ML23153A048

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PR-034 - 54FR47089 - Asnt Certification of Industrial Radiographers
ML23153A048
Person / Time
Issue date: 11/09/1989
From: Taylor J
NRC/EDO
To:
References
PR-034, 54FR47089
Download: ML23153A048 (1)


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ADAMS Template: SECY-067 DOCUMENT DATE: 11/09/1989 TITLE: PR-034 - 54FR47089 - ASNT CERTIFICATION OF INDUSTRIAL RADIOGRAPHERS CASE

REFERENCE:

PR-034 54FR47089 KEYWORD: RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete

STATUS OF RULEMAKING PROPOSED RULE: PR-034 RULE NAME: ASNT CERTIFICATION OF INDUSTRIAL RADIOGRAPHERS PROPOSED RULE FED REG CITE: 54FR47089 PROPOSED RULE PUBLICATION DATE: 11/09/89 NUMBER OF COMMENTS: 52 ORIGINAL DATE FOR COMMENTS: 02/07/90 EXTENSION DATE: I I FINAL RULE FED. REG. CITE: 56FR11504 FINAL RULE PUBLICATION DATE: 03/19/91 NOTES ON EDO SIGNED PROPOSED AND FINAL RULES.

TATUS OF RULE FILE LOCATED ON Pl.

TO FI ND THE STAFF CONTACT OR VIEW THE RULEMAKING HISTORY PRESS PAGE DOWN KEY HISTORY OF THE RULE PART AFFECTED: PR-034 RULE TITLE: ASNT CERTIFICATION OF INDUSTRIAL RADIOGRAPHERS PROPOSED RULE PROPOSED RULE DATE PROPOSED RULE SECY PAPER: 89-303 SRM DATE: 10 / 23 / 89 SIGNED BY SECRETARY: 1 0 / 30 / 89 FINAL RULE FINAL RULE DATE FINAL RULE SECY PAPER: SRM DATE: I I SIGNED BY SECRETARY: 03/04 / 91 STAFF CONTACTS ON THE RULE CONTACT!: ALAN ROECKLEIN MAIL STOP: NLS-139 PHONE: 492-3740 CONTACT2: MAIL STOP: PHONE:

DOCKET NO. PR-034 (54FR47O89)

In the Matter of ASNT CERTIFICATION OF INDUSTRIAL RADIOGRAPHERS DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT

11/13/89 10/30/89 FEDERAL REGISTER NOTI CE - PROPOSED RULE 12/20/89 12/06/89 COMMENT OF DENNIS JOHNSON ( 1) 12/20/89 12/06/89 COMMENT OF KENNETH OLSON ( 2) 12/20/89 12/06/89 COMMENT OF DON JOHNSON ( 3) 12/20/89 12/06/89 COMMENT OF JOSEPH PAUKERT ( 4) 12/20/89 12/06/89 COMMENT OF GREGGORY STANBY ( 5) 12/20/89 12/06/89 COMMENT OF MITCHELL NELSO ( 6) 12/20/89 12/06/89 COMMENT OF J. MOHN! ( 7) 12/20/89 12/06/89 COMMENT OF LARRY OBERG ( 8)

- 12/26/89 12/29/89 01 / 12/90 12/14/89 12/06/89 01/07/90 COMMENT OF RODNEY RE INHOLDT (

COMMENT OF PAT HAGGENMI LLER (

COMMENT OF X-CEL NDE INC.

9) 10)

(WILLIAM ROGERS, PRESIDENT) ( 11) 01 / 12/90 01/08/90 COMMENT OF RECO INTERNATIONAL, INC.

(NORMAN COLLINS, RADIATION OFFI CER) ( 12) 01 / 16/90 01/08/90 COMMENT OF IOWA DEPARTMENT OF PUBLIC HEALTH (DONALD FLATER, CHIEF) ( 13) 01 / 16/90 01 / 11/90 COMMENT OF UNITED AIRLINES (BOB SCOBLE, NOT MANAGER) ( 14) 01 / 17 /90 01/09/90 COMMENT OF INDEPENDENT TESTING LABORATORIES, INC.

- 01/ 17/90 01 / 10/90

{J. LAWSON, PRESIDENT AND H. WILSON) { 15)

COMMENT OF GCT INSPECTION, INC. {G. G. PELOQUIN) ( 16)

DOCKET NO. PR-034 {54FR47089)

DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 01/17/90 01/10/90 COMMENT OF JAMES MCHANEY, JR. { 17) 01/19/90 01/15/90 COMMENT OF SCHONBERG RADIATION CORPORATION

{RUSSELL SCHONBERG. PRESIDENT) ( 18) 01/22/90 01/15/90 COMMENT OF DON EDWARDS { 19) 01/22/90 01/18/90 COMMENT OF BIX TESTING LABORATORIES (MARK MEADOWS, RADIATION OFFICER) ( 20) 01/23/90 01/15/90 COMMENT OF ULTRASONIC SPECIALISTS, INC.

(LLOYD GRAY, OPERATIONS MANAGER) ( 21) 01/24/90 01/17/90 COMMENT OF DEPARTMENT OF HUMAN RESOURCES (RAY D. PARIS) ( 22) 01/25/90 01/09/90 COMMENT OF TEXAS DEPARTMENT OF HEALTH (DAVID K. LACKER) ( 23) 01/29/90 01/21/90 COMMENT OF FRANK MALEK &ASSOCIATES (FRANK MALEK) ( 24) 01/30/90 01/26/90 COMMENT OF TULSA GAMMA RAY, INC.

(JAMES C. MOSS, PRESIDENT) ( 25) 01/30/90 01/26/90 COMMENT OF GLOBAL X-RAY &TESTING CORPORATION

{BILLY JUNEAU, VICE PRESIDENT) ( 26) 02/01/90 01/22/90 COMMENT OF ARKANSAS DEPARTMENT OF HEALTH (GRETA J. DICUS) ( 27) 02/02/90 01/30/90 COMMENT OF HOUSTON LIGHTING AND POWER COMPANY (M.A. MCBURNETT) ( 28) 02/05/90 01/15/90 COMMENT OF AMERICAN AIRLINES (A. A. HALE, VICE PRESIDENT, ENGR.) { 29) 02/06/90 01/30/90 COMMENT OF MQS {EARLL. BANFIELD) ( 30) 02/06/90 01/30/90 COMMENT OF CONTINENTAL AIRLINES (RICHARD L. ROHRIG) { 31) 02/06/90 01/29/90 COMMENT OF CHERNE CONTRACTING CORPORATION (GREGORY A. ROSIER) { 32) 02/06/90 02/02/90 COMMENT OF MQS INSPECTION, INC.

{HUGH V. DORAN, PRESIDENT) ( 33) 02/06/90 01/29/90 COMMENT OF MQS INSPECTION, INC. (THOMAS JOFFE) ( 34) 02/06/90 02/02/90 COMMENT OF MQS INSPECTION, INC. (RONALD C. FALOON) ( 35)

DOCKET NO. PR- 034 {54FR47089}

DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 02/07/90 02/05/90 COMMENT OF TENNECO GAS {DAVID L. CULBERTSON) { 36) 02/07/90 01/31/90 COMMENT OF RTS TECHNOLOGY, INC. {JOHN J. MUNRO, III} ( 37) 02/07/90 02/02/90 COMMENT OF AIR TRANSPORT ASSOCIATION (DON COLLIER, ET AL.} ( 38}

02/08/90 02/01/90 COMMENT OF GENERAL DYNAMICS, ELECTRIC BOAT DIVISION (R. G. SCHEEL} ( 39}

02/08/90 02/01/90 COMMENT OF NOT PANHANDLE AND INSPECTION (ORVIL COUCH AND NORMAN RENEAU} ( 40) 02/09/90 02/07/90 COMMENT OF KENNETH F. BAKER ( 41) 02/09/90 02/06/90 COMMENT OF TENNESSEE VALLEY AUTHORITY (M. J. RAY) ( 42) 02/12/90 02/07/90 COMMENT OF PHILADELPHIA ELECTRIC COMPANY

{G. A. HUNGER, JR.} { 43) 02/12/90 02/02/90 COMMENT OF ALBERT J. DILTS { 44}

02/12/90 02/06/90 COMMENT OF TEXAS DEPARTMENT OF HEALTH

{DAVID K. LACKER) { 45) 02/13/90 02/06/90 COMMENT OF COMMONWEALTH EDISON (T. J. KOVACH) ( 46) 02/14/90 02/08/90 COMMENT OF STATE OF LOUISIANA (WILLIAM H. SPELL) ( 47) 02/20/90 01/12/90 COMMENT OF DONALD A. FLATER ( 48}

02/22/90 02/12/90 COMMENT OF AMOCO OIL COMPANY {JOHN J. MUNRO, Ill) { 49}

02/26/90 02/05/90 COMMENT OF BOEING SUPPORT SERVICES (WILLIAM E. MORGAN) ( 50) 03/05/90 02/28/90 COMMENT OF GEORGIA POWER COMPANY

{K. E. ADAMS, SR. VICE PRESIDENT) { 51}

04/09/90 04/05/90 COMMENT OF ILLINOIS DEPARTMENT OF NUCLEAR SAFETY

{PAUL EASTVOLD, MANAGER) ( 52) 03/15/91 04/04/91 FEDERAL REGISTER NOTICE - FINAL RULE I I I I

DOCKET NUMBER PR 3 f

... PROPOSED RU(s 'f r-~ .i-f10&'<ij

'91 MAR 15 P3 :38 NUCLEAR REGULATORY COMMISSION 10 CFR PART 34 RIN 3150-A035 ASNT Certification of Industrial Radiographers AGENCY: Nuclear Regulatory Commission.

ACTION: Final rule.

SUMMARY

The Nuclear Regulatory Commission is amending its regulations in 10 CFR Part 34 concerning radiographic operations to provide license applicants and licensees the opti on to affirm that individuals acting as radiographers will be certified in radiation safety by the American Soci ety for Nondestruc i ve Testing (ASNT) prior to commencing duties as radiogra-phers. License applicants may use ASNT certification in lieu of the por-ti on of the current licensing requirement that specifies submission of descriptions of planned initial radi ation safety train ing and qualifica-tion procedures. In addition, the amendment would permit existing NRC radiography licensees to substitute the ASNT examination for the licensee's radiation safety examination and to substitute ASNT certifi-cation for procedures used for verifying the training and testing of ex-perienced radiographers as described in license app lications. Licensees will not be required to have their licenses amended to make these substitutions until the next license renewal date.

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The intent of this rulamaking is to encourage industrial radiography licensees and license applicants to participate in the ASNT program because the Co11111ission believes that this program can contribute significantly to improved safety. The NRC staff plans to monitor the ASNT program, in part to obtain information which may be useful in any future rulemaking requiring third-party radiographer certification. It should be noted that this rulemaking does not affect the licensee's responsibility to assure that radiographers are properly trained in accordance with the requirements of Part 34.

EFFECTIVE DATE: _ 30 days_ after date of publication FOR FURTHER INFORMATION CONTACT: Dr. Donald 0. Nellis, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory CoDHDission, Washington, DC 20555, telephone (301) 492-3628.

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SUPPLEMENTARY INFORMATION:

Contents Bae kg.round Previous Regulatory Initiatives The ASNT IRRSP Certification Program Current NRC Practices Description of Amendments Public Comments Impact of the Rule Environmental Impact: Categorical Exclusion Paperwork Reduction Act Statement Regulatory Analysis Regulatory Flexibility Certification Backfit Analysis List of Subjects

Background

The high activity radioactive sources used in industrial radiography pose serious hazards if radiation safety procedures are not rigorously followed. A significant fraction of occupational overexposures and seri-ous radiation injuries reported to the NRC and the Agreement States has occurred in industrial radiography operations. For example, the State of Texas reported that 42 percent of all radiation overexposures in that State in 1987 were attributable to industrial radiographic operations.

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Investigations by the NRC and Agreement States have indicated that inadequate training is often a major contributing factor to radiography incidents. To counter this problemt i~ October 1986. the Texas Bureau of Radiation Control implemented a comprehensive testing program for radiog-raphers as a means of improving and verifying training and radiation safety practices in the industry. To date, approximately 3000 individu-als have been tested and over 2500 radiographers have been issued indus-trial radiography identification cards by the State of Texas.

Previous Regulatory Initiatives The concept of licensing or cer~ifying radiographers as a means of helping to reduce radiation overexposures in the radiography industry is not new. In July 1964, the Atomic Energy Commission (AEC) directed its staff.to consider whether individual radiographers should be licensed as were individual reactor operators at that time. The staff response was that the increased AEC workload created by either licensing or certifi-cation of individual radiographers by the Coanission would be very large and was not warranted, but that the CoR1Dission could improve radiography safety by encouraging the certification of radiographers by third parties such as industrial societies and associations.

In June 1977, the Non-Destructive Testing Management Association (NDTMA) filed a petition for rulemaking with the NRC (PRM-34-2) to re-quire registration of individual radiographers by the NRC, including the issuance of a registration card to qualified radiographers which would then be subject to recall or revocation on demand by the NRC. As a 4

result of this petition, an Advance Notice of Proposed Rulemaking (ANPRM) on certification of industrial radiographers by an NRC-approved third party was published in the Federal Register on May 4, 1982 (47 FR 19152).

- Public meetings in connection with the ANPRM were also held at four dif-ferent locations in 1982. Comments received from these public meetings indicated that most conrnenters believed that a third-party certification program would not significantly reduce the number of overexposure inci-dents _to personnel and that the costs associated with such a program would exceed the benefits. Although some organizations expressed inter-est in acting as third-party certifiers, none of these organizations came forth with an acceptable proposal for radiographer certification. As a result of the connnents received and an analysis of the costs involved, the NRC staff requested withdrawal of the_ANPRM and the Commission ap-proved this recommendation in November 1985.

Shortly afterwards, on December 17, 1986, the NRC published for pub-lic comment the report of its Materials Safety Regulation Review Study Group (51 FR 45122), which recommended, among other things, that indus-trial ~adiographers be certified by the_ NRC or by an,Agreement State through sOIBe form of third-party certification. In 1988, the General Accounting Office called for the NRC to adopt this recommendation.

The ASNT IRRSP*Certification Program The ASNT, recognizing the need for a qualified third-party certify-ing organization, formed a task group to develop an ASNT radiographer certification program for Industrial Radiography Radiation Safety Person-nel (IRRSP). In February 1988, ASNT presented its first draft proposal 5

to the NRC for consideration as a third-party certifying orgnization.

Several subsequent drafts of the ASNT program were submitted for review by the NRC, and in July 1989, the NRC concluded that the certification program would help to assure that individuals performing radiographer duties have an acceptable knowledge of radiation safety practices and principles, and meet minimum regulatory requirements for assessing train-ing and experience. As the NRC's Chairman indicated in his July 20, 1989 letter to the ASNT, the NRC believes that the ASNT program, and its 11 na-tional registry" of certified radiographers, will provide greater assur-ance that only properly qualified individuals will conduct industrial radiography in the United States.

The ASNT IRRSP Certification Program, which is a program for certi-fying industrial radiographers, was approved by its Board of Directors in March of 1990. The program, which includes use of a written examination developed by the State of Texas 1 , has been reviewed extensively by NRC headquarters staff and regional staff. The ASNT program will offer cer-tification for both isotope and x-ray users. This NRC rule, however, applies only to isotope radiography.

ASNT application requirements for industrial radiographer certifi-cation specify the documentation of a candidate's completion of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of classroom training in radiation safety topics specified by the ASNT (which includes those topics listed in Appendix A of 10 CFR Part 34);

documentation of 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct hands-on experience with radiography sources and devices under the control of an NRC or Agreement State 1 TBRC IR-03-1988, "The Development of an Examination Item Bank for Industrial Radiographic Personnel," C. Weber, R. Sanders, R. McBurney & E. Baily, Texas Department of Health, Bureau of Radiation Control. (NRC Contract

  1. NRC-02-86-009).

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licensee; and proof of successful completion of a practical examination on safety procedures administered by an institution recognized by the ASNT.

Recognized institutions are generally the candidates' employers, who are licensed by the NRC or Agreement States for the use of radiography sources.

Upon approval of an application for certification by ASNT, a candi-date radiographer is then be eligible to take the State of Texas writ-ten examination. The examination is administered by the ASNT or the Conference of Radiation Control Program Directors (CRCPD), and is sent to the State of Texas for grading and the results forwarded to the ASNT. The examination covers fundamental radiation safety principles outlined in Appendix A of Part 34, pertinent federal and state regulations, basic radiographic equipment operation, general operating and emergency procedures, radiation detection instrumentation, and radiation safety pro-cedures applicable to industrial radiography. In addition, the candidate is required to sign an acknowledgement that he/she will abide by the ASNT Rules of Conduct which ASNT considers necessary to maintain the integ-rity of the ASNT/IRRSP Certification Program. Upon successful completion of the required examinations and other requirements, the candidate for certi-fication is provided with a wallet card identifying him/her as an ASNT certified radiographer.

ASNT certification is valid for three (3) years unless suspended or revoked for cause. Renewal of certification may be accomplished both with or without re-examination. A candidate for renewal without re-examination must document continued active permanent employment in radiography for at least 24 of the last 36 months. In addition, the candidate must document at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual classroom refresher training covering basic 7

radiation safety principles, equipment operations, emergency procedures, new safety regulations, license requirements and other pertinent informa-tion. If these criteria are not met the candidate must retake the wr~tten exami.nation.

As described above, the ASNT-IRRSP program requires certified indi-.

viduals to abide by certain Rules of Conduct. The Rules of Conduct re-quire that certified individuals comply with NRC and/or Agreement State regulations, the employer's radiation safety and operating and emergency procedures, and to act in a professional manner in matters pertaining to industrial radiography or to the ASNT-IRRSP cert.ification.

