ CURRENT REGULATORY PROGRAM ON RADIOGRAPHY SAFETY o LICENSING 0 ANNUAL INSPECTIONS o EQUIPMENT UPGRADES
- o. STRONG ENFORCEMENT 0
INFORMATION fl0TICES SLIDE 4 )
L 1 / STAFF PERSPECTIVE ON TESTING / CERTIFICATION 0 'PROVIDES NRC ASSURANCE OF RADIOGRAPHER'S TRAINING, KNOWLEDGE,. SKILLS, AND HAZARD APPRECIATION O IMPROVE PROFESSIONALISM 0 MORE RESPONSIBILITY TO INDIVIDUAL RADIOGRAPHER 0 STANDARDIZED NATIONWIDE TESTING SLIDE 5
,y 1 e i n. l4 FUTURE NRC ACTIONS'ON' CERTIFICATION 0 STAFF REVIEW FINAL NATIONAL j CERTIFICATION PROGRAM O CRUCIAL' COMMISSION ACTION: EARLY RULEMAKING RECOGNIZING CERTIFICATION AS MEETING PART 34 QUALIFICATION REQUIREMENTS 0- LATER RULEMAKING REQUIRING CERTIFICATION SLIDE 6 i
c.
- s i
i c { i i 1
SUMMARY
/ PROPOSAL UPON ASNT BOARD OF DIRECTORS APPROVAL OF FINANCES, ASNT WILL' INSTITUTE ~A NATIONAL CERTIFICATION PROGRAM FOR IRRSP UTILIZING THE STATE OF TEXAS EXAMINATION PROCTORED BY ASNT OR CRCPD FDR THOSE STATES INTERESTED.
SLIDE 1 +
- t t
3 WHERE~ STATES PROCTOR EXAMINATIONS, j 'THE CRCPD WILL BROKER THE TESTS WITHOUT ASNT INVOLVEMENT. THE REMAINDER OF THE 1.- STATES WILL BE SERVED BY ASNT DEALING DIRECTLY WITH THE STATE'0F TEXAS.. EXAMINATIONS WILL BE OFFERED THROUGH -COOPERATION BETWEENl INTERESTED PUBLIC AND PRIVATE ORGANIZATIONS. ASNT AGREESLTO CERTIFY INDIVIDUALS EXAMINED BY STATES UPON -RECE-IPT. AND APPROVAL OF AN APPLICATION AND FEE' FROM EACH INDIVIDUAL INCLUDING THOSE PREVIOUSLY EXAMINED BY TEXAS. S' rDE 2 4 l I 1 i _m-_-___,_--_-_i____----_-
c s i s g ASNT WILL BE.THE NATIONAL CERTIFICATION ORGANIZATION, WITH STATES RECOGNIZING THE CERTIFICATION. ASNT'S THIRTEEN YEARS OF EXPERIENCE IN CERTIFYING PERSONNEL WILL ASSIST IN ASSURING ' UNIFORM QUALIFICATIONS OF INDUSTRIAL RADIOGRAPHER. THE ABOVE PROPOSALS ARE CONTINGENT ON THE CONCEPT THAT THE REGULATORY COMMUNITY WILL ASSURE THE VIABILITY AND EFFECTIVENESS OF ASNT'S PROGRAM BY' DEVELOPING RULES SUCH THAT ASNT CERTIFICATION IS REQUIRED IN ALL STATES. SLIDE 3 i
,f l AGENDA L PRESENTATION TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION INDUSTRIAL RADIOGRAPHY RADIATION SAFETY PERSONNEL (IRRSP) CERTIFICATION PROGRAM APRIL 5, 1989 WASHINGTON, DC
- 1. IIISTORICAL REVIEW
' 2. OVERVIEW OF PROPOSED PROGRAM A. PART 1, CERTIFICATION REQUIREMENTS B. PART 2, RULES OF CONDUCT C. PART 3, COMPLAINT AND IIEARING PROCEDURES
- 3. IMPLEMENTATION COSTS
{ i
- 4. SUMM ARY/ PROPOSAL
' c.. b,lk THE AM ERIC AN SOCIETY FOR 5'f/ A?', 3 ?,,,, ,,fr.g? NONDESTRUCTIVE T E S T I N G, I N C. j 4153 ARLINGATE PLAZA
- CALLER 728518* COLUMBUS, OHIO 43228 0518 NATIONAL 1800 222 ASNT
- OHIO 1800 NDT OHIO + TELEX 245347 O
- - -, _. -. ~ - 6 gS - g. 2 1 l TIIIS PAGE IS INTENTIONALLY BLANK f I i I 1 l I 1 l I i I
M. 3.... 3 l 3, n.. 3 i '. IIISTORICAL ' REVIEW 1
- 1. Cause. of-concern over radiation. safety using industrial-l5 radiography =(No. of overexposure as. a function of L
percent.of licensecs)
- 2. : ASNTl response to NRC concerns /pontential advance.
