ML20246P099
| ML20246P099 | |
| Person / Time | |
|---|---|
| Issue date: | 02/13/1989 |
| From: | Miller V NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | |
| Shared Package | |
| ML20246P084 | List: |
| References | |
| FOIA-89-179 NUDOCS 8905220083 | |
| Download: ML20246P099 (6) | |
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U.S. NRC D
Washington, D.C.. 20555-o i: NDTMA Annual Meeting Ceaser. Place, Las Vegas, NV.
Februa ry 13-16, 1989 Presented By:
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Vandy L. Miller Assistant Director foriState Agrecraents' Program State, Local and Indian Tribe Programs I u nt to thank the.Non-Destructive Testing Management Association (NDTMA) for inviting me to participate as a guest speaker and panel 1 member on radiography safety. . I am not a stranger to the association as I have been working with NDTMA for the last several years on radiography safety.
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The topics I would like to discuss with you today are the NRC perspective on radiographer certification, the status of the radiography equipment ]
rule and the role of management in a quality radiation safety program.
Radiography Certification .g The issue of radiographer licencirg or certification is a topic which has been discussed for implementation at various times by AEC/NRC since 1964.
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.NRC and Agreement State investigations of overexposure incidents have indicated that inadequate training of radiographer may be a significant contributing cause in many of the overexposure incidents. (Yugraph#2).
Over the decade, ending in 1984, industrial radiography has accounted for more than 50 percent of the overexposure greater than 5 rems to the whole body or 75 rems to the extremities as reported by all NRC licensees, also, 60 percent of the overexposure greater than 25 rems to the whole body, and 375 rems to the extremities.
The Comission is committed to improving radiation safety in industrial radiography and has requested to be periodically informed of the radiographer industry's progress in developing an industrial radiographer certification program and of other staff efforts to improve radiography safety.
It is the staff's view that a certification program could help to provide
) NRC assurance that individual radiographer meet minimum training and experience criteria, and have an acceptable knowledge of radiation safety and appropriate safety precautions. The staff is currently exploring a certification program with ASNT.
Certification for industrial radiographer has been considered at various times in previous years. (Vugraph#3) In 1977, a petition for rulemaking was filed which requested that NRC amend its regulations to provide registration, licensing, and control of individual radiographer. On May 10, 1982, an Advance Notice of Proposed Rulemaking (ANPR) noted that NRC was considering radiographer certification, and it was published in the O-____________.__---___________-___-_.__-_-_-_-__--____-______.
1 K Federal Register. Our NRC Office of Nuclear. Regulatory Research contracted for a study to evaluate the impact of certification.
In 1985, the Commission withdrew the ANPR, based on recommendations of the staff that there was no consensus'that a certification program for
-[' radiographer would reduce the number of overexposure, and that implementation of a program would be expensive and time-consuming.
In approving the withdrawal of the ANPR on certification of radiographer,_the Commission directed the staff to provide aggressive action to implement other alternatives such as equipment rulemaking, more frequent inspections at temporary jcb sites, performance symptoms, and to takestrongerenforcementactions.(Vugraph#4)
The Radiography Equipment Rule The equipment rulemaking effort is coming along nicely. The proposed rule was published in the Federal Register in february 1988. (Vugraph
- 5) The equipment rule is intended to improve reliability.and safety.
The couraent period was to expire May 16. However, due to a number of requests, including one form NDTMA, NRC extended the comment period an additional 90 days to August.
The proposed rule would require improved radiography devices, source assemblies, and controls along the lines of ANSI N432; source assembly I
and drive cable connectors which could not be unintentionally disconnected; a visual source position indicator; automatically secure
4 or lock the source in the shielded position upon return to the device; modifications which compromise the design safety. features of the oevice or associated equipment would be prohibited. The rule would require
, that all devices purchased one year after the effective rule date meet the requirements and that all devices used.in industrial radiography five years after the effective rule date meet the requirements. Also proposed was a new section to Part 34.which would require a written report within 30 days of certain incidents'and equipment malfunctions.
In eddition, the rule would also require both radiographer and assistants to wear an alarming dosimeter.
l'PC received a total 87 docketed comment letters, however several were duplicates or concerned a different rule, for a total net of 68 valid letters. Also, ASNT polled their membership using a survey questionnaire and received 399 responses.
Many comments included suggestions for safety improvement which were outside the scope of the rule, such as; two man radiography crews, improved radiographer training and certification, increased field surveillance by the regulatory agencies, and periedic inspection of equipment by the manufactures.
The areas of the rule that received the most comments int.lude: the source assembly-control cable connection - commenters stated the wording !
needed clarification; there also was significant opposition to a source position indicator and automatic securing of the source assembly, the requirement that all devices in use meet the proposed rule in five years, cnd the requirement for wearing personnel alarm dosimeters.
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. The staff is presently evaluating the coninent letters, preparing responses to the comments, and rewriting the final rule. . As proposed thus far, the final rule may extend the tire period for implementing of certain provisions, and further clarifying some of the requirements.
Otherwise, few changes are envisioned to the rule at this time.
i Establishing a time period for having all devices in use meets the rule's requirements and has created a good deal of debate within NRC.
The staff currently anticipates that the final rule will be published by mid-year.
Management Role In Quality RSP NRC has been noting a disturbing trend in radiography operations which I would like to share with you, especially since you all are the l roanagers. The most disturbing aspect of this trend is that the violations frequently appear to be occurring without the knowledge of 1
l management. In a few cases the trend indicates licensees are knowingly concitting violations for convenience and economic reasons.
The NRC staff considers willful violations to be extremely serious and such noncompliance can lead to major penalties up to and including criminal prosecution by the U.S. Department of Justice.
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.Insummarythefollowingsixpoliciesembodywhatmanagemenkshouldbe r i
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- but are frequently'not doing:.
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- Radiation Safety is the #1 priority 2 1-
. - Contracts', deadlines, bids and customers must'never be the causee..,;
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of compromising safety. 41
- Management personal involvement in radiation safety ,
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- Careful'and thorough supervision of radiography personnel, c
- Clear and direct cc munication \
l: - The RSO must be aiven responsibility and euthority- ,
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