The program also contains complaint and hearing procedures. Upon receipt of a written allegation of unauthorized practice by an ASNT-IRRSP individual, a formal complaint is prepared and distributed to the IRRSP Ethics SubcoD1Dittee. Should the subcommittee not dismiss the allegation for insufficiency or other reason, a formal hearing that includes all interested parties may be held. Should ~he ASNT IRRSP Ethics Subcom-mittee determine that an unauthorized practice has been co11111itted, the committee can take the following actions, based upon one of three severi-ty levels specified in the ASHT certification program:

Severity Level I - A severity level I violation is grounds for revocation of certification for a mini-mum of 1 year and surrender of the certifi-cation card to ASNT.

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Severity Level II - A severity level II violation may result ,~

suspension of certification for 30 to 180 days and surrender of the certification card to ASNT for the duration of the suspension.

Security Level III - Violations in this category shall result in a formal reprimand that describes the nature of the violation and any subsequent action which may result if the violation is repeated.

ASNT is currently implementing its certification program. It is expected' that the program could be fully capable of certifying the ~sti*-

mated 7000 eligible radiographers within two (2) to three (3) years. The NRC staff will monitor the program to provide, through actual experien*ce, information for assessing the impacts of this third-party certification program. This information may be used in the development of future ru1e-making to make such certificatJon mandatory. In addition, the NRC and ASNT have entered into an agreement on the exchange of information. ASNT will share with the NRC, and with the Agreement States through the NRC, an up-to-date list of radiographers certified through the ASNT program.

ASNT will also inform the NRC of radiographers who have been reprimanded or whose certification has been suspended, revoked or otherwise affected, and will provide the NRC with information concerning the basis for the ASNT action. Also, the ASNT will refer to the NRC allegations of unsafe practices that it receives from complainants concerning certified 9

radiographers. Allegations pertaining to such radiographers workin*g in Agreement States will be referred to the appropriate Agreement State.

The NRC will review as appropriate those allegations referred to it and will inform the ASNT of the results of such reviews and on any regulatory action taken. Further, if the NRC takes enforcement action directly affectin~ an*ASNT certified radiographer, the NRC will provide appropriate info~ation to the* ASNT so that the ASNT can consider appropriate action relating to the radiographer's ASNT certification.

More deta ;'1 ed information regarding the cert ifi cat ion program is available from the ~rican Society for Nondestructive Testing, Inc.,

4153 Arlingate Plaza, P.O. Box 28518, Columbus, Ohio 43228-0518.

-turrent NRC Practices Current NRC sealed source _radiography 1icensi ng requi reaients, para-graph 34.ll(b), specify that an applicant for a license will have an ade-quate program_ for training radiographers and radiographers' assistants and will submit to the Commission a schedule or description of the program, which specifies the following: *initial training; periodic .training; on-the-job training; and the means to be used by the licensee to determine the radiographer's knowledge and understanding of and ability to comply with Co111111ission regulations and licensing requirements., and the operating and emergency procedures of the applicant. Also, paragraph 34.31(a) specifies that a licensee shall not permit any individual to act as a radiographer until such individual has been instructed in 10 CFR Part 34 Appendix A subjects, NRC regulations and the licensee's operating and emergency procedures; has demonstrated co,npetence in the use of the licensee's 10

radiographic equipment; and has sucessfully completed a written test and field examination on the subjects covered under this paragraph.

When applying for a NRC license to conduct industrial radiography, an applicant must describe his training program for radiographers, in accordance with §34.ll(b). The applicant must submit an outline of the training course (which must include the topics in Appendix A to Part 34),

specify the time to be spent on each topic and show that the training course totals approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, identify the individual (and pro~

vide qualifications) conducting the training, submit a copy of a typical written examination to.be used, and describe the field or practical exami-nation given to prospective radiographers.

For an individual who has been a radiographer for another licensee, i.e., who has received training from a previous -employer, it is still the new employer's responsibility to determine that the individual has met all regulatory requirements and is competent to- act as a radiographer. The newly hired individual must receive formal instruction in at least the employer's operating and emergency procedures and must be given the writ-ten and field examinations. Licensees are expected to describe under

§34.ll(b)(J) and (4) how they will conduct this instruction and describe their testing procedures as part of their program description. The 11

training program descriptions submitted by a license applicant are incorporated by the NRC as a condition of the new license.

---Descript-1 on~of--Amendments Upon review of the ASNT certification program, the NRC staff con-cluded that individuals certified under the program would meet minimum radiation safety and qualification requirements. Based upon this conclu-sion, in 1989 the NRC published for comment a proposed rule that would*

permit certification of jndustrial radiographers under the ASNT program in lieu of the current requirement for radiographer license applicants to submit a description of the appl1cants 1 initial training and-testing pro-gram on radiation safety subjects in Appendix A of 10 CFR Part 34 and required under §34.31 (54 FR 47089; November 9, 1989). This rulemaking, which is now being published in final form complements and* is consistent with other recent NRC actions relating to radiography, such as the final radiography device rule (55 FR 843, January 10, 1990) aryd the quarterly radiographer performance inspection program (51 FR 21736, June 16, 1986).

The amendmen~s to 10 CFR 34.11 apply to all applicants for NRC industrial radiography licenses and to all current NRC radiography licensees. This final rule will provide radiography license applicants

  • the option to affirm that all individuals acting as radiographers will be certified in radiation safety by the ASNT-IRRSP program prior to commencing duty as radiographers. This option is in lieu of the current requirement in §34.11 for submitting a description of the applicant's initial training and testing program on radiation safety subjects listed in Appendix A of 12

10 CFR Part 34. Existing NRC radiography licensees will be allowed to substitute the ASNT examination for the written examination required by

§34.31(a)(4) described in their license application. However, this option applies only to that portion of the written examination that covers the topics outlined in Appendix A to 10 CFR Part 34 and does not affect other competency requirements such as those spe~ified in §34.31(a)(2) and

§34.31(a)(3).

Existing licensees will also be allowed to substitute ASNT certifica-tion as evidence that an individual has completed the necessary radiation safety training and testing requirements in lieu of any verification pro-cedures the applicant may have described for previously trained individuals in its application. NRC 1 s radiography licensees ~ill be able to make these substitutions without applying to have their licenses amended. However, these allowed substitutions apply only fQr the current duration of the license. In the application that the licensee submits for license renewal after the effective date of this final rule, the licensee has three choices:

(1) Specify only the training and testing programs described in previous applications; or (2) Delete the description of the initial radiation safety training program in previous applications and affirm that all of its radiographers will be ASNT certified; or (3) Modify the description of the training program in previous applications to incorporate a provision to substitute ASNT certification as provided in this rulemaking for some or all of its radiographers.

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Of course, at_any time, an existing licensee can elect to seek amendment of its license to eliminate the description of its initial training program and to affirm that all of its radiographers will be ASNT-certified.

It is important that radiography licensees* and applicants note that while the rule permits licensees and applicants to use ASNT certification of radiographers in lieu of certain descriptions required by §34.ll(b), it does not waive the other requirements in §34.ll(b), §34.31, and Appendix A of 10 CFR Part 34. Furthermore, this rule also does not change the requirements for radiographers* assistants and the descriptions of the periodic retraining and training in operating and emergency"procedures as specified in §34.ll(b)(2) and §34.ll(b)(4). When reviewing a license application, as stated earlier, NRC staff will continue to examine how the applicant intends to train prospective radiographers in the Appendix A radiation safety topics. If the license applicant intends to conduct this training in-house, the identity of the individual and his/her qualifications must be set fort~ in the application. The NRC will also require the applicant to confirm that prospective radiographers will receive approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of formal classroom training in the 10 CFR -Part 34 Appendix A radiation safety topics.

As noted earlier, the NRC plans to monitor the ASNT certification program. The purpose of such monitoring is to assure that the certification program continues to adequately assess radiographer ompetence in radiation safety and to determine what impacts these amendments have on radiation safety within the radiography industry. The NRC will analyze the costs and benefits-of the program as part of NRC 1 s plan to initiate a subsequent rulemaking which would require third-party certification of all radiographers.

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Public Comments The proposed rule [54 FR 47089, November 9, 1989] specifically so-licited comments on two issues:

1. The provision to provide license applicants the option to af-firm that all of their active radiographers would be certified in radia-tion safety by the ASNT, prior to comencing duties as radiographers, in I lieu of the current licensing requirement to submit descriptions of planned radiation safety training requirements and qualification procedures.
2. The costs and benefits of third-party radiation safety certifi-cation for use by the Commission in its consideration of a planned subse-quent rulemaking that would require radiographer certification.

A total of 52 responses were received. However, the majority of the commenters did not comment on the first issue and directed their comments to the second issue involving third-party certification. The following is a discussion of the c011111ents received.

1. Option to Affirm This issue was addressed by only sixteen (16) of the fifty-two (52) co11111ent letters received. Of those commenting, nine commenters favored the option, and seven were opposed.

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Comments in Favor Those commenters favoring the option made the following points:

1) A standardized radiation safety program could save applicants time and money when submitting a request for a license, since the development of a description of the training program would not be required.
2) The option might save som~*companies considerable effort and expense in that the ASNT program would eliminate the need for them to set up their own training programs and it could perhaps benef~t smaller operators .

.3) Licensees would benefit-because participation in the voluntary ASNT program has the potential to significantly improve radia-tion safety awareness and performance in the radiography indus-try and will provide a higher level of assurance for licensees that their radiographers have received the required training and have an adequate understanding of radiation safely principles.

NRC Response: Comment 2 of those favoring the option appears to indicate a misunderstanding of the proposed rule. Commenters assumed that certification would substitute for the licensee 1 s training program and possibly save the licensee time and ~ense resulting from the training requirement.

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The proposed rule was quite clear on this issue and provided that applicants could affirm that all individuals acting as radiographers would be certified under the ASNT program in lieu of the applicant having to describe an initial training program for radiographers.

The proposed rule also clearly stated that the proposed provisions did not alter the requirements for providing the training specified in 10 CFR 34.31. It was never intended that the ASNT would provide the required training. Rather, ASNT, as part of its certification prograJ11, would require documentation that radiographers had received the specified training. The training of radiographers would remain

  • the licensee's responsibility. A parenthetical statement included in-the new §34.ll(b)(5) is intended to make clear that the licensee will still be required to provide radiographer training. The statement reads 11 This paragraph does not affect the licensee's responsibility to assure that radiographers are properly trained in accordance with

§34.31(a)." The ASNT certification would satisfy the examination requirements of §34.31(a)(4) but only to the extent of the Appendix A topics, and not for topics such as emergency procedures.

The NRC agrees with comment 3 of those favoring the option that the ASNT certification program could lead to improved safety awareness and performance. This coanent also seems to imply that under the proposed rule NRC 1 s current licensees would directly bene-fit from the rule change. As originally proposed however it was not clear whether.the proposed rule only applied to liceAse applicants.

Current radiography licensees would have had to request an amendment to their licenses to utilize the ASNT program. As stated in the notice of proposed rulemaking, it was NRC's intent to encourage 17

industrial radiography licensees as well as applicants for licenses to participate in the ASNT program. After further consideration, the NRC staff recognizes that requiring a current licensee to seek amend-ment of its license would not encourage licensees to participate in the program. In fact, license amendment costs could possibly deter many existing_ licensees from participating in the program. Therefore, the NRC has revised the language of the rule to provide for existing radiography licensees to participate in the certification program without the need for having their licenses amended.

Co1J11110nts in Opposition Those commenters opposing the option made the following points:

1) The ASNT program costs too much.
2) The ASNT program appears to remove oversight from the NRC and 9 leave it in the hands of an organization with a vested interest in radiography. Third party certification rules must be admin-istered by a regulatory body which has the statutory authority to promulgate rules and impose enforcement actions.
3) Since the licensee would still be providing classroom and on-the-job training and conducting the practical examination; and since the ASNT has not COlllfflitted to verifying training and practical examinations, it is imperative that the NRC continue to exercise regulatory control and oversight of radiographer training through its license application review process.

18

NRC Response: At the proposed rule stage the NRC estimated the cost of certification to be $1000 per radiographer. The NRC has reevaluated this cost due to a.reduction in travel costs based upon ASNT plans to offer the examination at approximately 70 locations. The NRC staff now believes the cost to be about $350 per radiographer which is reasonable considering the many facets of the program and the expected improvement of radiographer training and awareness of safety procedures that,could result from certification. In any case, ASNT certification is to be voluntary. Licensees are not required to seek ASNT certification for radiographers.

With regard to the second coD1Dent concerning a perceived loss of oversight*by the NRC, this is neither intended nor ,is it' a likely result.

The NRC will continue its inspection of licensee programs and will ensure that individuals acting as radiographers meet all regulatory requirements.

By these efforts, the NRC_staff will be evaluating the third-party cer-tification prograR1 to ensure its effectiveness. Interested Agreement States may also recognize the ASNT program and thereby also make an assessment of the ASNT program through the- inspection process within their own jurisdictions.

The NRC and the ASNT are also developing an agreement for periodic monitoring of the ASNT program. It is hoped that representatives from the CRCPD and the State of Texas will also participate. This monitoring_ will be supported through an exchange of information between ASNT and NRC (which has been stipulated in an agreement between the two parties and which is discussed in the section on ASNT IRRSP certification) concerning the dis-position of reports of unauthorized practices by individual radiographers or problems with a licensee training program.

19

With regard to the last comment concerning NRC regulatory control and oversight of radiographer training, NRC will continue to monitor training since the final rule does not relinquish training or supervision of training to the ASNT, and does not affect the training of radiogra-phers' assistants. The rule simply allows the ASNT certification to be used by licensees and license applicants as a means for meeting the re-quirements of §34.ll(b) and the examjnation requirements for radiation safety topics in §34.31(a)(4). The NRC.staff believes, however, that pass-ing the ASNT examination may be a better indicator of the adequacy of a licensee's*training"program than an NRC review of the applicant's descrip-tion of the training program and an outline of the list of subjects to be covered. The staff notes that State of Texas representatives haye indi-cated that some companies providing training to industrial radiographers in that State have had to upgrade their training programs to ensure-that trainees would be able to pass-the Texas examination. As part of its license review process, the NRC will continue to determine how a licensee or license applicant intends to provide this training to its employees.

If the licensee intends to conduct this training in-house, the NRC will continue to review the qualifications of the individuals -conducting the training as well and will also assure that total duration of training will be a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

2. Mandatory Third-Party Certification The proposed rule solicited comments on the costs and benefits of third-party certification which would be used by the Coonission in its 20

consideration of planned subsequent rulemaking that would require radiog-rapher certification [54 FR 47069].

Comments: Of the persons responding to the proposed rule, most com-mented on this issue. The proposed rule did not state that if there were mandatory third-party certification the ASNT would be the only third-party certifier. Nevertheless, most c0111Denters assumed this would be the case, with the result that many coR111ents included criticism directed to-ward the ASNT and provided little discussion of the major issues associ-ated with requiring radiographer certification. In spite of this, numerous questions were raised regarding mandatory third-party certifi-cation which the Commission will consider in any subsequent proposed rulemaking relating to mandatory third party certification. The follow-ing is a sUR1Rary of the ~omments made on this issue:

1. The criteria that other third-party certifiers would have to satisfy should be identified.
2. Will ASNT-certified radiographers have to be recertified in Texas or in other States that develop their own programs? Who will de-cide whether there will be reciprocity among the various certification programs?
3. If there are multiple certification programs, who will have the authority to decertify individual radiographers for cause?
4. Since the NRC does not regulate x-rays, who will certify x-ray radiographers in States that do not have their own certification program?
5. Unless there is a national certification program with reciproc-ity among all States, revoking a radiographer's certification in any par-ticular State will be ineffective in preventing him/her from working in another State.

21

6. Rules that are to become matters of compatibility should be developed in close cooperation with the States through a joint rulemaking

' effort.

7. NRC shou'ld form a task force to develop procedures to handle reciprocal recognition of the training and experience criteria estab-lished by various entities for certification of industrial radiographers.

Impact of the Rule The ASNT initially had estimated the initial cost of certification to be approximately $1000 per radiographer based on a conservative as-sumption that radiographers would have to travel to *a central location to take the certifying ex~ination. The cost estimate included examination and certification fees of $95 for ASNT members and $140 for non-members. The remainder of the estimate CORIJ)rised the costs for travel, food and lodging fo~ a radiographer applying for certification. At the present time, ASNT plans to offer the examination at approximately seventy (70) of its local ASNT chapters throughout the United States. This approach should reduce travel, food and lodging costs to about $200-$300 per radiographer. The present estimate of the initial cost is therefore approximately.$300-$400.

Cost for renewal of certification, which is required every 3 years, is $55 per radiographer for certification without examination for mem-bers, and $100 for non-member certification without examination. The requirements for recertification without examination are discussed under ~

th,e section "The ASNT IRRSP Certification Program. 11 The costs of renewal where an examination is required would be the. same as for an initial certification.

22

Based upon experience with similar voluntary certification programs in other industries such as welding, the staff estimates that about 10

' percent of the eligible radiographers, numbering about 7,000, will seek certification each year. At an overall cost of $300 to $400 per radiographer, the annual cost to the industry will be $210,000 to $280,000.

However, because the certification provided for by this rule is volun-tary, all of the costs will be incurred voluntarily by licensees and individual radiographers. Those choosing the option to incur these costs will do so only becau~e they perceive that the benefits obtained from pursuing this alternative are sufficient to justify'the expense.

The NRC, as well as those who commented in favor of the proposed rule, believe that voluntary participation in the program has the poten-tial to significantly benefit the industry as a whole as well as regula-tors, by adequately ensuring the effectiveness of the training, improving the standard of radiographer training and raising the level of profes-sionalism and knowledge among radiographers and their attention to radi-ography safety procedures.