notice of proposed rulemaking
- 3. ASNTs experience in certifying NDT professionals
- 4. Approval. by ASNT Board of Directors on 3-24-89
- 5. Implementation issues State of Texas Conference 'of Radiation Control Program Directors Distribution of funds Communications and interface Seed money from USNRC
,i s
7-_ J 1 4 l. 3 l OVERVIEW. 0F PROPOSED PROGRAM The proposed program is entitled "ASNT Certification Program for Industrial Radiography Radiation Safety Personnel" or ASNT-CP-IRRSP-1 A. It consists of three parts: ASNT IRRSP Certification Requirements -dSNT 1RRSP Rules of Conduct ASNT IRRSP Program Complaint and Hearing Procedures
I 5 i CERTIFICATION REQUIREMENTS l l INTRODUCTION J Certification to be offered in either or both of the following categories: Isotope Radiation Safety Practices X-Ray Radiation Safety Practices Certification is evidence that an individual: Satisfies training and cIperience requirements Has successfully completed a State of Texas written examination and recognized practical examination Has agreed to the IRRSP Rules of Conduct
a. I-6 .( b QUALIFICATION REQUIREMENTS
- 1. Submittal of application that willbe verified and fee specified by ASNT
- 2. Meet the following training and experience requirements (both for X-ray and isotope):
40 hours classroom training by a recognized institution .520 hours of actual experience in each category sought I i
. -:,..,?... em 17. x. EXAMINATIONS
- 1. 'ASNT or'CRCPD proctored State of Texas written examination
- 2. Practical examination administered by a recognized institution
- 3. At locations and times approved by ASNT or.
CRCPD CERTIFICATION
- 1. Both written and practical exams must be passed within 6 months of each other except as granted by the. Executive Director i
- 2. Candidates who fail may re-submit' new application and fees
- 3. Candidates who satisfy requirements willbe notified in writing
- 4. Wallet card provided to IRRSP l
____.-_________.______.._.__m
L l 8 FEES L
- 1. To be established / approved by-the ASNT Executive Committee
- 2. State of Texas /CRCPD fees in addition to ASNT l
fee
- 2. Refunds less administrative fees availabic for unqualified or unable to attend personnel (15 day notification)
STATEMENT REOU1REMENTS -1. Agreement to Rules of Conduct and ASNT right.to revoke
- 2. Attest that application is true and correct
- 3. Hold harmless agreement 9
h. ;,. ' y 9 EXPIRATION AND RENEWAL
- 1. Certification for 5 years l: -
- 2. Applications for renewat meet original requirement
- 3. Renewat by application if:
Active for24 oflast 36 months in radiography category of certification Active for 6 oflast 12 months 8 hours of documented training per year by ASNT recognized institution
- 4. Renewal also available by examination plus 8 hours of training per year by ASNT recognized institution I
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.n.,9 y r 10 REVOCATION SUSPENSION E7"IRATION Certification no' longer valid when: The certificate has expired Certification' is suspended by ASNT Certification is revoked by ASNT Requested. by the individual y 1 I ) I E_____________________________'_.__-____._____-----_________.________________ _______.---_.-_._-.______-.__________----__________-._--______j
1, ,c # 11 RULES OF CONDUCT PURPOSE ~ Describes the rules of conduct for-IRRSP RULES OF CONDUCT Maintain high standard of skills and knowledge Assume responsibility Inform proper authority of deficiencies Minimize exposure ( ALARA). Wear and maintain personnel dosimetry Maintain awareness of personal exposure Properly document activities Always comply.with safety procedures l Never misuse ASNT IRRSP certification Avoid conflicts of interest Refuse to accept gratuities or bribes