Environmental Impact: Categorical Exclusion The NRC has qetermine~. that this regulation is the type of action described as a categorical exclusion in 10 CFR 51.22(c)(3)(i). There-fore, neither an environmental impact statement nor an environmental as-sessment has been prepared for this final rule.

23

Paperwork Reduction Act Statement This final rule does not contain a new or amended infonnation col-iection requirement subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.). Existing requirements were approved by the Office of Management and Budget approval number 3150-0007.

Regulatory Analysis The Cormnission has prepared a regulatory analysis on this final regulation. The analysis examines the costs and benefits of the alterna-tives considered by the Commission. The analysis is available for inspec-tion 1n the NRC Public Document Ro011, 2120 L Street NW. (Lower Level),

Washington, DC. Single copies of the draft analysis may be obtained from Dr. Donald 0. Nellis, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory COlllfflission, Washington, DC 20555, Telephone (301) 492-3628.

Regulatory Flexibility Certification As required by the.Regulatory Flexibility Act (5 U.S.C. 605(b)), the Commission certifies that this rule does not have a significant economic impact on a substantial number of saall entities. While the regulation affects all industrial radiography licensees and license applicants, it is in the form of an option so that any costs incurred under the regula-tion are voluntary. Under the current regulatiQns, license applicants are required under 10 CFR 34.ll(b) to provide written descriptions of initial radiation safety training and the means used to determine radiog-24

,::_ * > I raphers 1 knowledge and understanding in this area. This final rule per-mits substitution of ASNT certification of radiographers for these written descriptions and allows current NRC radiography licensees as well as license applicants to take advantage of the ASNT program as previously described. Certification, which is voluntary, will initially cost $300 to $400 per radiographer. Certification is for a period of 3 years and the costs of recerti'fication without re-examination are $55 for members and $100 for non-members for those qua 1i fi ed. The addi ti ona 1 c_osts involved in this option are voluntary and could be _incurred either by the licensee or by the individual radiographer. The NRC believes that those who select this option do so because they believe that the addi-tional training and prestige that accompany certification are worth the added cost. However, the potential improve1Rent in safety awareness and perf9rmance is believed to be significant and the overall benefit to industry is believed to outweigh any economic impact on small entities.

Backfit Analysis The NRC has deter111ined that the backfit rule, 10 CFR*S0.109, does not apply to this rule and, therefore, that a backfit analysis is not required _for this rule because these amendllents do not 1nvo l ve any provi-sions which would impose backfits as defined in 10 CFR 50.109(a)(l).

25

List of Subjects in 10 CFR Part 34 Packaging and containers, Criminal penalties, Radiation protection, Radiography, Reporting and recordkeeping requirements, Scientific equip-ment, Security measures.

For the reasons set out in the preable and under the authority of .

the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 552 and 553, the NRC is adopting the following amendment to 10 CFR Part 34.

PART 34 - LICENSES FOR RADIOGRAPHY AND RADIATION SAFffi REQUIREMENTS FOR RADIOGRAPHIC OPERATIONS

1. The authority citation for Part 34 continues to read as follows:

AUTHORITY: Secs. 81, 161, 182, 183, 68 Stat. 935, 948, 953, 945, as amended (42 U.S.C. 2111, 2201, 2232, 2233); sec 201, 88 Stat. 1242, as amended (42 U.S.C. 5841).

Section 34.32 also issued under sec. 206, 88 Stat. 1246 (42 U.S.C.

5846).

For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C.

2273); §§ 34.22, 34.23, 34.24, 34.25(a), (b), and (d), 34.28, 34.29, 34.31(a) and (b) 34.32, 34.33(a), (c), and (d), 34.41, 34.42, and 34.43(a), (b) and (c), and 34.44 are issued under sec. 161b, 68 Stat.

26

948, as amended (42 U.S.C. 220l(b)); and§§ 34.ll(d), 34.25(c) and (d),

34.26, 34.27, 34.28(b), 34.29(c), 34.31(c), 34.33(b) and (e), and

' 34.43(d) are issued under sec 1610, 68 Stat. 950, as amended (42 U.S.C.

2201(0)).

2. In§ 34.11, paragraph (b)(S) is redesignated as paragraph (b)(6) and a new paragraph (b)(S) is added to read as follows:

§34.11 Issuance of specific licenses for use of sealed sources in radiography.

(b)

(5) In lieu of describing its initial training prograJ1 for radiog-raphers in the subjects outlined in Appendix A of this part, and the description of and the neans used to determine the radiographer 1 s knowledge and understanding of these subjects, the applicant affirms that all indi-viduals acting as radiographers will be certified in radiation safety through the Certification Program for Industrial Radiography Radiation Safety Personnel of the American Society for Nondestructive Testing, Inc.

(ASNT-IRRSP) prior to conmencing duties as radiographers. From [insert effective date of rule] to the date of the renewal of an existing license, an approved license application is deemed to include the option, for indi-viduals who are certified in radiation safety through the ASNT-IRRSP, to substitute ANST-IRRSP certification in lieu of the described means to determine a radiographer's knowledge and understanding of the subjects in §34.31(a)(l).

27

(This paragraph does not affect the licensee's responsibility to assure that radiographers are properly trained in accordance with §34.31(a)).

lit Dated at Rockville, Maryland, t h i s ~ day ofU., 1991.

For the-Nuclear Regulatory Commission.

or or Operations.

28

STATE OF ILLIN0IS DEPARTMENT OF NUCLEAR SAFETY 1035 OUTER PARK DRIVE SPRINGFIELD, IL 62704 (217) 785-9900 TERRY R. LASH DIRECTOR April 5, 1990 Secretary of the Commission U.S. Nuclear Regulatory Commission

~. Yashington, D.C. 20555 Attn: Docketing and Service Branch Re: Proposed Amendment to 10 CFR 34, "Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations", 54 Federal Register 47089-47091 (November 9, 1989).

The Illinois Department of Nuclear Safety (IDNS) hereby submits its comments on the above-identified proposed amendment concerning the training requirements for industrial radiographers. Illinois is an Agreement State and IDNS is the agency in Illinois with responsibility for protecting workers and the public from the potentially harmful effects of ionizing radiation. We reserve the right to comment on the acceptability of the American Society for Nondestructive Testing (ASNT) certification until we receive, and review a copy of the ASNT Program.

It is our understanding that details of the ASNT program are still being developed; therefore, it appears premature to amend 10 CFR 34 to allow use of

- . the program at this time.

It has been stated that the NRC may require Agreement States to accept ASNT Certification by designating it an item of compatibility. The Department would object to such a proposal. An Agreement State should have the flexibility to develop alternatives to the ASNT Certification process including enforcement.

Further, testing is only part of the program to insure adequate training and experience before authorizing individuals to use radioactive materials as a radiographer. We urge the NRC to form a task force to develop procedures to handle reciprocal recognition of each other's training and experience qualification criteria for industrial radiographers. The states represented on the task force should be those with a significant number of radiography licensees.

Sincerely, fl w r

~ Paul Eastvold IcUvl f* Manager , Office of Radi ation Safety PDE:gs cc: B. J. Holt, NRC Region III

u.-,. NUCLEAR REGULATORY COMMISSION DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date ~ _t____

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Georgia Power Company DOCKET NUMBER PR 333 Piedmont Avenue Atlanta, Georgia 30308 PROPOSF.I) RULE a4 <<bt Telephone 404 526-7002 (54 F~4'108Cl)

Mailing Address: OOCKEiED Post Office Box 4545 USN1C Atlanta, Georgia 30302

-go HAR -5 P7 :19 K. E. Adams the southern electnc system Senior Vice President Fossil and Hydro Power QFFICi: Of SECRElARY OOCKEilNG & '.i[tlV ICf.

BRANCH February 28, 1990 Mr. Samual J. Chilk Secretary of the Commission United States Nuclear Regulatory Commission Washington, DC 20555

Subject:

Nuclear Regulatory Commission Proposed Amendment to 10 DFR Part 34 Mr. Chi lk:

On November 9, 1989, as published in the Federal Register, the Nuclear Regulatory Commission (NRC) proposed to include the American Society of Nondestructive Testing, Inc., (ANST) radiation safety program entitled "Certification Program for Industrial Radiography Safety Personnel" as a requirement for active radiographers in addition to current licensing requirements (proposed amendment to 10 CFR 34.11 (b)

(5) - 54 FR 47089).

We offer the following comments:

1. To review only the proposed amendment to 10 CFR Part 34 without having ASNT's details of implementation of the program or the published program is not consistent with the "incorporation by reference" process. Prior to the issuance of a final rule, the Director of the Federal Register and ASNT should make available the program and the implementation plans for review and comment.)
2. The referenced NRC Proposal would require all individual radiographers to be certified per ASNT requirements in the area of radiati dn safety and be placed on a national reg~ster of Certified Radiographers. The certifie-at-lon woul~-- -

be for a three year period; therefore, requiring examination every three years for each radiographer.

The cost could be from $200 to $1,000 per radiographer depending on the location of the test. It should be noted that all present state requirements for radiation safety would remain as is.

~nowfed by

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Mr. Samual J. Chilk February 28, 1990 Page Two It is therefore our recommendation that the proposed NRC Certification Program not be approved. In our opinion, the NRC Program offers no di rect benefit to Georgia Power Company, and would only increase our costs involved in maintaining our radiography program.

We further do not believe that the proposed revision would be in the best interest of the Nuclear Industry and we neither agree with nor support the intended purpose of this amendment.

K. E. Adams DWW/tt

Boeing Support Services DOCKET NUMBER P.O. Box 3707 PROPOSED RULE 34 Seattle, WA 98124-2207

( 54 FR~17D'69 )

@)

I tJ CKLi [O February 5, 1990 US NRC 4-1210-90R-0086

  • 90 FEB 26 PS :41 Secretary Attention: Docketing and Service B~ h oF SECRt-. TARY U. S. Nuclear Regulatory Commission DUCKt I ING & SEiN1r.r.

Washington D.C. 20555 BRANC~

Subject:

Proposed Changes to 10CFR Part 34 "ASNT Certification of Industrial Radiographies" Reference RIN 3150-AD 35 BOEING

Dear Sir:

The Radiation Health Protection organization of The Boeing Company does not believe the subject rule change will significantly improve radiation protection procedures and practice s. This same conclusion was reache d in 1984 by a radiography steering committee formed by the NRC to study this i ssue. What is needed is higher quality in-house training, testing, and radiation monitoring procedures for radiographers and support personnel. Licensees who already provide these features of a radiation protection program should not be penalized by having to send employees to outside training.

This rule change will also cost a great deal more than the NRC estimate of $1,000 per radiographer. The cost an outside quality training program (which will be necessary to pass this exam) will be $800 - $1200 alone. Then you have transportation, lodging, time off the job and finally the additional cost to travel to a site to take the exam. Then the process would be repeated if an applicant failed the exam, which judging by data from the people who developed the test, approximately 20 percent of those taking it will fail. These expenses will drive up the cost of industrial radiography and drive smaller firms out of business. This money would be better spent on improvements in in-house training, and more thorough assigning of radiation protection responsibilities.

In summary this rule change will not significantly improve radiation safety and could drive many small companies out of business. For this reason, we oppose it.

(]Aa ~ ~

fill fI'am E rgan Radiation ealth Protection Org. 4-1210 M/S 6Y-38 Phone 393-3050 TDG:rs

NUCLEAR REGULATORY COMMISSIOl'-

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Amoco Oil Company Yorktown Refinery Post Office Box 578

-go FEB 22 P5 :23 Yorktown, Virginia 23690-0578 Manufacturing Department 804-898-5120 J. E. Stanhope Manager -FF!C!:" OF SECRE TA.RY

~OCKE1 ING & S( ilVICf t, 8R/\NC'1 February 12, 1990 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Sir:

This letter is in response to your notice of proposed rule making on ASNT certification of industrial radiographers published in the Federal Register of a 9 November 1989 (54 FR47089). Amoco Oil Company, Yorktown, Virginia refinery, has proven to be a leader in industrial radiography training and safety since the early 1960's. Amoco has developed, updated, and implemented an intense radiography training program for its employees which has been reviewed and accepted by the NRC.

Let it be known that Amoco Oil Company, Yorktown, Virginia refinery is opposed to the proposed rule making requiring ASNT certification of industrial radiographers mandatory.

Not only would this rule waste the years of experience and money Amoco has spent developing its in-house radiation safety training program, but it would prove to be a major set back to industrial radiation safety as a whole. I question how the NRC proposes to improve radiation safety among the industrial radiography sector by requiring that an inexperienced, unproven, and unregulated organization provide radiation safety training.

Under present regulations, the NRC monitors/regulates the industrial radiography training programs of licensed user and holds the user responsible, liable for this training. Under the proposed rule, the ASNT will not be held liable for any claims, demands or cause of action as a result of an applicant's certification. This is a step backwards.

On January 31, 1990, John J. Munro, Ill of RTS Technology, Inc. responded to this proposed rule (copy attached). I strongly support Mr. Munro's stand on this proposed rule and join him in urging you to withdraw this proposal.

Very truly yours, tw,t J~

R. W. Birdsong, Supt.; Engineering and Inspection John J. Munro, Ill ATS Technology, Inc.

SBS /wp

.I. NUCLEAR REGULATORY COMMISSION DOCKETING & SERVICE SECTION OFF ICE OF THE SECRET ARY OF THE COMMISSION Document Statistics Post rk Date -d-,/_'-+---=-Cj_O_ __ __

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RTS TECHNOLOGY, 1Nc.

A Company of the Sauerwein Group Il;!i l'-------

ATS TECHNOLOGY , INC.

35 Flagship Drive 31 January 1990 North Andover, MA O1845 Telephone 508-683*5211 Telefax 508*683-9469 Secretary U. S. Nuclear Regulatory Com mission Washing ton, DC 20SS5

Dear Sir,

This letter is in response to your notice of proposed rule making on ASNT Certification of Industrial Radiographers published in the Federal Register of 9 November 1989 (54 FR 47089).

From the public record, it is quite clear that the US Nuclear Regulatory Com mission is concerned about the safety record of the industrial radiography industry. In a Notice published in the Federal Register on 10 January 1990 (SS FR 843), it states that the NRC has been concerned about the number of radiation overexposures among radiographers for several years. As stated in the supplementary information presented with this current proposed rule, the US Nuclear Regulatory Commission is determined to make every effort to improve the radiation safety record in industrial radiography. I applaud your efforts in this direction. However, I believe that the proposal presented is contrary to that objective.

Under the present regulations, a licensee must submit to the NRC a description of its training program, including a detailed description of the topics to be covered, the qualifications of the instructors and the means to be used to determine the radiographer's knowledge and competence. The NRC has the opportunity to make a judg~ment of the adequacy of the proposed training program and to require the changes necessary to meet its criteria.

Subsequently, through the inspection program. the NRC has the opportunity to review the implementation of this training program for adequacy and to require any changes deemed necessary. This proposed rule removes the training and qualification of radiographers from NRC oversight and places it completely in the hands of the industry being regulated. (The proposal is so bold as to state that this removal of NRC oversight will result in a cost savings to the industry!) Whereas the NRC is determined to make every effort to improve the radiation safety record in industrial radiography, and whereas the NRC is not presently satisfied with the safety performance of the radiography industry, it is quite difficult to understand the logic behind the proposal to give up its direct oversight of such a vital aspect as training and relinquish it to self-regulation by the industry.

The problem is further exacerbated by the details of the proposal. The plan is to recognize the certification program of the American Society for Nondestructive Testing (ASNT). However, such a certification program does not, in reality, exist. Although a written program has been drafted, no person has been certified under this program. There is no assurance that such a certification program wi11 be implemented in a manner meeting the objectives of the NRC. There is no NRC control over changes to the program after the rule making process. Furthermore, the ASNT has no history of commitment to radiation safety and has made no noted contributions to the radiation safety of the radiography industry. The purpose of the

  • organization, as stated in its constitution, makes no reference to radiation safety.

One may argue that the proposed ASNT program is similar to the certification program already in use in the State of Texas and conducted by the State of Texas Radiation Control Agency. However, administration of a program by a regulatory agency responsible for radiation safety is quite different to one administered by an industry organization. Prudence would dictate that, as a minimum. the NRC would monitor such a voluntary certification program for several years to assure its adequacy and measure its success in improving radiation safety before granting it recognition.

Granting total control over the qualification of radiographers to an untried and untested program administered by an organization new to radiation safety and controlled by the industry whose radiation safety record is unsatisfactory to the NRC is a serious mistake.

The published proposal is misleading. Although it clearly states that the NRC will recognize the ASNT certification program, it does not delineate this program, nor does it adequately des~ribe the ramifications of the program.

The ASNT certification program places an extensive number of additional requirements on the radiographer above those presently required by the NRC, many of which have no bearing on radiation safety. The requirement that the radiographer comply with the ASNT certification program code of conduct is particularly onerous. This requires additional knowledge on the part of the radiographer, invokes additional governmental reporting requirements (presumably approved by OMB?) and places requirements on personnel conduct above any such requirements of the NRC. The application of sanctions, including revocation of certification, and thereby the right to participate in NRC licensed activities, rests with the industry, in the form of

- RTS TECHNOLOGY, INc.

A Company of the Sauerwein Group I1§11 the ASNT certification committee. This committee is comprised of individuals who are involved in the radiography business. Under such a system, one can find himself being subjected to employment threatening decisions by his business competitors. One's certification, recertification and sanction can be decided by individuals who have a vested economic interest in the outcome. This hardly portends objective regulation.

Furthermore, the ASNT certification program requires the applicant to release the ASNT from any and all liabilities, claims, demands or causes of action whatsoever as a result of his certification. The individual is required to indemnify the ASNT and hold it harmless for any claims by third parties against ASNT as a result of their certification. The cost of such indemnification is not insignificant. However, it does not appear to have been included in the NRC assessment of the economic impact of this rule making. It is also not clear where the NRC receives the legal authority to require an individual to indemnify a private organization in order to participate in an NRC licensed activity.

The fact that these, and other, requirements related to the ASNT certification program were not appended to the published rule making is misleading.

Applying these requirements by reference, without subjecting them to the publication requirements of the rule making process seems less than forthright. However, since this has occurred, I request that you hold a public hearing on this rule making to provide a forum for a full airing of the ramifications of this proposal and to subject it to complete public scrutiny.

Many of the comments made above could be dismissed by the argument that the proposal presented is for voluntary certification by ASNT and that a radiography licensee has the opportunity to continue with the existing program. However, the NRC indicates in this proposal its consideration for making this a mandatory program in a subsequent rule making. This makes the existing proposal all the more onerous.

In May of 1982, the NRC issued an advance notice of proposed rule making on the topic of certification of industrial radiographers (47FR 19152 ). The NRC received a number of written comments on this notice. It also held a series of public meetings about this. The NRC finally withdrew this proposal in September of 1985 (S0FR3801 -1). In its notice of withdrawal of this rule making, the NRC stated "the Commission has concluded that there is no

Illm I______

RTS TECHNOLOGY, INc.

A Company of the Sauerwein Group consensus that a certification program for radiographers would reduce the number of overexposures". Nothing is presented in this proposal to demonstrate why the NRC has completely reversed its earlier conclusion.

If the NRC now feels so strongly that a certification program is necessary.

then it should conduct the program itself or have it conducted by another governmental regulatory agency. If a program were conducted by a governmental regulatory agency, such as the NRC or an agreement state radiation control program. then there would be no question as to the dedication of the program to radiation s~.fety. The program would be conducted by experienced radiation safety professionals with no vested economic interest in the conduct of the program, and by individuals mot.ivated toward improved industry safety.

I believe that NRC relinquishment of the oversight of radiographer training and qualification. this vital aspect of radiation safety, in favor of an untried and unproven program administered by an organization new to radiation safety and controlled by the regulated industry whose radiation safety record is unsatisfactory to the NRC is a grave mistake. I urge you to withdraw this proposal.

Sincerely,

Ille STATt OF" COCK[ 1[D ') .'~ ET NUMB I ------~ US NHC

  • I\Ul JSED RU~

TERRYE. BRANSTAD, GOVERNOR OEP.ARTMENT OF PUBLIC HEALTH

'90 FEB 20~A':/ :~ . -: MARYL ELLIS, OIREr.TI"\~

January 12, 1990 VFF!CE Of SECRFTARY * ( .s'{- FR.. 41l>tfj u0CK[11NG 1. SEtlVtf.f.

BRANCl-i Carlton Kamerer, Director State, Local and Indian Tribe Programs Office of Governmental and Public Affairs U.S. Nuclear Regulatory Comfssion Washington, D.C. 20555

Dear Mr. Kamerer:

I .

I have just completed my coments on your agency's ---p*roposed new regulation to recognize an alternative method of meeting the educational/test standard for industrial radiographers. My initial impression was what should I coment on? The proposed regulation merely says that in lieu of a training program by a licensee, a radiographer for a company can be qualified by meeting the ASNT crfterf a (and being a card-carrying member). At thfs tfme I reserve the right to accept or reject ASNT as acceptable because the standards for ASNT were not publ fshed. It f s hard to accept something when you don't know what the "somethingN you are accepting is.

I am serf ously considering the establishment of an industrial radiographer certification program in Iowa. I am assumf ng that sf nee NRC recognizes ASNT and is threatening the agreement states wfth compatfbilfty relative to industrial radf ographers, I would be 111 advised to ignore the ASNT standard. I would 11 ke to request the following:

1. The standards ASNT/NRC have set relative to education for industrial radiographers.

- 2. Criteria to follow fn establishing a practicum credentialing phase for industrial radiographers. Please be specf fie on subject, testing methods, etc.

3. Written examination criteria. Is the Texas examination going to be the only acceptable test?
4. Special definitions used fn standard.
5. Continuing education requirements relative to recertification.
6. Retesting requirements.
7. Fees for credentialing.

r

8. Penalties for rule infraction.
9. Recfprocfty criteria.

LUCAS STATE OFFICE BUILDING / DES MOINES, IOWA 50319-007!5 / !51!5-281-!5787 FAX # (!51 !5) 281-49!58 / TDD # (!51 !5) 262-61 !56

J . S. NUCLEAR REGULATORY COMMISSK>N DOCKETING & SERVla SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date Copies Received Add ' I Copies Re produced 6s,ecial Distribution 'Rios, PD!<,

~ , C4-Yt.-ica

10. Recertification criteria if not in the renewal phase.

Another request is for infonnation regarding funding. I realize that generally the NRC does not provide funds to state regulatory programs. However, I understand that the agency has provided funds to the State of Texas to develop the industrial radiographer test a*nd has provided in excess of $100,000 to the ASNT to develop its industrhl radiographer credentialing program. My specific question 1s would NRC be willing to fund Iowa activities if we embark on a program to develop a state based credentialing mechanism which would include the use of existing credentialing mechanisms such as the Texas test? If you are unwilling to provide funds, please document your reason.

I would appreciate any additional infonnation that I have not mentioned above. If you have any questions, please do not hesitate to contact me *

  • Sinc"fi~t Don~ rrli:f.?chief Bureau of Radiological Health 515/281-3478 OAF/bf cc: B.J. Holt, NRC Region III CRCPD

c3/ ___,

UU(,;KtT NUMBER PROPOSED RUL State of Lou s ana(5f Department of Environmental Qualflfh1l 0 t./t 2i'4 _,

14 AB~.MJl.

IIU00V ROEMER

  • rm TIMPL!T Governor 90 l"c.o "'~retary Of F!C£ OF SEC)<~TARY rebruary e, 1990 OOCKtilNG & .)tJ VIC f.

BRANCH Carlton Xarnmerer, 0irector State,Local and Indian Tribe Program Office of Governmental and Public Affair*

u.s. Nuclear Re;1.1latory Commi1aion Wa1hington, cc 205S5

Dear Mr . Kammerer:

Please accept the following comments concerning the proposed ASNT certification of industrial radiographer*.

Louiaiana fir1t propoeed to th* Atomic Energy Commission, in 196 7 , a liinited te1tin9 proqram of induatri&J. radiographer* to aes~xe proper training. For whatever reason, this w&s not pureued beyond the initial diecu,aiona.

In 1975, because of an apparent increase in the number of excessive exposures to induatrie.l radiographers, the Nuclear Energy Division undertook an inve1ti9ation into the cauae of the ov*r*xp01ures. On June 6, 1976, in a memorandum to Kr. B. Jim

  • Perter, former administrator of the Division, 1everal au;qeationa were made to addr*** th* Civision'e concern * .&nd during the All*

A;reement State meeting of that same year, the 1u99estiona were ahared with the A;reament States and the NRC, as follows:

1. Th* uae of civil penaltiee. fhere ia no question that civil penaltie1 serve as
  • deterrent to licensee violations. However, they probably impact individ~al radiographer, very little.
2. Interna.l :Ln1pection1 by the management ot the radio;raphy companiea. Thia was first addre11ed ** a lic*n**

condition and eventually incorporated into the regulations. The propo1ed in pection frequencf was once per quart.er per radio;rapher. '

NUCLEAR ENERGY DIVISION P.O. BOX 14890 BATON AOUGE, LOUISIANA 70898-4690 AN EQUAL OPPOATUNITV !M~LOVEFI

~ftiiwledged by card* ~

,- I J.S. NUCLEAR ~~ "t V COMMISSICII DOCKf.TING g

  • VI CE SECT ION OF HCE Of l t r StCRETARY O F THE c..._ MMISSION Documerl t,ttistics Postmark Date __ F!(]_-__ ~ ..:...;---

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- February 7, 1990 lage 2

3. Postin; of performance bonds by zadiography companies.

Thi* waa considered to be aimilar to the a1ae11ment of civil penalties and, therefore, dropped.

4. A third party independent testing prog~am. The teetin; pro;ram waa believed to be a nece aary part of our compliance efforta to aid in evaluating training programs.

S. Eat&bli1h guidelines for qualif icationa ot Radiation Safety Officers.

6. Increase inapection capability 10 that more field inspection* could be performed. Thia waa, and i1, still considered one ot the moat important things that we do.
7. Eliminate the a11i1tant radiographer claaaitication. It was the Divi1ion's opinion that anyone handling radioactive material* ahould be completely qualified and fully trained prior to bein; allowed to do o. An individual with incomplete training ehould not be allowed to wor:k under the *auperviaion" of a qualified individual when aourcea aa lar;e ** indutrial radio;raphy a0~rce1 are bein; handled.
8. Chang** in the way that a lican1e was i11ued for
  • training program were alao recommended. These change, included naming an authorized inetructor on th* lic*n***

By ao doing, 1*r thi1 individual leave, the company, the program would bave to be reevaluated.

In addition, radio;raphy c0mpanie1 :equeatin; training program* were evaluated by a r*pnaentative ot the Division who attended the firat 1uch trainin; program.

Most cf th* above recommendations were adopted _in the 1980 revision to th* Louisiana Radiation bgulation*~ and they resulted in change* to our inspection and lic*nsin9 pro;rams.

The firat te ting of radiographer, by tbe atate alao took pla~* in th* early 1980' a, at which time it wa decided that professional a11i1tanc* *** nece aary to develOF an adequate teat.

NRC was asked for a i tance in this matter by both Texas and Loui iana, and eventually Texas was given financial ***iatance in

Carlton Xammerer, n1rector rebruary 7, 1990

  • ' Page 3 developing a teat.

Thia brief hiatorr ie 9iven in hop** that you will understand the p01ition that toui1iana h11 always taken, and atill takes, concerning th* certification of induatrial radioqraphere, It i*

our opinion that third party independent testing ie an important tool in an overall compliance program. It ie aleo our opinion that thi* would beet be admini t*r*~ by a re;ulatorJ agency. However, one alternative i* for it to be adminiatared by aome other third party. We do not believe that either th* te1tin; program or certification by itaelf ie the an1wer to the hJgh exp01ure1 being experienced by some industrial radi09rapber1. We believe that all of the changes made in th* late 1970'* and early 1980'* have been important to th* overall regulation of induatrial radiography.

T,nni ,-,f An111 ,mppnrt.11, in princisile, the idea of te1tinq of induatrial radiographera. Wa do not think it is necessary that th* individual be certified or licenaed. We aee the te1tin9 program as another tool in evaluating the performance of a licenaee and, tha:efore, consider it part cf out compliance program. We think the other chan;** that were mede, 1uch a1 att nding the training programs, naming th* in1tructore on the licenae, performing field inspections to evaluate the performance cf the radiographer,, and eliminating the aa1iatant radio;rapher cla11ification are just as important aa the testing program. We aleo believe th* internal in1pection by the radio;raphy companies 11 verJ important.

Again, Louisiana can aupport, in principl*, the idea of third party teating. If it ie believed that the certification of th*

radiographer, in addition to thi1 third party teet:Lng, i1 nece11ary and beneficial, Louisiana does not oppose thi1 and will work to ensure th* aucceea of any pro;ram that will provide third party teatinq and improvement in radiation eatety of the indu1try.

  • The proposed rule impli** that ASNT i i a third party.

However, the ASNT con1i1t1 of non*deetructive teetin9 companies and can hardly be claaaified **

  • diaintereated third party. 'l'h*

propoaed rule indic*tee that th* NP.C ataff will monitor the trial program prior to initiating rulemakin;, but it mak** no mention of monitoring the program on a ccntinuin; ba1i1, It i* recommended that the NP.C con1ider continued oversight of tbia certification proiram it it ie adopted.

Carlton Kammerer, Director

  • February 7, 1990 Page 4 It i atron;ly recommended that th* NRC reconaider the position of acceptin9 ASNT certification in lle~ ot th* current requirement for 1ubmittin9 a description of th* applicant'* initial trainin; and t**tiNJ program on radiation eafety, Thi i made because ot our under1tanding that the licensee would moat likely etill be admini1terin9 class room and the on*the*job training, in addition to providin; the practical examination of the on-the-job training. Therefore, it appears that an evaluation of the trainin9 program and the qualific*tion of the inatructore will etill be an important part of the license review, It also appear, that if, after the trial proqram, it is deemed 1ucce11tul by the NRC, the certification pro;ram will becom* a requirement and a matter ot compatibility, It i 1till our

. understanding that compatibility will requi~e that th* ASNT certitication program be the only acceptal>le program. If thi1 i1 true, the Division requeata information concerninq how thi* will impact tho** atat** that wish to admini*t*r their own testing program.

Thank you for this opportunity to provide comment* on this most important matter.

Sincerely, William H, ellr Admini trator Nuclear Energy DJvision 504 925-4S18 lfHS:P.LW:ffs

e Commonwealth Edison 1400 Opus Place Downers Grove, Illinois 60515 DOCKET NUMBER 5'-/

DD PROPOSED RULE [D ~ /

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.? ~I COCKEi[O USNRC
  • 90 FEB 13 P4 :11 February 6, 1990 OFF!C~ OF SECRETARY DOCK ETING ,._ SE HVICf Mr. Samuel Chilk BRANCH Secretary U.S. Nuclear Regulatory Commission Washington D.C. 20555

Subject:

ASNT Certification of Industrial Radiographers

Reference:

Federal Register Volwne 54, No. 218, November 9, 1989, Proposed Rule: American Society of Nondestructive Testing (ASNT) Certification of Industrial Radiographers

Dear Mr. Chilk:

This letter provides Commonwealth Edison Company's (CECo's) comments on the Referenced proposed rule. While CECo is not currently licensed to conduct radiography, the proposed rule will have an indirect cost impact on our company because we utilize contract radiography services.

In general, CECo supports the proposed rule because it offers industrial radiographers an option to develop their own initial training programs and a standard on which to base this training program. CECo would however, like NRC clarification on whether this proposed option establishes a new baseline for assessing licensee training programs.

Adoption of the ASNT program implies that the current requirement for instructing radiographers in the subjects outlined in 10 CFR 34 Appendix A, would only be met if that training was 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in duration. Also it would no longer be sufficient to demonstrate competence in the use of radiographic exposure devices, sealed sources, related handling tools and survey instruments by successful completion of a written test and field examination; but would require 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct experience with radiography sources. If this program is encouraged by the NRC, it is uncertain what impact it will have on companies who use a contractors who do not implemen t the ASNT program.

In response to the request for comments on future rulemaking requiring a third party radiation safety cert if ication, CECo would not be supportive of this agenda. While CECo is supportive of improvements in safety awa r eness; required certificat ion possess an additional hwnan resource burden and eliminates the utility radiation protection training and admin is t r ative programs as a means of supplementing qualif ications t o ensure no undue risk to the health and safety of it's employees and con t ractor s i s incurred.

O, !: 1-lUCLEAR REGULA lO~V COMMtSSION DOCKETING & SERVICE SECTION OFFtCE OF THE SECRETARY OF THE COMMISSION Oocumont St,tiatlea Postmark Dato Copies Recoiv&d Add' I Copies Reµ , ,1.Jwc*~

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Commonwealth Edison Company appreciates the opportunity to provide these comments.

Very truly yours, T.J. Kovach Nuclear Licensing Manager 0652T/RL:wj

DOCKETED USNRC Texas Department of Health >10 FEB 12 P6 :34 Robert Bernstein, M.D., F.A.C.P.

Commissioner 1100 West 49th Street Robert A . m , ~rcRET AR y Austin, Texas 78756-3189 Deput~

Profession

. 1 WW'& SEflV!Cf:

eFvlM?ANC~ -

(512) 458-7111 Hermas L. Miller Radiation Control Deputy Commissioner (512) 835-7000 Management and Administration February 6, 1990 Secretary U.S . Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch Ref : RIN 3150-AD35

Dear Sirs:

Staff members of the Bureau of Radiation Control have reviewed the proposed amendments to 10 CFR Part 34 , "Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations." The American Society for Nondestructive Testing , Inc . (ASNT) "Certification Program for Industrial Radiography Radiation Safety Personnel" was not included with the proposed rule. Without access to the details of this program, it would be very difficult to adequately evaluate and comment on the proposed rule . However ,

this Agency obtained access to the ASNT certification program and offers for consideration the following comments on the proposed rule .

1* The proposed rule creates a lack of regulatory control and oversight in the area of training. The rule will allow licensees to use the ASNT certification in lieu of current rules which require licensees to submit descriptions of planned initial radiation safety training and radiographer qualification programs. By accepting the certification ,

the Nuclear Regulatory Commission (NRC) is relinquishing to ASNT its responsibility to ensure a radiographer is adequately trained . The ASNT certification program does not require ASNT to review or verify a radiographer ' s training . In fact , in a letter dated October 20, 1989, ASNT r e vised its program to delete the re qu irement for 100%

verification of the information on an application for certification.

Therefore , NRC will not be reviewing training and ASNT has not committed to verifying each r adiographer ' s training. In addition , ASNT does not evaluate training programs on-site, as do many regulatory agencies . This lack of review is unacceptable in an industry which has as poor a record in radiation safety as the industrial radiography industry .