i..,.[ :,.. 12 RULES OF CONDUCT CONTINUED Never misrepresent qualifications L No association with fraudulent or dishonest venture Refuse to falsify documents Do not testify without adequate knowledge Never operate equipment under the influence of mood altering substances SANCTIONS Violations of the foregoing may result in sanctions by the IRRSP Ethics Subcommittee
1 13-1 COMPLAINT AND HEARING PROCEDURE ] Introduct.'on
- 1. Provides fair notice and hearing
- 2. Published and made available to public
- 3. Annual report of revocations
- 4. Committee responds to status of IRRSP COMPLAINTS AND INVESTIGATIONS
- 1. Any person may submit complaint
- 2. ASNT Executive Director-prepares formal complaints
- 3. Ethics Committee dispositions complaints
- 3. Ethics Subcommittee may:
3.1 Close file for lack of evidence 3.2 Prepare formal complaint
14 COMMENCEMENT 0F HEARING ACTIONS
- 1. Executive Director sets date for hearings
- 2. Respondent has right to answer by mail (45 days)
- 3. Executive Director may modify date for good i
cause / \\, PRE-HEARING PROCEDURES
- 1. Pre-hearing conference with interested parties followed by written report
- 2. Pre-hearing conference may result in proposed ruling and Ethics Subcommittee
~ may vote
- 3. Adjudication without formal hearing must be agreed to by both parties I
l
15 HEARINGS
- 1. Panel makeup of three including presiding officer appointed by the Chairman
- 2. Hearings shall be private except for
. unanimous agreement to contrary
- 3. BOD may participate in hearings-
- 4. Ethics Committe members when compininant shall not be on panel
- 5. Respondent may defend scif
- 6. Record of hearing and retention thereof
- 7. Presiding officer controls hearing
- 8. Panel shall assure the following:
8.1 Permit full development of issues 8.2 Disallow inappropriate evidence 8.3 Protect rights of witnesses 8.4 Allow evidence in written form 8.5 Copies of original evidence are allowed 8.6 Committee may act on specialized knowledge 8.7 Objections to evidence are recorded
l.- . l6 l
- 9. Presiding officer shall assist in the l
appearance of witnesses, enjoin witnesses to tell the truth, and control subpoenas and testimony under oath
- 10. Witnesses subject to cross-examination
- 11. Hearing conducted
-ithin 1 year or dismissed
- 12. Presiding officer advises respondent of communications I
m._m_m___---___- --.2
RULINGS Panel adopts ruling after procedure. e Presiding officer delivers ruling to Executive Director RFPRIMAND. SUSPENSION, AND REV0 CATIONS Actions shall be based upon one of the following: Severity Level III - least significant, persons or. property not at risk, results in written reprimand. Severity Level II - persons or property are deemed at risk, suspension for 30 to 180. days Severity. Level 1 - most significant, deemed to cause or threaten serious injury or property damage, results in revocation for at least one year Petition for good cause to to reinstate may be considered APPEALS Respondent may appeal within 60 days
18 l I ANCILLARY MATTERS i ) { Ethics Committee may not be advised by other individuals Witnesses have right to counsel SANCTIONS AGAINST NON-CERTIFIED INDIVIDUALS CLAIMING ASNT CERTIFICATION
- 1. Complaints to be sent to Executive Director I
- 2. Executive Director directs offender to cease i
or be subject to court. action
- 3. If offender is ASNT member, formal complaint and request for forfe!'.ure of.
membership requested IMPLEMENTATION COSTS Fees to applicant circa $100 times approx. 12000 persons - 1.2 million Other related cost to industry - $400 per, applicant times approx.12000 persons - 4.8 million State of Texas exam fee approximately $30 (included in fee) CRCPD administrative cost - $10 per applicant times approx. 2000 persons - 20 K Totalindustry cost = $6.02 million l
w 19~ SUMM ARY/ PROPOSAL-1 UPON ASNT BOARD OF DIRECTOR APPROVAL OF FINANCES, ASNT WILLINSTITUE A NATIONAL CERTIFICATION PROGRAM FOR IRRSP UTILIZING THE STATE OF TEXAS EXAMINATION PROCTORED BY ' ASNT, OR THE CRCPD FOR THOSE INTERESTED STATES. I WHERE THOSE INTERESTED STATES PROCTOR EXAMINATIONS, THE CRCPD WILLBROKER THE' TESTS WITHOUT ASNT INVOLVMENT. THE REMAINDER OF THE STATES WILLBE SERVED BY ASNT DEALING DIRECTLY WITHTHE STATE OF TEXAS. EXAMINATIONS WILLBE OFFERED THROUGH COOPERATION BETWEEN INTERESTED PUBLIC AND PRIVATE ORGANIZATIONS. 8 ASNT AGREES TO CERTIFY INDIVIDUALS EXAMINED IN THE INTERESTED ST ATES UPON RECEIPT AND APPROVAL'0F AN APPLICATION AND FEE FROM EACH INDIVIDUAL INCLUDING THOSE PREVIOUSLY EXAMINED BY TEXAS. ASNT VTILLBE THE NATIONAL CERTIFICATION ORGANIZATION, WITH ALL STATES RECOGNIZING THE CERTIFICATION. ASNTs THIRTEENYEARS OF EXPERIENCE IN CERTIFYING PERSONNEL WILL i ASSIST IN ASSURING UNIFORM QUALIFICATIONS 0F INDUSTRI AL RADIOGRAPHER. l i
l i 20 i THE ABOVE PROPOSALS ARE CONTINGENT ONTHE CONCEPT: THAT THE REGULATORY COMMUNITY WILL ASSURE THE VIABILITY AND' EFFECTIVENESS OF ASNTs PROGRAM BY DEVELOPING RULES SUCH THAT ASNT 1 CERTIFICATION IS REQUIRED IN ALL STATES. H e I i __m_____._-__.____.______m_____
i -. 3 o a THE TEXAS EXPERIENCE WITH A RADIOGRAPHER TESTING PROGRAM David K. Lacker Texas Department of Health Bureau of Radiation Control INTRODUCTION TO THE TESTING PROGRAM In January 1987, the Texas Bureau of Radiation Control (TBRC) became the first entity to implement a cohesive testing program for industrial radiographer as a means of improving and verifying knowledge and awareness of radiation safety. This testing program requirement was one of many major changes made to the Texas industrial radiography rules which became effective in October 1986. The requirements concerning the testing program and radiographer qualifications were adopted in direct response to the radiation safety record of the industrial radiography industry. Investigations by Texas, Nuclear Regulatory Commission (NRC) and other Agreement State inspectors have indicated that inadequate training of radiographer may be a significant contributing cause in many reported overexposure incidents. The new Texas rules address this problem in several ways. Now, a radiographer trainee must have completed an Agency-approved training course before handling any sources of radiation. Possession of an I.D. card alone does not mean an individual is a qualified radiographer. To be recognized as a radiographer by the State of Texas an individual must complete all the training required, submit the appropriate documentation and pass the exam. Thc purpose of the Texas industrial radiography safety exam is to assure that each and every individual authorized to. work at an industrial radiography site has the basic information and knowledge to work safely. To date, over 2200 exams have been administered to more than 1800 l indiviOJals. These numbers include individuals from 17 states in ) addition to Texas. All of the Agency-administered exams are developed i from a bank of validated, safety-related items. The items were created i by TBRC staff members and collected from training courses utilized in the radiography industry, from other regulatory agencies, and from various training materials utilized in radiation safety courses. This is an on-going process as the Agency continues to expand and improve the item bank. Exam items relate only to radiation safety and thus all the items in the bank are categorized according to those subjects of instruction outlined in Texas Regulations for the Control of Radiation Appendix 31-A (Suggested State Regulations for Control of Radiation Fart j E, Appendix A and 10 CFR 34, Appendix A). A portion of the item bank i was developed with monetary aid from the NRC. ] \\ l 1 l l 1 3