..ii. NUCLEAR REGULATORY COMMISSION DOCKETING & SERVICE SECTION OFFICE OF THE SECRET ARY OF THE COMMISSION Document Stat,st ics Postmark Date ~ / ClO Copies Received {

Add' I Copies Roproduc nd 4 _ __

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Secretary February 6, 1990 Page Two

2. The estimated $1,000 cost of an ASNT certification (excluding training costs) will have a detrimental effect on the industrial radiography industry. Over 50% of the radiographers and trainees (assistants) work for small companies with less than 15 employees. These small companies will find it very difficult to pay the cost of having radiographers certified by ASNT, so it is highly unlikely that small companies will voluntarily certify radiographers. Furthermore, small companies competing for contracts from large contractors on sites such as oil refineries could find themselves being required by those contractors to have an ASNT certification, effectively removing them from competition with larger companies.
3. Over 50% of the overexposures to radiographic personnel in Texas were to assistants (prior to 1987). This group of radiographic personnel is not included in the ASNT certification program. Because of this, current licensing requirements would still apply to this group, which constitutes a significant number of employees. Therefore, encouraging radiographers to have an ASNT certification would not significantly improve radiation safety. The estimated cost of $1,000 per radiographer would then not result in a substantial benefit.
4. The ASNT certification program is lacking in many procedural aspects.

The program states that to be certified an individual must receive training from an "ASNT-accredited institution". However, it is not specified what constitutes an ASNT-accredited institution. How wi ll ASNT review such institutions and have minimum qualifications been established for training curriculum? Must an institution pay ASNT a fee to be accredited? Is a membership in ASNT or an ASNT certification required? Also, the certification program requires that each radiographer must have passed a practical exam administered by an institution recognized by ASNT (an NRC or Agreement State licensee).

There are no assurances in the program that ASNT will verify the current license status of anyone administering the practical exam. In addition, the program contains no mechanism whereby ASNT would be required to initiate revocation proceedings at the request of NRC or an Agreement State. Has ASNT ever revoked a certification from one of its other programs? The program appears incomplete in many areas which would be of concern to regulatory agencies.

The following comments address the concept of third-party certification.

This Agency has a serious concern regarding the effectiveness of the third-party industrial radiography certification program currently under consideration by the NRC and the attention which is being placed upon the industrial radiography safety exam itself. Our concern is that undue emphasis is being placed upon the safety exam as the means to achieve our mutual goal of improved radiation safety in industrial radiography when, in fact, the exam has played a part in the overall rule which has resulted in improvement of the safety record of Texas radiographers.

Secretary February 6, 1990 Pag e Three Toe revision of Texas Regulation for Control of Radiation (TRCR) Part 31, "Radiation Safety Requirements and Licensing and Registration Procedures for Industrial Radiography," was developed over a period of five years w1 th careful consideration given to radiography safety problems. During this time, the Agency reviewed overexposure data and determined that the majority of industrial radiography overexposures could be attributed to failure to follow established safety procedures, equipment malfunction, or inadequate safety training. As a result of this data, rules were promulgated which address these problems with the intent of improving the safety record of the industrial radiography industry. TRCR 31. 15 establishes minimum standards for radiographic equipment, TRCR 31. 30 requires two qualified radiographers at temporary field sites which provides an added measure of safety in the event of an emergency at a field location, and TRCR 31. 20 was revised to correct training inadequacies.

To be qualified in Texas, an individual must successfully complete a 40-hour safety training course prior to operating any radiographic equipment, have at least two months of documented on-the-job training, demonstrate competence in the use of radiographic equipment, pass the Agency-administered safety exam, and possess an Agency-issued I. D. card indicating successful completion of the exam. It is not the intent of the Agency that possession of an I. D. card be the sole indicator that an individual meets the regulatory requirements. However, possession of an I.D. card gives the ind iv id ual radiographer direct responsibility for observing safety procedures because the Agency may revoke or suspend an I. D. card.

The changes to TRCR Part 31 became effective in October 1986. Toe enclosed figure shows that overexposures to radiographers are on the decline and that radiographer trainee overexposures have dropped off dramatically. This improvement is a result of all the industrial radiography rule changes implemented in 1986, not just the exam requirement. Toe Agency uses the exam requirement as a compliance tool. Successful completion of the exam indicates compliance w1 th the rule requiring an understanding of radiation safety principles and provides an indication that the radiation safety training received by the individual is adequate.

Under TRCR Part 31, Texas radiographers are already required to meet the same qualifications that are listed in the ASNT certification program. In fact, the requirements in TRCR Part 31 are stricter than those in the ASNT certification program. Therefore, it would be redundant for Texas radiographers to be certified by ASNT or any other third party having the type of program.

To date, the Agency has suspended one I. D. card, and two others are being considered for enforcement action. In each case, the individual passed the exam. This indicates the individuals had an adequate knowledge of safety principles but demonstrated a willful disregard of the rules. For this reason, the Agency feels that any exam or third-party certification requirement must be accompanied by rules similar to TRCR Part 31 and must be administered by a regulatory body which has the statutory authority to promulgate rules and impose enforcement actions.

Secretary February 6, 1990 Page Four The requirements in TRCR Part 31 are proving to be effective in improving the safety record of the industrial radiography industry in Texas. This Agency is proud of our industrial radiography exam program but recognize that the exam is just one aspect of a multifaceted approach to regulating industrial radiography safety. We are concerned that other parties involved in this issue may not be fully aware that the success of our program is dependent upon a cohesive rule package.

If you have any questions concerning these comments, please contact me

  • er ,

Bureau of Radiation Control Enclosure

Figure 1 Radi,:,graphe1* Overe:,.p:,sures > :3R Radiographer Exp:-sure ( 3R 2.S 2.S 20 20 1.S 1S

~umber Number 10 10 s s 0 0 84 85 86 87 88 84 85 86 87 88 Year Year Assistant. ,:,r Trair,ee Exi:*:,se,j > :3R Assist.ant or Trainee E:,:i:*:osed < JR 20 12 18 16 I 10 14 I 8 12 I

  • Jmber 10 I
  • Number 6 8 I *

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  • 86 87 88 0

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  • A.J. Dilts 490 Shrub Rd.

DOCKET NUMBER PR ~

Bristol, CT 060 10 r' ROruSED B!JJ-E ~

C_S ff r£ 47a<T9 cocKEiED USNRC February 2, 1990

~ FEB 12 A10 :29 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Servicing Branch

Reference:

10 CFR Part 34 RIN 3150-ADJS ASNT Certification of Industrial Radiographers

Dear Sir,

The following comments are being submitted for the Commission ' s consideration concerning the proposed amendment to 10 CFR 34 "Licences for Radiography and Radiation Safety Requirements for Radiographic Operations". The proposed amendment would require that all radiographers be certified by ASNT for radiation safety.

I believe that this amendment would not be in the best interest of the commission. At present each licensee is.

required to establish their own training program which must be submitted to the commission for approval. By having ASNT be responsible for this, the licensee's will, by the very fact that they are no longer involved, lose sight of the safety requirements needed in this industry. The industry al-ready has problems with some licensee's negative attitudes toward safety. Let's not add to the problem. I can take an individual and have him pass the ASNT course and still not be a safe radiographer. In fact, the person might not even be a radiographer. I feel the only way to have a safe radiographer is by instilling good safety practices from the beginning.

This can only be accomplished by requiring the licensee to have adequate training from the beginning. Pr ior to taking this exam the radiographer must receive some sort of formal training. This ls where he will learn proper safety technique. If he is to be a safe radiographer he must learn early by example not by some test put together by ASNT. All the tests in the world mean nothing if the radiographer does not practice safety every day.

And lastly, who is going to train assistant radiographers?

The licensee ls still going to be the responsible party. This is where the future radiographer is going to learn his safety habits. One must have the proper safety practices instilled in them from the beginning, before ASNT see them.

l9S

J, l>. NUClfAR REGULAlORY COMMISSIOte DOCKETING & SERVICE SECTION OFFICE OF THE SECRET ARY OF THE COMMISSION Document Statistics Postmark Date t

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Secretary, U.S. Nuclear Regulatory commission Page 2 February 2, 1990 In essence what I am saying is don't put the testing and training in someone else's hand without the responsibility.

If ASNT is going to totally responsible, for classroom, practical training and accidents, fine, but they wont be.

The licensee is still going to be responsible and therefore must have control over the training and testing. If the commission and the industry want to cut down on overexposures then do it by weeding out the unsafe radiographer. Do more field safety audits. Catch the unsafe practices and correct them at that time or get the radiographer removed. If licensees are not willing to do this deny them their license.

Lets not get more third parties with no vested interests involved but get the licensees more active in trying to instill safety in the industry. This is one time when less is better and more bureaucratic involvement thru third party involvement is not better.

Respectfully,

{};alj.JJd?

Albert J. Dilts Facility Radiation Safety Officer MQS Inspection, Inc.

DOCKET NUMBER PROPOS D RULE

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0 PHILADELPHIA ELECTRIC t'-bt("{t~R'S9J USNHC NUCLEAR GROUP HEADQUARTERS "90 f[B 12 A8 :35 955-65 CHESTER BROOK BL VD.

WAYNE, PA 19087-5691 (21 !I) 640-6000 Mr. Samual J. Chilk Secretary of the Conmission U.S. Nuclear Regulatory Comission Attn: Docketing and Service Branch Washington, DC 20555

SUBJECT:

Conments Concerning the Nuclear Regulatory Conmissi on' s Proposed Rule 10 CFR 43, "ASNT Certification of Industrial Radiographers" (54 fR 47089)

Dear Mr. Chilk; This letter is being submitted in response to the Nuclear Regulatory Co111nission 1 s (NRC 1 s) request for conments concerning the Proposed Rule 10 CFR 34, 11 ASNT Certification of Industrial Radiographers," published in the Federal Register (54 47089, dated November 9, 1989).

The Philadelphia Electric Company (PECo) appreciates the opportunity to comment on this proposed rule. PECo agrees with the proposed revisions to 10 CFR 34 regarding American Society for Nondestructive Testing (ASNT) certification for industrial radiographers as described in 54 FR 47089.

Invoking these requirements may result in additional costs to utilities and contract testing companies performing radiography; however, radiation safety would be improved, thereby reducing the chance of overexposure. Therefore, we endorse the NRC 1 s efforts and support promulgation as a final rule.

If you have any questions, please do not hesitate to contact us.

Very truly yours,

/J.(). ~f'-<,f .

G. A. Hunger, Jr.

Director Licensing Section Nuclear Services Department

.t.S. NUCLEAR REGULATORY COMM ISSION DOCKETING & SERVICE SECTION OFFICE OF THE SECQET ARY OF THE COMMI S)!ON Docur.ient ~ *, , cs Postmark Date -Ff:--

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DO~f\fJ NUMBER PR .3 / I PROPOSED RULf TENNESSEE VALLEY AUTHORITY /$1,-/ '

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DOCKETED USNRC LL

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SN 157B Lookou t Place FEB 06 1990 ~ FEB -9 P3 :54 OFFICE OF SECRETARY uOCKEl ING & SEfNICf.

U.S. Nuclear Regulatory Commission, BRANCH ATTN: Document Control Desk Washington, D.t. 20555 Gentlemen:

NUCLEAR REGULATORY COMMISSION (NRC) - PROPOSED RULE 10 CFR PART 34, AMERICAN SOCIETY FOR NONDESTRUCTIVE TESTING (ASNT) CERTIFICATION OF INDUSTRIAL RADIOGRAPHERS TVA has reviewed and is pleased to provide comments on the subject proposed rulemak ing recently published in the November 9, 1989, Federal Regi st er (54FR 47089-47091).

TVA agrees that voluntary participation in the ASNT certification program has the potential to significantly improve safety awareness and performance of industrial radiography personnel. We support the proposed rulemaking allowing the licensee an "option to utilize the ASNT certification program for Industrial Radiography Radi ation Safety Personnel, in lieu of the licensee submitting its radiographic training and qualification program to NRC.

TVA does not believe, however, that mandating third-party certification would achieve the desired result of reducing excessive exposures, since most excessive exposures are a direct result of personnel failing to follow prescribed procedures; a situation that cannot be cured by mandating third-party certification.

In addition to meeting regulatory requirements, TVA's radiological training program's effectiveness is demonstrated on a daily basis in the workplace.

With radiological safety as our primary goal, TVA has experienced no radiological incidents in the 10-year history of our industrial radiographers' training program. We also estimate that the savings associated with administering our own training program as opposed to relying upon a third-party certification has amounted to approximately $100,000 over the 10-year history of the program.

In conclusion, we believe that NRC can best accomplish its goal of achieving safety in the workplace by allowing licensees the option of maintaininig their own training program or using the ASNT program to ensure that personnel have been properly trained in the radiation safety as provided in 10 CFR Part 34.31 and Appendix A.

I An Equal Opportunity Employer

~- ~- NUCLEAR REGULA TORY COMMI SSIOM OOCKETltJG & s~JIVICE SECTION OFFIC : OF H~ SECRETARY OF THE COMMISSION Document S+atist ics

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U.S. Nuclear Regulatory Commission FEB 061990 He appreciate the opportunity to provide these comments.

Very truly yours, TENNESSEE VALLEY AUTHORITY Man~n~ a1i.1cens1ng and Regulatory Affairs cc: Ms. S. C. Bl ack, Assistant Director for Projects TVA Projects Division U.S. Nu cl ear Regulatory Commission One Wh ite Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Hilson, Assis t ant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Re gion II 101 Marietta Street, NW, Suite 2900 Atl anta, Georgia 30323 Mr. Alan K. Roecklein Office of Nuclear Regulatory Resea rc h U.S. Nuclear Regulatory Commission Washington, D.C. 20555

t:OCKUED USNRC

-go FEB -9 P\2 :50 fto/1) 'i/?I -4'-158 uF'*,ci:- OF SECR lAR Y' oo'c*K[T ING & 5ti1VlCf. iiii BRANCH

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(__S '/ F,(' .tf7()g'C/) eoct\£1£0 (ABE) ORVIL COUCH, Owner

  • P. 0. Box 1474
  • Borger, TX 79OO8-1401N~C8O6-273-2733 NORMAN RENEAU, Field Superintendent February 1, 1990 Secretary u.s. Nuclear Regulatory Commission 2120 L Street NW (Lower Level)

Washington, D.C. 20555 Attn: Docketing and Service Branch Re: Proposed NRC Rule concerning ASNT Certification of Industrial Radiographers.

Dear Secretary:

We would like to take this opportunity to make you aware of our feelings toward the above proposal.

As you know, Texas Industrial Radiographers are already required to meet the same gualifications under TRCR 31 Part 31 as the qualifications required in the ASNT certification program. In fact, the requirements in TRCR Part 31 are stricter than those in the ASNT certification program. Therefore, we feel it would be redundant for Texas Radiographers to be certified by ASNT or any other third party having the same type program.

NRC has stated that the potential improvement in safety awareness and performance would outweigh the economic impact on small industrial radiography licensees.

We do not agree with this. Considering that ASNT regula-tions are not as strict as TRCR, how could there be an improvement in safety awareness and performance. As for the economic impact, it would be a financial disaster on the small industrial radiography companies. ASNT estimates the cost to be $1,000.00 per radiographer. It is costing about $300 .0 0 per radiographer to comply with TRCR.

MAR 5 990,. -r~.,

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  • P. 0. Box 1474
  • Borger, TX 79008-1474
  • 806-273-2733 p~~ NORMAN RENEAU, Field Superintendent

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'Nspe,~

Secretary U.S. Nuclear Regulatory Commission February 1, 1990 Page 2 We feel that TRCR is doing a great job and there is absolutely no need to require third party certification.

We ask you to please consider the small industrial radiography companies and rule against third party certification.

Sincerely, Orvil Couch, R.S.O.

President Norman Reneau, D.R.s.o.

Field Superintendent CC: Congressman Bill Sarpalius Congressman Beau Boulter Senator Teel Bivins

.. .DOCKET NUMBER

.. AROPOSED RULE GENERAL OYNAMICS Electric Boat Division 75 Eastern Point Road, Groton, Connecticut 06340-4909 203-446-5960 "90 FEB -8 P3 :57 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, OC 20555 Attention: Docketing and Service Branch

Subject:

Title 10 ,... Chapter 1, CODE OF FEDERAL REGULATIONS, Part 34 -

Proposed Rulemaking: Certification of Industrial Radiographers

Reference:

(a)

(b)

(c)

Federal Register, Volume 47, Number 86, dated May 4, 1982, P. 19152 Federal Register, Volume 54, Number 216, dated November 9, 1989, P. 47089 Title 10 - Chapter 1, CODE OF FEDERAL REGULATIONS - Part 34

Enclosure:

(1) General Dynamics, Electric Boat Division letter to the Commission, dated August 31, 1982: Same Subject

Dear Sir:

General Dynamics, Electric Boat Division, favors the proposed amendment to reference (c) that will provide radiography license applicants the option to have their radiographers certified by the American Society for Nondestructive Testing (ASNT) in lieu of sul:xnitting descriptions of planned initial radiation safety training-and qualification procedures.

General Dynamics, Electric Boat Division, remains opposed to the suggested rulemaking that would require a third-party certification of radiographers.

Comments solicited by reference (b) are herein sul:xnitted as enclosure 1.

Enclosure 1 contains the list of comments originally sul:xnitted on August 31, 1982 as solicited by reference (a).

Sincerely, GENERAL DYNAMICS Electric Boat Divi5ion R. G. Scheel, Manager QA Engineering RGS:FHD:cag Enclosure Acknowledged by card * * * * - - * - . . - ~

I,

. . . R\JCLEAR REGULATORY COMMISSIO,,.