STATUS OF THE TESTING PROGRAM For each session, three different exams are created. One contains safety. items related to radioactive materials, one deals only with safety items related to x-ray machines and the third has items concerning both x-ray machines and radioactive materials. Each exam consists of 125 four-choice multiple-choice items. Twenty-five items on each exam are provisional. Provisional items are those that have not been validated. They are randomly distributed throughout the exam and the radiographer are not aware of which ones they are. Provisional-items are. not graded but are analyzed using psychometrics procedures, so in this manner new items may be continually validated and the item bank expanded. Thus, each radiographer's score is based upon 100 active-(previously validated) items. Exams are now administered in Austin once a month and an average of E9 people attend each session. The overall average failure rate is 18%. The overall average score for the radioactive materials exam is 75. The average score for the x-ray machines exam and the exam for both are 79 and 82, respectively. CHANGES DUE TO THE TESTING PROGRAM The TBRC began issuing notices of violations for non-compliance concerning the safety exam in March 1988. There has not been sufficient time elapsed since then to determine any valid correlations between trends in inspection reports and the testing program. However, there have been several situations in which an Agency inspector terminated operations at a job site because the individuals did not have I.D. cards in their possession. Agency inspectors have reported observing individuals studying resource materials on the job site. This is very encouraging in terms of increasieg knowledge and awareness of radiation safety. The TBRC has suspended one individual's I.D. card and is currently considering suspension of two more. In each case, Agency inspectors have docwented a willful intent to violate the roles. Similacly, there has not been enough time elapsed since January 1,1988 (the date by whit.h all radiographer in Texas must have been tested) to i determine what impact the testing' program has had on overexposure incidents. However, Figure I shows the number of exposures greater than three rem per quarter reported to the agency from 1979 to 1987. Figure 2 shows reported exposures greater than 25 rem per quarter. The figures include 1986, the year in which the training and testing requirements became effective. In both figures, the shaded areas represent exposures to " assistant" radiographer. The Agency feels that the downward trend ( in overexposure is due to two things. With the decline in oil prices, l the Texas economy and therefore, available jobs in the radiography l industry also declined. In addition, when the new rules were adopted, individuals began preparing for the state exam. People were being trained and retrained, creating an increased awareness of job safety. The Agency also believes that the decrease in the number of exposures to what were then " assistant" radiographer is directly related to the new rules. Radiographer trainees (previously helpers or assistants) must now pass an Agency-approved safety training course before handling sources of radiation. j 2
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i As mentioned earlier, possession of an I.D. card alone does not mean an individual is a qualified radiographer in Texas or that he or she will not be overexposed. The new Texas rules are.T. cant to correct e lack of knowledge and training, and provide a means of determining compliance I with training requirements. l l FUTURE OF THE TESTING PROGRAM 1 The TBRC will continue to test industrial radiographer working in Texas. Many other Agreement States have expressed an interest in i adopting similar rules, including a testing program. The Agency is l currently negotiating with the Conference of Radiation Control Program Directors (CRCPD) to provide exam development and administrative services to radiation control regulatory agancies. Those regulatory agencies would, in turn, administer the exams to.those radiographer they regulate. With this type of pri.jram, all exams would be developed using the same validated item bank. Not only would this provide a nationwide consistency in testing, but reciprocal recognition of radiographer across state lines would be made simpler. The Agency has also received a proposal from the American Society for Nondestructive Testing (ASNT) concerning ASNT administration of an industrial radiography safety exam. The proposal calls for the TBRC to be the sole provider to ASNT of exams and grading services. There would also be reciprocal recognition by the ASNT of the TBRC test and vice versa. We are prepared to proceed toward formalizing the proposal in contract when the Commission approves a National Certification program. The interest in our testing program shown by the NRC, other Agreement State regulatory agencies, and the industry certainly indicates a nationwide concern over the safety history of industrial radiographic operations and a commitment to improving that record.