DOCKETING & SERVICE SECTION OFFICE OF THE SECRET ARY OF THE COMMISSION Document Statist ics Postmark Date Copies Received

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GEN ERAL CVNAMIC:S Electric Boat Division Secretary of the Commission U.S. Nuclear Regulatory Commission Page 2 February l., ] 990

'Internal Distribution:

F. H. Davison/322 H.J.

  • Donah~e/438 W. C. Everett/602 W. H. Lord/601 R. V. Pierce/320 C. J. Stavros/322

/

/

. GENERAL CYNAMICS Electric Boat Division Eastidn Po,n1 Road. Groton. Connect,cut 06340 ENCLOSURE (])

August 31, 1982 Secretary of the ColTrilission U.S. Nuclear Regulatory Conmission Washington, D. C. 20555

  • Attention: !x>cketing and Service B*ranch

Subject:

Title 10 - Chapter 1, CODE OF FEDERAL REGULATIONS, Part 34 -

Proposed Rulemaking: Certification of Industrial Radiographers

Reference:

l

Enclosure:

(a)

(b)

(1)

Federal Register, Volume 47, Nurrber 86, dated May 4, 1982, P. 19152 Title 10 - Chapter l, CODE OF FEDERAL REGULATIONS - Part 34 Corrr.:-ents Regarding Subject Proposed RuJ.~making

  • /

Dear Sir:

General Dynamics, Electric Boat Division, submits herein corrrnents solicited by reference (.a) relative to the 10 CFR 34 proposed rulemaking for the implement-ation of a third-party certification program for industrial radiographers.

Selected items from reference (a) have been addressed separately in the attached enclosure. Electric Boat Division, which opposes the suggested

_certification program, has chosen not to conment on items that refere.nce conditions ~ssociated with the implementation of such a program.

Electric Bdft Division offers for NRC consideration what it considers to be a viable alternative to those discussed in reference (a} to enable the NRC to determine the effectiveness of the training programs administered by radio-graphy licensees. This alternative is addressed in Item 10 of enclosure (1).

Sincerely, GENERAL DYNA~ICS Electric Boat Division

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H. Surp~t , Ma nager' Nondestructive Tes ting and Engineering RHS/CJS/cer Enclosure /

... GENERAL DYNAMICS Electric Boat Division Secretary of the Conmission U.S. Nuclear Regulatory Conmission Page 2 August 31, 1982 Internal Distribution:

H.J. Donahue/438 S. M. Hirschberg/602 W. H. Lord/601 R. V. Pierce/320 C. J. Stavros/324

ENCLOSURE (1)

Page l of 4 ITEM 1: Is the training provided to radiographers under the present system adequate?

EBDIV. COMMENT: The present system is adequate in that it provides a foundation upon which licensees may develop and administer train-ing programs which satisfy their specific safety needs. Whether a licensee adheres to the training program submitted to, and approved by, the '.lRC is another matter. It is *'feasible that a third-par:y certification program, which provides a standardized training curri-culum, could eliminate deviations

  • from an approved training program.

However, the impracticability of such a program to be designed relative to the hazards unique to each li:ensee's industrial environ-ment should be a major consideration when detennining the adequacy of such a program. EB Div. contends that a third-party certification program would be limited to providing a generalized program and that the more effective method is one which allows responsible licensee management to develop and administer a program that encompasses the general safety requirements as well as those criteria applicable to the conditions unique to each licensee's operations. __.

ITEM 2: Would a third-party certification program reduce the n~mber of overexposures in the radiography indus:ry?

EBDIV. COMMENT: Probably not. While a t~ird-party certification program could conceivably provide the basics of radiation safety, it could not guarantee adherence to established safety procedures or regulations. Radiation safety is the res~nsibility of licensee .

management and only through effective management controls can a re-duction in the number of overexposures anj deviations from establish-ed criteria be realized.

ITEM 3: Would a third-party certification program motivate radio-graphers to work more safely?

EBDIV. COMMENT: It is unlikely that the suggested third-party certi-fication program could provide a motivating force sufficient to ensure that radiographers work more safely. Once again, the emphasis ~ust be placed upon the role that effective management controls play in this area. A responsible management which causes the perfonnance of routin_e and thorough internal audits, and administers progressive disciplinary action for safety violations, is far more effective at motivating radiographers to adhere to established safety procedures than a third-party certification program could possibly be.

ENCLOSURE (1)

Page 2 of 4 ITEM 3: (Continued)

EB Div. maintains an internal radiation audit organization which, in effect, functions as a "third-party" certification and inspection agency with responsibilities separate from those of its production organization. It is accountable for the -training ar.d retraining of radiography oersonnel and t~e auditing of radiograp~y operations to ensure the effectiveness of the training provided a~j compliance with applica~le rules and regulations. The establis~ment of this well-qualified and skeptical presence within EB Div. is the orinci-pal contribu:ing factor to its excellent safety/operating record.

The suggested alternative could not, in our opinion, prov i de EB Div.

with the sarrP- comprehensive commitment to safety re;arding the use of radioisotopes in industrial radiography.

ITEM 4: Wha~ elements in the present system or in tne suggested alternative are parti cularly desi rable or undesirab1e? *--why?

EBDI',*. COMME'.;T: As previo~sly noted, the present sys terr. affords l i ce~sees the fundamental sroundwork upon which the~. may ex::iand NRC safety requirements to more specifically address conditi ons unique to their individual radiography environments . The suggested alternative :annot provide the individualized traini~g that is an esser.tial element for the safe use of radioisotopes i n industrial radiography.

ITEM 5: If a third-party certification program is adopted, what items should be included ir. the standard for deterrr:i ~ing the compe-tence of individuals to act as radiographers?

ITEM 6: If a third-Darty certification program is adopted, should it apply to individuals presently working as radiographers or only to new radiographers?

ITEM 7: If a third-oarty certification program is a:!opted, should certificates be issued to individuals for life or snould there be periodic renewals of the certification?

EBDI\'. COMME!iT: Iter.:s 5, 6 and 7 - EB Div. has chosen not to comment on items which reference conditions that could only exist if a third-party certification program were adopted.

ENCLOSURE (1)

Page 3 of 4 ITEM 8: Would a third-party certification program affect the ability of a licensee to respond to variable manpower needs?

EBDIV. COMMENT: f"'ost assuredly it would. With the present system, licensees may increase their work force and provide training to new-hires whenever workload schedules demand. The adoption of the suggested alternative, however, would place undue restrictions uoon a licensee's manpower loading schedules in that the planning for such would have to coincide with a third-party training calendar.

The concept of a licensee's manpower loading being dependent upon the availability of a third-party certification program is unaccept-a bl e to EB Di v.

ITEM 9: Since a third-party certification program would likely be based on cost recovery by a fee system, would the cost to the licensee of such a program be warranted?

EBDIV. COMMENT: EB Div. contends that neither the fee nor compulsory participation is warranted for such a program for licensees that consistently maintain excellent safety records.

ITEM 10: Which alternative of the two discussed (present system, third-party certification) is preferable? Why? Are there other better alternatives? If so, please explain.

EBDIV. COMMENT: As reference (a) points out, the inherent problem with the present system is the difficulty of verifying the effective-ness of a licensee's training program. EB Div. maintains that a key indicator of the effectiveness of a licensee's training program, as well as its management controls, is its actual operating/safety history.

Rather than imple~ent a third-party certification program, EB Div.

suggests that the NRC revise its inspection policy to enable it to thoroughly investigate chronic safety violators to determine where deficiencies exist. The present means of inspecting training records to determine the adequacy of a licensee's training program cannot provide sufficient verification of training effectiveness or individual radiographer knowledge of NRC regulations and the licensee's operating and emergency procedures. EB Div. contends that NRC inspections of actual radiography operations at a licensee's facilities and/or field .

sites are the most effective means of confirming a licensee's training effectiveness.

/

) ., -. I I**-

ENCLOSURE (1)

Page 4 of 4 ITEM 10: (Continued)

EB Div. recognizes that the numb'e r of radiography licensees places an inspection burden on the NRC and limits the inspections that are conducted in both time and scope. As such, it is proposed that the NRC adopt an inspection policy which would permit it to concentrate its investigative efforts on the licensees that consistently indicate a need for reorganization of management controls and training pro-cedures based on their operating/safety records. The bplementation of a random sampling inspection technt4ue for those licensees tiat consistently exhibit a corrmitment to safety would provide additional time for the NRC to concentrate, on a case-by-case basis, its in-spection (and re-inspection, if necessary} efforts on the chronic violators.

ITEM 11: With respect to the two alternatives, what kind of enforce-ment could and should be taken against radiographers who do not operate equipment safely or follow established procedures? Wha:

rights should radiographers have with resoect to such enforcement actions?

EBDIV. COMMENT: Under the present system, effective management controls should enforce safety procedures by administer ~ng appropriate disciplinary action against radiographers responsible

().

for safety violations. Rights of radiographers, like o:her per-sonnel subject to disciplinary action, would be determined in accordance with applicable labor agreements, company ru l es and ,ro-cedures, corrrnon law principles, and any statutory or regulatory provisions which might apply in a particular case.

ITEM 12: Would a small licensee because of its size bear a dis-proportionate adverse economic impact under a third-party syste~?

EBDIV. COMMENT: No corrment.

ITEM 13: For those organizations that are interested in partic i pating in a third-party certification program, wnat would be t~e esti~~ted cost in implementing such a program?

EBDIV. COMMENT: Should the Corrmission proceed with the implementation of the proposed third-party certification program, EB Div., although opposed to the suggested alternative, expresses an interest in becoming an authorized certifying agency.

The cost involved to implement such a program can only be developed after a criterion has been established as to which portion of the training required by reference (b) will be administered by the third-party certification agency versus that portion for which the licensee

..,~

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  • NUMBER t-'nlJPOSED RULE PR -;:;. ~~I r::,./

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(§1F£ Lf 70%'~}oo7KE AirTransport Association ata OF AMERICA USNRC 1709 New York Avenue, NW *90 FEB -7 P4 :15 Washington, DC 20006-5206 Phone (202) 626-4000 February 2, 1990 Secretary U.S. Nuclear Regulatory Commission Attn: Docketing and Service Branch Washington, DC 20555

Subject:

Proposed Rule on Certification of Radiographers (RIN 3150-AD35)

Gentlemen:

The optional provisions of the proposed rule obviously minimize any impact that this rule would have on ATA members. However the supplementary information to this proposed rule state the intentions of the NRC to proceed with subsequent rulemaking which would require third party certification of all radiographers. ATA has therefore requested its members to respond to the proposed rule as if it were mandatory.

ATA believes that a rule that requires third party certification of all radiographers goes considerably beyond what is needed to address concerns over radiation protection and if adopted would cause considerable disruption within the NOT programs of our members. The existing requirement of ASNT certification that an applicant have 52 O hours of on-the-job instruction before an applicant can be considered for certification, is particularly onerous. A typical NOT inspector within the airline industry practices a number of NOT techniques besides radiography.

Consequently the opportunity to compile 520 hburs on just isotope inspections will require months and even years before existing inspectors could qualify for a certification program. As a practical matter it would force the airlines to contract out much of their radiography workload to outside concerns. While this practice exists now to a limited extent, adoption of a rule which requires third party certification for all radiographers would create critical shortages of contract radiographers that are familiar with the inspection practices of the airline industry.

The inability of airline operators to respond to mandatory inspections affecting their aircraft would cause significant disruption of service to the traveling public.

MAR S 1990

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ATA member airlines agree that effective training of personnel is of great importance in the reduction of radiation incidents and accidents. ATA believes that the excellent record that the airlines have on low radiation exposure and incidents is due in part, to the selection of experienced inspectors for radiography inspections and to the training they receive. Attached is a document entitled 11 ATA Specification 105 11 which serves as an industry standard for in-house training of NDT inspectors. While only recently adopted as an ATA specification, this guideline was derived from the existing training programs of many ATA members. The cirriculum of ATA Specification 105 is similar to ASNT training document SNT-TC-lA in that it provides a curriculum for the basic NDT techniques. It differs from TC-lA in that it is specifically tailored for aircraft applications. The ASNT program is primarily directed to NDT programs outside the airline industry and therefore does not completely respond to the specific needs of our industry.

ATA therefore requests that the NRC withdraw the proposed rule so that ATA members will continue to develop and improve on their own in-house training programs for radiographers. The Federal Aviation Regulations that define an airline's maintenance program require that each air carrier have a training program to ensure that inspectors are fully informed about procedures, techniques and new equipment in use and are competent to perform their duties.

Our members have therefore already invested substantially in their own in-training programs and believe that third party certification of its radiographers will do little to promote safety practices that they cannot accomplish in-house.

If the NRC insists upon proceeding with adoption of the proposed rule then ATA requests that an additional provision be added which allows applicants the opportunity to seek an alternate means of compliance. Adoption of such a provision will ensure that the ASNT program for certification remain competitive.

Attached are the individual comments of the members on this subject. Your consideration of their comments is appreciated.

Sincerely, Don Collier Acting Chief- Engineering and Maintenance Division Attachment

  • J AmericanAirlines MAI NTEN ANCE & ENGINEERI NG CENTER JAN 0 5 1990 AIR TRANSPORT ASSOCIATION 1709 New York Ave. N.W.

Washington, DC 20006-5206 Attn: David Letterer Re£: E&M Exec. Memo 89-144

Subject:

Certification of Industrial Radiographers Contingent upon an analysis of the costs and benefits of third-party certification and demonstrated success of the American Society for Nondestructive Testing <ASNT) Certification program, the Nuclear Regulatory Commission <NRC) is considering the initiation of a subsequent rule making which would require third-party certification of all radiographers. In the next few paragraphs I will summarize the cost and problems associated with this proposed program, and alternatives to third-party certification.

1. Cost/problems associated with proposed program The ASNT has said the total cost will be about $1000 per individual. The actual cost that ASNT will charge £or the service is unknown, they are estimating $150. Airfare, hotel room, meals and transportation associated with taking the examination would be an additional expense. Companies such as American Airlines promote from within, mechanics to inspectors. After spending considerable time and money to qualify an inspector, by contract, he is £ree to bid £or another job within the company. American Airlines presently has 15 radiographers that meet the requirements £or isotope radiography. Under the proposed ASNT Certification program, X-ray (machines> will come under the same requirements ns isotopes. This will require certification of 67 additional inspectors. The requirement of 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of on-job-training (OJT) for x-ray and 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> for isotope radiography, will make it time consuming and more expensive to qualify radiographers. American Airlines uses the same inspector for both X-ray and Isotope radiography. At field stations where x-ray or isotope radiographic inspections are not required on a daily basis, it will become impossible to qualify an inspector i n a reasonable time period.

1 MD LBJ P o. BOX 582809. TULSA, OKLAHOMA 74158-2809. CABLE ADDRESS AMAIR

Also q uestionable i s th e process by which an inspector is certified. The steps required to certify an individual are as follows:

a. Submit application plus required fees for each individ-ual to the ASNT.
b. ASNT will review the qualifications and pass the request on to the Conference of Radiation Control Program Director <CRCPD>. Note: The CRCPD is a non-profit organization that will broker the test for th e state of Texas.
c. The CRCPD will provide the Texas test to a proctor.

The proctor may be an employee of the state health department or a qualified ASHT member, depending upon that states program.

d. After completion of the examination, the proctor will send the test t o Texas for g ra din g. The Texas Department of Radiation Control will notify the ASHT the results of the test.
e. The ASNT will then notify the individual the results of the test. If the individual passed, he will be provided a certificate.

In addition to taking the examination, the individual must sign a statement agreeing to the Rules of Conduct and ASNT's right to revoke their certificate. The individual must attest that the application is true and correct. And he must agree not to hold ASHT responsible <Hold harmless agreement> for any future actions connected with their certificate.

A program such as the one being proposed may be acceptable for small NDT companies that follow construction projects.

They would like to hire radiographers off the street. Large corporations, such as American Airlines, will have increased training cost associated with promoting mechanics to inspectors <radiographers> from within the company.

2. Alternatives to third party certification
a. Why change the present system? The majority of the licensees have a good radiography program. American Airlines has not had a serious violation in the 18 years that ve have been licensed by the NRC. The NRC has the authority <CFR Ti~le 10, Part 2) to prosecute an individuali no additional regulations are needed.

Enforcement of the regulations uniformly to all licensees would be sufficient to minimize radiation 2

exposure to individuals. In the past, the NRC has chosen to hold th* company responsible, not the individual. Nov under the proposed certi:fication program, they will expect the ASNT to revoke the certi:ficate o:f any individual :found guilty :for certain violations.

b. A second alternative could be a dual system. Under this method, the ASNT proposed certi:fication program would be optional. Small companies could hire only radiographers that have a current certi:ficate, while large corporations might choose to remain the same as we are today.
c. A third alternative, would require the Rad iation Sa:fety 0:f:ficer to be a member o:f management and be held more responsible :for compliance with the license. Many s a :fety o:f:fi cers lack proper authority to control the radiation sa:fety program within their company. This has previously been discussed with the NRC and Oklaho ma Department 0£ Health.

In summary, under the proposed program, the ASNT will receive the greatest bene:fit through monetary gains. The small contract NOT shops will bene:fit by not being required to have a training program, while the large corporations will be penalized by increased cost. The cost to American Airlines :for certi:fication o:f 82 inspectors will be $82, 000 .

Licensing o:f programs such as radiography must be regulated by a regulatory agency, not by a non-pro:fit organization with board members appointed bv other board members. The cost o:f implementing a national certi:fication program such as the one being proposed (12, 000 radiographers at $1 000 each) will be $12,000, 000. It has not been su:f:ficiently shown that proper en:forcement o:f the present regulations will not accomplish the same results as the proposed program. Delegating the en:forcement authority to a non-pro:fit organization that requires a Hold Harmless agreement, will create legal problems that may have unpredictable results. Finally, it doesn't make sense to restructure a program that basically has worked well :for the majority o:f the licensees. I:f a certi:fication program is implemented, it should be controlled by a regulatory agency, not the ASNT.

af.~ ~

A.A. Hale Vice President. Engineering 3

TWA 11-ans World Airlines, Inc.

P.O. Box 20126 Kansas City International Airport Kansas City, Missouri, 64195 January 5, 1990 Mr. D. W. Letterer, Director Airworthiness &Technical Standards Air Transport Association of America 1709 New York Avenue, N.W.

Washington, D. C. 20006

Subject:

Certification of Industrial Radiographers - Proposed Nuclear Regulatory Commission (NRC) Rule

Reference:

ATA Engineering &Maintenance Execs Memo No.89-144

Dear Mr. Letterer:

Attached are comments from TWA's Inspection/NOT Department concerning the subject proposed rule.

If you have any questions, please contact me.

ruly yours, C:::-~i---'L_

v~

L. F. Brett, Director Government & Industry Liaison Attachment Icahn Enterprises Tr 1s World * ~CF- Industries. Inc.

  • Icahn & Co. lf'IC. Membet", NYSE.
  • Bayswater Realty & Capital Corp.
  • Foxfield Thoroughbreds, Inc.

G-1502

0fi.'!lii'§!X1@ffeffe0@& @@!X1!11§~/j)@ll[J@§ll[J@[i TWA TO: J. Spicarich FROM: J. Morgan COPIES:

ADDRESS: Dir., Insp. & Insp. Svcs. Mgr., Inspection/ NOT J. Jensen 1-150 ADDRESS: 1-150 J. McCa rthy CITY: MC I CITY: MCI J. Nemecek TELEPHONE: 891-41 28 L. Brett DATE: November 22, 1989 J. Mo 11 enkamp

SUBJECT:

Federal Register NPRM Vol. 54, No. 216, Page 47,089, Thursday, Nov. 9, 1989 I received a Fax copy of the above NPRM Monday, November 20, 1989.

It i s a proposal to change ru l e 10CFR, Part 34 "licenses for Rad i ography and Radi ati on Safety Regul at i ons for Rad i ographic Opera t ions ". (Copy attached) Th i s rule is Part 1 of a two part program. The f i rs t ru le will give the li censee an option to state that all his radiographers have been certi fied by ASNT in lieu of submi t ti ng a detail ed safety training program for rad i ographers.

This will require all radiographers to be certified by ASNT. The second rule will make cert i fication by ASNT mandatory.

REC'D. This program wou l d place a definite economic and personnel burden on TWA's NOT Inspection Program. Some background information NOV 2 71989 follows.

FM&usTR" TWA has a large number of radiographi c operations both in Kansas L!n::::ON City and St. Louis. These are requ i red by AD's and Service Bu 11 et i ns. We have the capability to accomplish a 11 of these i nspections safely and efficiently with 1AM contract personnel at MC I and SGOC. We are not required by the state of Missouri to have a license to operate x-ray or isotope equipment. However, the Federal Government (NRC) requires us to have a license to operate isotope radiography. It includes ou r operating procedures and training program plus an internal aud i t system of record keep i ng .

The NRC (Federal Government Regulator of All Industrial Isotope or Nuclear Operations) has found a need for a Safety Training and Qua l ification Program for all persons working in industrial radiography, including isotope and x-ray. The NRC has solicited a third party certification program to be admin i stered by the ASNT (American Society for Nondestructi ve Testi ng, a non-profit orga nization for betterment of the profess ion) , the Conference of Radiati on Control Program Directors, and the state of Texas.

All of these groups will have a part in the qualification process.

An estimate of the cost by the ASNT and published as part of the NPRM is $1,000 per person for administrative costs, exam fees, travel and lodging at the test site. TWA has 100 individuals working with isotopes and x-ray at MCI and STL under our current 1i cense. The majority of these inspectors work under a uni on contract which must be considered.

FORM G-1510 (M7) PRINTED IN U.S.A.

TWA S/N &40503

J. Spiciadch Page Two November 22, 1989 Some alternatives.

1. Answer the NPRM with the ins is tance that TWA has an isotope radiography program approved by the NRC which i ncludes a training and qualification program. That we have an excellent safety record. That if the NRC approve the ASNT qualification program, it should also continue to approve ours on the basis of their past approval of our program of training and qualification and excellent record.
2. Certi fy our contract people as required at a cost of $100,000 p1us : ( These same people a re current 1y approved by the NRC) . It would also require IAM contract considerations.
3. Certify a sma 11 group of non -contract personne 1 and do a 11 the work with this group (This would have to be negoti ated with the 1AM).
4. Contract our r a - raphi c work out to an outside agency (This would have to be negotiated out of the current 1AM contract).

Time is short, the colTl!'lent period is up February 7, 1990. I would urge your action to the ATA, Senior Management, Legal, Congressional contact on this matter as its impact on airline operation i s significant.

Sincerely, J. L. Morgan JLM/mkd/5/6/

~ . OELTA AIR LINES, INC.

GENERAL OFFICES HARTSFIELD ATLANTA INTERNATIONAL AIRPORT ATLANTA, GEORGIA 3032 0-600 1 U.S.A.

January 3, 1990 Mr. David W. Lotterer Director Airworthiness and Technical Standards Air Transport Association of America 1709 New York Avenue, N.W.

Washington, D.C. 20006

Subject:

Certification of Industrial Radiographers - Proposed Nuclear Regulatory Commission (NRC) Rule

Reference:

Engineering &Maintenance Executives Memo No.89-144

Dear Dave:

The subject proposed rule would provide licensed applicants the option of having their radiographers certified in radiation safety by the American Society for Nondestructive Testing (ASNT) in lieu of current licensing requirements. Further, based upon the demonstrated success of the ASNT certification program, the NRC is cbnsJdering possible future rulemaking to require third party certification of all radiographers.

We have reviewed and we fully concur with your draft comments in response to the proposed rule. Delta ' s position on this subJectiTemains the same as that reflected in our response to EMEX No. 86-62 . The ATA response should request the withdrawal of this proposed rule and ask the NRC to consider alternate training programs, such as ATA Specification 105, to that of the ASNT program for any proposed rule on the subject.

Sincerely,

~President Technrc:~c6perations CJM/NJC:sc

R.

GREATER PITTSBURGH INTERNATIONAL AIRPORT* PITTSBURGH, PA 15231 December 21, 1989 Mr. David Letterer Airport Transport Association of America 1709 New York Avenue, N.W.

Washington, DC 20006-5206

Dear Dave:

Responding to ATA memorandum 89-144, USAir is genuinely concerned and opposed to any involvement or certification of personnel by ASNT or any third party organization. It appears that the ASNT is hell-bent on a self-serving mission at the expense of the traveling public and the airlines with little regard to quality of the end product.

Having worked closely with several other air carriers on development of ATA Spec 105, I believe it to be a viable and comprehensive program which can, and will, address the training, qualification and certification of personnel accomplishing not only radiographic, but all ~on-~estructive ~esting personnel.

The airline industry should pursue action to secure a waiver similar to the medical industry regarding NRC regulations.

USAir's Manager of NDT, Mr. Fred Nardei, will be attending the forthcoming ATA NDT Task Force Meeting in January.

Sincert Stanley w. Switzer Senior Director - Inspection SWS / dcr

Secretary, U.S. Nuclear Regula1'ogy Commission Washington, DC 20555 ~

ATTN: Docketing and Service Branch

Subject:

Certification of Industrial Radiographers- Proposed Nucl,ear Regulatory Commission CNRC) Rule 10 CFR part 31f Pan American World Airways position on this subject is that third party certification would create an undue burden on our company. As stated, the proposed rule is only an option, but the NRC states that their intentions are to proceed with third party certification in subsequent rule making.

The airlines have always had an opportunity to upgrade professional inspectors into NOT inspection positions that use ionization radiation. Training is accomplished in accordance with existing training criteria, called out by the NRC or the agreement States. This is in sharp contrast with the people working in the pipeline or structural radiographic field who may not have had previous inspection experience resulting in higher incident rates.

The burden of having to qualify so many assistant radiographers and even radiographers to complete 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> each of isotope work would be prohibitive. We have 80 inspectors as assistant radiographers and 12 supervisors trained as Radiographers at the New York maintenance base.

We believe that third party certification should be carried out by the NRC with a national licence such as the FAA requires for aircraft maintenance personnel. Third party certification and licensing by ASNT or States compounds our problems when work has to be done in another State or the Inspector transfers to another maintenance base. We have to bear the financial burden of recertifying him in that State.

We believe the NRC should withdraw the proposal and seek other alternatives.

lf l~~

R Hannula Assistant Radiation Safety Officer Pan American World Airways

~

~-=:

CONTINENTAL AIRLINES RESERVATIONS PHONE 398-3000 STAPLETON INTERNATIONAL AIRPORT DENVER, COLORADO 80207 January 3, 1990 Dave Lotterer Air Transport Association 1709 New York Avenue Washington , DC 20006

Subject:

NRC Proposed Rule for 3rd Party Certification of Radiographers

Dear Dave:

  • Continental Airlines is opposed to the above in its entirety.

The rule as now written would be on a volunteer basis, however, it states that it would become mandatory in the future.

Third party certifi~a.ion is not needed at Continental. We have in place a radiation safety cotlb.t bf 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> for all personnel who are scheduled to work in this area of inspection. The safety course is given to the personnel before they start working with radiographers .

Sufficient on the job training is received before their names are submitted to appropriate licensing agencies as a radiographer .

The proposed rule would require 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of on the job training prior to the in-dividual being qualified as a radiographer. This is an excessive amount of time *

  • Continental uses one manufacturers equipment. We are able to qualify the personnel on the safe handling and operation of the equipment in all cases, in 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> . Tests to assure the personnel are qualified to become radiographers are in place.

In our program, requalification is required if an individual does not work as a radiographer for 1 year or shows on the quarterly review tha t he/she is not working in compliance with the applicable federal or state regulations.

The expense of certifying 40 radiographers by a third party is considerable. Not only is the cost of the test a factor, the cost of lost time of the personnel on the job is a heavy burden. The personnel perform many other NDT functions at the airline.

Their presence at the aircraft check lines when not complying with radiography operations is a must .

Sincerely yours, Con i ~ental Airlinesi ,

Richard L. Rohrig

<fi Manager, N. D. T.

RLR/mgb

04 SFOEG-~ NO.409 P002/ 002 11/J un1Tec A1Runes Maintenance Operations Secretary, U.S. Nuclear Regulatory January 11, 11990 I

Commission Washington, D. c. 20555 Attn: Docketing and Service Branch 2120 L. street N. w. (lowe~ level) Washington, o. c.

~oposed Rule Making 10 CFR Part 34 ASNT Certific ation of l ndustr i al Radiographers

  • The proposed rule to r equire third party certi f p roduce unjust hardships on the airline industr

~arriers have develope d and adopted training p r ograms that Yr,f ect ASNT guidelines tailored to airline indus ry

, ~ifi.s The se re p rograms that were approve tion would The air NRC

,g.e . ~, Sates fo r eac h operator. These tra ~

p 09 . have b e ,: f--*rmal i zed and presented as; A... r Tra1sport. sociation - Specification 105.

ography programs emp Of experi e nced ai rcra f t cctot's who have been trained in the safe use of og *~ e quipment. United Airlines for example n 5 i s otope inspections and 4 0 - 50 x -ray

,~r week at SFO. United Airlines has ex erienc_ no person nel over-exposures, has received no safety viola t i ons, a nd has passed State of California Radiation Safety audits. The airlines have a radiation ety record that c annot be matched by t he radiography us ry as a whole.

,

  • 1:. 1111t:s we lcomes un i formity of t r aining and if

- Esary, leg i s lat i on to m ndate that training. Howeve~,

o a so* ~; e ve the irl ii~ maintenance industry has taken upon itself to cre ate t r a in ing programs and adhe re to them .

The ASNT p rogr am of fers no improvement in the c u rrent airl ine program, i t would only add increased costs a nd planning p r oblems.

United Airlines strongly recommends the adoption of rule*

mati ng thitd party certification an option in lieu of th¢ operator s own approved certification program.

s~ncer~y, /

/;,J<j c~!t____,

1 Bob Scob le NOT Manager San F=ranc,sco lntcrnat,onat Airport San Francisco, Cattforn,a 94128 United Airlines

GUIDELINES FOR TRAINING AND QUALIFYING PERSONNEL IN NONDESTRUCTIVE TESTING METHODS ATA SPECIFICATION 105 AIR TRANSPORT ASSOCIATION OF AMERICA 1709 New York Avenue. NW Washington. DC 20006 Phone (202) 626-4000 Printed 1n U S A

(ata) ~PECIFICATION NO. 105 LIST OF EFFECTIVE PAGES CHAPTERl ~ DATE SECTION List of 1 Jan 15/90 Effective Pages Table of 1 Jan 15/90 contents 2 Jan 15/90 3 Jan 15/90 Introduction 1 Jan 15/90

- 1-1 1-1 1-1 1-1 1-1 1

2 3

4 5

Jan Jan Jan Jan Jan 15/90 15/90 15/90 15/90 15/90 2-0 1 Jan 15/90 2-1 1 Jan 15/90 2-1 2 Jan 15/90 2-1 3 Jan 15/90 2-1 4 Jan 15/90 2-1 5 Jan 15/90 2-1 6 Jan 15/90 2-1 7 Jan 15/90 2-1 8 Jan 15/90

- 2-2 2-2 2-2 2-3 1

2 3

1 Jan 15/90 Jan 15/90 Jan 15/90 Jan 15/90 2-3 2 Jan 15/90 2-3 3 Jan 15/90 2-4 1 Jan 15/90 2-4 2 Jan 15/90 2-5 1 Jan 15/90 2-5 2 Jan 15/90 2-5 3 Jan 15/90 2-5 4 Jan 15/90 2-5 5 Jan 15/90 Page 1 Jan 15/90

(ata J sPEcIFIcAT1ON No. 10s CHAPTER/SECTION PAGE INTRODUCTION GENERAL 1-1

1. Scope 1
2. Definitions 1
3. Nondestructive Testing Methods 2
4. Qualifications 2
5. Requirements 2
6. Examination 3
7. Qualifying 4
8. Requalification 4 TRAINING OUTLINES 2-0

- 1. RADIOGRAPHIC EQUIPMENT OPERATING &

EMERGENCY INSTRUCTIONS TRAINING COURSE A. Personnel Monitoring B. Survey Instruments

c. Leak Test of Sealed Radioactive Sources 2-1 1

1 1

D. Radiographical Survey Reports 1 E. Radiography Work Practices l F. Exposure Devices 2 G. Storage & Shipment of Storage Devices 2 H. State & Federal Regulations 2

2. BASIC RADIOGRAPHY PHYSICS COURSE 2 A. Instruction 2 B. Fundamental Properties of Matter 2
c. Radioactive Materials 3 D. Types of Radiation 3 E. Interaction of Radiation with Matter 3 F. Biological Effctis of Radiation 3 G. Radiation Detection 4 H. Exposure Devices & Radiation Detection 4
3. RADIOGRAPHY TECHNIQUE COURSE 4 A. Introduction 4 B. Basic Principles of Radiography 5 C. The Radiograph 5 D. Radiographic Image Quality 5 E. Film Handling, Loading & Processing 6 F. Exposure Techniques - Radiography
4. FILM QUALITY & MANUFACTURING PROCESSES COURSE A. Review of Basic Radiographic Principles 6 B. Dark Room Facilities, Techniques & Processing 6 C. Indications, Discontinuities & Defects 7 D. Radiological Safety Principles Review 7 Contents Pagel Jan 15/90

( ata J sPEcIF1cATI0N No. 10s CHAPTER/SECTION PAGE

5. RADIOGRAPHIC EVALUATIONS & 7 INTERPRETATION COURSE A. Radiographic Viewing 7 B. Application Techniques 8 C. Evaluation of Weldments 8 D. Standards, Codes & Procedures 8 MAGNETIC PARTICLE TESTING TRAINING COURSE 2-2 A. Principles of Magnets & Magnetic Fields 1 B. Characteristics of Magnetic Fields 1
c. Effect of Discontinuities on Materials 1 D. Magnetization by Means of Electric E.

F.

G.

H.

Current Selecting the Proper Method of Magnetization Inspection Materials Principles of Demagnetization Magnetic Particle Test Equipment 1

2 2

2 2

I* Types of Discontinuities 3 J. Test Indications & Interpretation 3 ULTRASONIC TESTING TRAINING COURSE 2-3 A. Fundamental Properties of Sound 1 B. Principles of Wave Propagation 1

c. Genertaion of Ultrasonic Waves 1 D. Ultrasonic Testing Methods 1 E. Ultrasonic of Specific Equipment 2 F. Operation of Specific Equipment 2 G. Specific Testing Procedures 2 H. Variables Affecting Test Results 3 LIQUID PENETRANT TRAINING COURSE 2-4 A. Introduction 1 B. Liquid Penetrant Processing 1
c. Selection of Penetrant Test Methods 1 D. Liquid Penetrant Test Equipment 1 E. Liquid Penetrant Indications 1 F. Inspection Procedures & Standards 2 Contents Page 2 Jan 15/90

(ata J sPecIFIcAT10N No. 105 TABLE OF CONTENTS CHAPTER/SECTION PAGE ELECTROMAGNETIC TESTING TRAINING COURSE 2-5

1. BASIC ELECTROMAGNETIC PHYSICS COURSE 1 A. Introduction to Eddy Current 1 B. Electromagnetic Theory 1
2. ELECTROMAGNETIC TECHNIQUE COURSE 2 A. Read-out Mechanism 2 B. Types of Eddy Current Sensing Elements 2
c. Types of Flux Leakage Sensing Elements 3
3. ELECTROMAGNETIC EVALUATION COURSE 3 A. Review of Electromagnetic Theory 3 B. Factors Which Affect Coil Impedence 3
c. Factors Which Affect Flux Leakage Fields 4 D. Signal/Noise Ratio 4 E. Selection of Test Frequency 4 F. Selection of Method 4 G. Coupling 4 H. Field Strength & Its Selection 5 I. Field Orientation For Flux Leakage Testing 5 J. Instrument Design Consideration 5 K. Applications 5 L. User Standards and Operating Procedures 5 Contents Page 3 Jan 15/90

(ataJ sPEcIFIcATION No. 10s INTRODUCTION In June of 1988 the FAA sponsored an Aging Aircraft Conference which included separate discussion sessions on nondestructive testing (NDT) of aircraft structure. Such sessions included discussion on what training is received by NOT specialist at a typical airline and whether this training is adequate. Certain attending NOT specialists from the Air Transport Association (ATA) member airlines expressed the view that a uniform approach to training NOT inspectors among the airlines was highly desirable but that certification of individuals should be accomplished within tne existing framework of each airline's maintenance training program.