b i i 1 T, ROLE OF THE CONFERENCE OF RADIATION CONTROL PROGRAM DIRECTORS (CRCPD) IN THE TESTING 0F INDUSTRIAL RADIOGRAPHER Briefing bef,re the NPC omissioners Apdi C,1989 Presented by: Charles F. Tedford, Chairman, CRCPD Thank you, Chairman Zech, and Commissioners, for the invitation extended to attend this briefing. The Conference of Radiation Control Program Directors, Inc. (CRCPD), whose membership is comprised of the directors of the radiation control programs of the fifty states; the District of Columbia; New York City; and Puerto Rico, considers the a issue of national certification of radiographer to be of greet importance. In large measure, the health and safety of our citizens depend upon the successful resolution of this matter of mutual concern. History has.shown that a high percentage of radiation incidents and 4 accidents have occurred in the field of industrial radiography. Many of i these incidents and accidents were caused by the lack of proper training l by those who actually perform the radiographic procedures. The thrust i of this program is to recognize and certify individuals who have demonstrated an understanding of radiation protection principles and practices in the use of radioactive sources. The states, and in particular, those states which have an agreement with the NRC, and the ] NRC have recognized the need for a national program since 1975. Accordingly, the CRCPD applauds the NRC for the effort to develop a nationc1 industrial radiographer certification program. Machine-produced radiation is also used for industrial radiography. The CRCPD is as concerned for proper safety from machine-produced radiation as for radiation produced from radioactive i materials (RAM). Any national program is encouraged to place equal importance on both types of radiation sources. The certification i program should encompass and qualify the individual for machine and RAM ) sources. It should be noted that the Texas Radiographer Testing Program has established a positive precedent for this area of concern. n.
1 l 1 2 l ) The CRCPD is in a unique position relative to the issu.e,.since the Conference represents all states - both Agreement States (which now i number twenty-nine) and Non-Agreement States. Additionally, the CRCPD is not restricted to particular radioactive materials covered by the I E Atomic Energy Act, but can address all radioactive materials, including Naturally Occurring and Accelerator Produced Radioactive Materials (NARM),andmachine-producedradiationsources. 1 k Because of this unique position, the State of Texas has requested .I l 1 L the CRCPD to consider brokering the Texas-developed Industrial Radiographer Test to those states with an interest in administering the ) test. The executive Board of the CRCPD has approved the pursuit of a i brokerage role, and has developed a proposed contract to be executed j between the CRCPD and the State of Texas to accomplish this purpose. i The basic concept of the CRCPD role is as follows. When a state has interest in administering the Texas test, the Program Director of that state, who is also the member of the CRCPD, will act on behalf of i the CRCPD in administering the test. Texas will train state proctors. The state administering the exam will subsequer:tly establish a testing time and place, and determine the number of individuals to be tested. Then, through the CRCPD, the interested state will receive the specified number of tests from the State of Texas. The CRCPD member in the interested state, or designed representative, will administer the test, using the trained proctor. The state will collect the completed tests and mail them to Texas for grading and analysis. The results of the test will be sent to the national certifying body, with copies of the results provided to the state which administered the test. The state member of the CRCPD will have responsibility for the security of the tests. The Conference strongly believes that states who desire to administer the test should be given the opportunity. The use of the CRCPD as a broker will provide for an expedient procedure in obtaining the test from Texas. With CRCPD as the broker, a separate contractual document will not be necessary between Texas erd the other states desiring to use the test.
B 3 Again, please accept my sincere appreciation and comp 1.iments for the concerted, stellar efforts by the NRC to establish a national certification program for individuals performing industrial radiography. The establishment of a national certifying / testing program for industrial radiographer has been under consideration for the last several months by the NRC, the State of Texas, the American Society for NondestructiveTesting(ASNT),andCRCPD. The CRCPD-will cooperate in making this national certification effort an' effective, workable program. I will be pleased to entertain any questions that you may have on the role of the CRCPD. There are two individuals with me today whom I may call on for assistance in responding to your questions. They are i Ronnie Wascom, representing the Association of NRC Agreement States, and Charles Hardin, the Executive Secretary of the CRCPD. j i i 4
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