Existing standards such the American Society for Nondestructive Testing (ASNT) Recommended Practice No. SNT-TC-lA and Military standard MIL-STD-410 directly respond to the training and qualification of NDT personnel. In fact the curriculum of individual member programs upon which this guideline was developed, was primarily derived from such standards. However ATA/NDT specialists required a training guideline that was specifically tailored for airplane inspection. A guideline which could be adopted among ATA member training programs was needed.

The first draft of this guideline was developed by NDT representatives from American Airlines, Eastern Airlines, Trans World Airlines, United Airlines and US Air. This draft was distributed among the other ATA members for comment and following minor changes was adopted in January, 1990 by the ATA Engineering, Maintenance and Material Council (EMMC). Also approved by the EMMC was the formation of the ATA NOT Panel which is responsible for review and approval of subsequent changes to this specification.

ATA Specification 105 does not, in itself, impose any performance obligations on any airline, or any other entity. Its provisions become effective only to the extent they are adopted by an airline anc;i incorporated into its manual provided in

  • Sections 121.133, 121.135(b) (19), 135.21 and 135.23(0) of the Federal Air Regulations (14 C.F.R., Sections 121.133, 121.135(b)(19), 135-21, 135.23(0)).

For this reason, any entity which contractually performs maintenance for an airline must determine from that airline which provisions of that airlin~*s manual are applicable to the specific situation. Any recommendations for changes or amendments to the manual of a given airline must be communicated directly to it.

If any airline or other interested person wishes to recommend an alteration or amendment to ATA Specification 105, it should submit its recommendation to the Engineering and Maintenance Division, Air Transport Association of America, 1709 New York Ave., N.W.,

Washington, D. c. 20006. The recommendation and any 'supporting documentation or information will be brought before the next meeting of the group responsible for continuing review of ATA Specification 105 to determine the appropriateness of the proposed amendment.

Page 1 Jan 15/90

(ata J sPEcIFIcAT10N No. 105 GENERAL

1. SCOPE A. This guideline e.stablishes the m.in.imum requirements for training, qualifying, examining, and certifying of nondestructive testing personnel for inspection of aircraft, powerplants, and components. It establishes criteria for the qualification for personnel requiring appropriate knowledge of the technical principles underlying the nondestructive tests they perform.

B. It is recognized that the effectiveness of nondestructive testing applications depends upon the capabilities of the persons who are responsible for performing nondestructive testing.

C. This guideline applies to one or more of the methods listed in Paragraph C "NONDESTRUCTIVE TESTING METHODS."

2. DEFINITIONS A. Terms included in this document are defined as follows:

Qualification - Demonstrated skill, training, knowledge and experience required for personnel to properly perform the duties of a specific job.

Training - The program developed to impart the knowledge and skills necessary to qualify.

Certification - Written testimony of qualification training.

Certifying Agency - The employer of the personnel being certified, or the organization supplying the training to meet the minimum requirements for qualification.

1-1 Page 1 Jan 15/90

(ata J sPEcIF1cAT10N No. 10s

3. NONDESTRUCTIVE TESTING METHODS A. Qualification of personnel in accordance with this recommended guideline should be applicable to the following methods:

(1) Radiographic (RT)

(2) Magnetic Particle (MT)

(3) Ultrasonic (UT)

(4) Liquid Penetrant (PT)

(S) Eddy Current (ET)

NOTE: Methods other than those listed above may be added as the need arises.

4. QUALIFICATIONS A. Prior to qualification, an individual must have sufficient*

training and experience as required by the air carrier to W properly perform the necessary tasks.

B. An individual should be qualified to direct and carry out tests in the method concerned. He must also be able to set up and calibrate equipment (where applicable), read and interpret indications and evaluate them with reference to applicable standards and specifications. He should be thoroughly familiar with the scope and limitations of the method and should have the ability to apply detailed techniques to products or parts within his limit of qualifications. He should be able to organize and report nondestructive testing results.

C. The qualification of individuals may be further subdivided to acknowledge that additional levels of skills may be necessary for specific nondestructive testing applicationse,.

5. REQUIREMENTS A. The air carrier shall establish a written program for the control and administration of personnel training, examination and qualification. This program should include a progressive or recurrent training plan.

B. The air carrier shall designate qualified instructors that have satifactorily completed an approved NOT program for the applicable testing method. Such individuals must have demonstrated practical experience and demonstrated knowledge of the subject.

C. Prior to qualification, personnel will complete sufficient organized training to become familiar with principles and practices of the applicable test method. The training program shall include on the job instruction in basic principles, products, equipment, operating procedures and test techniques which the individual will encounter in his assignment.

(' 1-1 Page 2 Jan 15/90

(ata) sPEcIFIcAr1ON No. 10s D. Refer to Section 2-1 through 2-5 for the training outline for each of the methods, the required minimum content of the organized training material and recommended classroom hours.

6. EXAMINATION A. To be considered for examination qualification, personnel must meet the requirements of this recommended guideline as adapted by the air carrier's written program referenced in Paragraph 5, REQUIREMENTS.

B. Examination to verify physical and technical qualifications shall consist of three segments and will include sufficient examination to assure the training material has been comprehended.

(1) Physical (a) An examination to assure near vision, of at least one eye, either corrected or uncorrected, must be such that the employee can read SNELLEN equivalent of 20/25 (Jaeger fl or Ortho~Rater 18). Distance vision, of at least one eye either corrected or uncorrected, must be equal to or better than SNELLEN equivalent 20/30. The examination must be on a periodic basis, not to exceed two years.

(b) Color vision and/or additional medical requirements shall be considered when preparing the air carriers practice.

(c) The physical requirements currently established by the air carrier for the personnel classification assigned to perform nondestructive testing duties will normally suffice.

(2) Written (a) The written examination shall cover the basic test principles relative to the applicable method and the equipment, operating procedures and test techniques that the operator may encounter in his assignment.

1-1 Page 3 Jan 15/90

(atal sPecIF1cArION No. 10s (b) In preparing the examination, the air carrier should select pertinent questions covering the applicable method.

(c) The examination may also cover the specifications or standards used by the air carrier in its nondestructive testing procedures.*

(3) Practical (a) The person considered for qualification shall satisfactorily demonstrate that he/she is familiar with and.can operate the necessary test equipment and analyze the resultant information to the degree required.

c. Grading and Examinations (1) A qualified instructor of the air carrier's a organization will conduct and grade the qualificatic:9' examinations for each classification.

(2) The examination shall include sufficient questions to assure the training material has been comprehended.

A passing grade of 70% or higher must be obtained.

7. QUALIFYING A. Each air carrier shall establish written procedures covering all phases of qualification as specified in Paragraph 5, REQUIREMENTS.

B. Qualification of personnel shall be based on demonstration of satisfactory performance as determined by procedures outlined in Paragraph 6, EXAMINATIONS.

c. Records of qualification identifying qualified personnel shall be maintained by the employer.

D. At the option of the air carrier, a qualified outside agency may be engaged to provide NDT training and certification.

1-1 Page 4 Jan 15/90

(ata) SPECIFICATION NO. 105

8. REQOALIFICATION A. Personnel may be required to be retrained or reexamined and their certification continued or revoked at the discretion of the air carrier, when they:

(1) Demonstrate unsatisfactory performance.

(2) Have been inactive in the process for 12-month period.

1-1 Page 5 Jan 15/90

(ata) SPECIFICATION NO. 105 TRAINING OUTLINES The entire Body of Knowledge contained in these Training Outlines for the applicable method shall be covered in the training course. The amount of time and depth of coverage for each topic shall be approved by the air carrier

  • 2-0 Page 1 Jan 15/90

(ata) SPECIFICATION NO. 105

1. RADIOGRAPHIC EQUIPMENT OPERATING AND EMERGENCY INSTRUCTIONS TRAINING COURSE NOTE: It is recommended that the trainee receive instruction in this course prior to performing work in radiography. This part of the training is not regulated by the FAA. It mus.t comply with the requirements of the Agreement State or NRC License.

NOTE: Topics so indicated(*) may be deleted if the Radiography is limited to x-ray exposure devices.

A. Personnel Monitoring (1) wearing of personnel monitoring badges (2) Reading of pocket dosimeters (3) Recording of daily dosimeter readings

  • B.

(4)

(5)

"Offscale" dosimeter - action required Permissible personnel exposure limits Survey Instruments (1) Types of radiation survey instruments (2) Reading and interpreting survey instrument meter indications (3) Calibration frequency (4) Calibration expiration - action (5) Battery check - importance

c. Leak Test of Sealed Radioactive Sources
  • (1) Requirements for leak test
  • (2) Purpose of leak test
  • (3) Performance of leak test D. Radiographical Survey Reports (1) Requirements for completing (2) Description of report format E. Radiography Work Practices

( 1) Establishment of restricted areas

( 2) Radiation exposure (3) Use of time, distance, and shielding to reduce personnel radiation exposure.

( 4) Applicable regulatory requirements for surveys, posting and control of radiation and high radiation high radiation areas.

2-1 Page 1 Jan 15/90

(ataJ SPECIFICATION NO. 105 F. Exposure Devices (1) Daily inspection and maintenance for exposure devices

  • (2) Radiation exposure limits for gamma ray exposure devices (3) Labeling of exposure devices (4) Use of exposure devices (5) Use of collimators to reduce personnel exposure
  • (6) Use of "Source Changer" from gamma ray sources G. Storage and Shipment of Exposure Devi.ces and Sources
  • (l) Vehicle accidents with radioactive sealed sources
  • (2) Fire involving sealed sources
  • (3) "Source Out" -- failure to return to safe shielded conditions
  • (4) Emergency call list H. State and Federal Regulations (1) The NRC and agreement states - authority (2) License reciprocity
  • (3) Radioactive materials License requirements for industrial radiography (4) Qualification requirements for radiography personnel (5) Regulations for control of radiation (State/NRC as applicable)
  • (6) Department of transportation regulations for radiography source shipment (7) Regulatory requirements for X-ray machines (State/Federal as applicable)
2. BASIC RADIOGRAPHY PHYSICS COURSE A. Instruction (1) History and discovery of radioactive materials (2) Definition of industrial radiography (3) Radiation protection; Why it is needed.

(4) Basic math review, exponents, square roots, etc.

B. Fundamental Properties of Matter (1) Elements and atoms (2) Molecules and compounds (3) Atomic particles, properties of protons, electrons, and neutrons (4) Atomic structure (5) Atomic number and weight (6) Isotope versus radioisotope 2-1 Page 2 Jan 15/90

(ataJ SPECIFICATION NO. 105

c. Radioactive Materials
  • (l) Production of radioactive materials, (a) Neutron activation (b) Nuclea~ Fission
  • (2) Stable Versus unstable (Radioactive) atoms
  • (3) Curie - The unit of activity
  • (4) Half-line of radioactive materials
  • (5) Plotting of radioactive decay
  • (6) Specific activity - curies/grams D. Types of Radiation (1) Particulate radiation properties: alpha, beta, neutron (2) Electromagnetic radiation: X-ray, gamma ray (3) X-ray production (4) Gamma ray production (5) Gamma ray energy (6) Energy characteristics of common radioisotope sources (7) Energy characteristics of X-ray machines E. Interaction of Radiation with Matter (1) Ionization (2) Radiation interaction with matter (a) Photoelectric effect (b) Compton scattering (c) Pair production (3) The unit of radiation exposure-The Roentgen (4) Emissivity of commonly used radiography sources (5) Emissivity of X-ray exposure devices (6) Attenuation of electromagnetic radiation - shielding (7) Half value layers/tenth value layers (8) Inverse square law F. Biological Effects of Radiation (1) "Natural" background radiation (2) The unit of radiation dose - REM (3) The difference between radiation and contamination (4) Allowable personnel exposure limits and the banking concept (5) Theory of allowable dose (6) Radiation damage - repair concept (7) Symptoms of radiation injury (8) Acute radiation exposure and somatic injury (9) Personnel monitoring for,tracking exposure (10) Organ radiosensitivity 2-1 Page 3 Jan 15/90

(atal sPecIFIcArION No. 10s G. Radiation Detection (1) The pocket dosimeter (2) The difference between dose and dose rate (3) survey instruments (a) Geiger muller tube (b) Ionization chambers (c) Scintillation chambers counters (4) Film badge - ~adiation detector (5) TLD (Thermoluminescent Dosimeters)

(6) Calibration of survey instruments I

H. Exposure devices and radiation sources

  • (l) Radioisotope sources (a) Sealed source design and fabrication (b) Gamma ray sources (c) Beta and bremsstrahlung sources (d) Neutron sources
  • (2) Radioisotope exposure device characteristics (3) Electronic radiation sources - 500 key & less - low e

energy (a} Generator - high voltage rectifiers (b) X-ray tube design and fabrication (c} X-ray control circuits (d} Accelerating potential (e) Target material and configuration (f) Heat dissipation (g) Duty Cycle (h) Beam filtration MINIMUM TOTAL HOURS 40

3. RADIOGRAPHY TECHNIQUE COURSE A. Introduction (1) The process of radiography (2) Types of electromagnetic radiation sources (3) The electromagnetic spectrum (4) Penetrating ability or quality of X-rays
  • (5) Penetrating ability or quality of gamma rays (6) Spectrum of X-ray tube source
  • (7) Spectrum of gamma radioisotope source (8) X-ray Tube -- change of ma or kvp effect on quality and intensity 2-1 Page 4 Jan 15/90

(ata J sPEcIFIcArION No. 10s B. Basic Principles of Radiography (1) Geometric exposure principles (a) Shadow formation and distortion (b) Shadow enlargement calculation (c) Shadow sharpness (d) Geometric unsharpness (e) Finding depth of discontinuity (2) Radiographic Screens (a) Lead intensifying screens (b) Fluorescent intensifying screens (c) Intensifying factors (d) Importance of screen/Film contact (e) Importance of screen cleanliness and care (f) Techniques for cleaning screens (3) Radiographic Cassettes (4) Composition of Industrial Radiographic Film (5) The "Heel Effect" with X-Ray Tubes

c. The Radiograph (1) Formation of the latent image on film (2) Inherent unsharpness (3) Arithmetic of radiograph exposure (a) Milliamperage - distance - time relationship (b) The reciprocity law (c) Photographic density (d) X-ray exposure charts (material thickness, KV, and exposure)
  • (e) Gamma ray, exposure chart (f) Inverse square law considerations (g) Calculation of exposure time for gamma and X-ray sources (4) The characteristic (hand d) curve (5) Film speed and class descriptions (6) Selection of Film for Participation Purpose D. Radiographic Image Quality (1) Radiographic sensitivity (2) Radiographic contrast (3) Film contrast (4) Subject contrast (5) Definition (6) Film graininess and screen mottle effect (7) Penetrameters or image quality indicators 2-1 Page 5 Jan 15/90

(ata J sPec1F1cAr10N No. 105 E. Film Handling, Loading and Processing (1) Safelight and darkroom practices (2) Loading bench and cleanliness (3) Opening of film boxes and packets (4) Loading of film and sealing cassettes (5) Handling techniques for "Green Film" (6) Elements of manual film processing F. Exposure Techniques - Radiography (1) Single wall radiography (2) Double wall radiography (a) Viewing two walls simultaneously (b) Offset double wall exposure single wall viewing (c) Elliptical techniques (3) Panoramic radiography (4) Use of multiple film loading (5) Specimen configuration

4. FILM QUALITY AND MANUFACTURING PROCESS COURSE A. Review of Basic Radiographic Principles (1) Interaction of radiation with matter (2) Math review (3) Exposure calculations (4) Geometric exposure principles (5) Radiographic image quality parameters B. Dark Room Facilities, Techniques and Processing (1) Facilities and Equipment (a) Automatic film processor versus manual processing (b) Safe lights (c) View lights (d) Loading bench (e) Miscellaneous equipment (2) Film Loading (a) General rules for handling unprocessed film (b) Types of Film Packing (c) Cassette loading techniques for sheet and roll (3) Protection of radiographic film in storage (4) Processing of film - manual (a) Developer and replenishment (b) Stop bath (c) Fixer and replenishment (d) Washing (e) Prevention of water spots (f) Drying 2-1 Page 6 Jan 15/90

(ata) SPECIFICATION NO. 105 (5) Automatic filming processing (6) Film filing and storage (a) Retention life measurements (b) Long term storage (c) Filing and separation techniques (7) Unsatisfactory radiographs, causes and cures (a) High film density (b) Insufficient film density (c) High contrast (d) Low contrast (e) Poor definition (f) Fog (g) Light leaks (h) Artifacts (8) Film density (a) Step wedge comparison film (b) Densitometers C. Indications, Discontinuities and Defects

( 1) Indications .

(2) Discontinuities (a) Inherent (b) Processing (c) Service (3) Defects D. Radiological Safety Principle Review (1) Controlling personnel exposure (2) Time, distance, shielding concepts (3) ALARA concept (4) Radiation detection equipment (5) Exposure devise operating characteristics

5. RADIOGRAPHIC EVALUATION AND INTERPRETATION COURSE A. Radiographic Viewing (1) Film illuminator requirements (2) Background lighting (3) Multiple-composite viewing (4) Penetrameter placement (5) Personnel dark adaptation and visual acuity (6) Film identification (7) Location markers (8) Film density measurement ,

(9) Film artifacts 2-1 Page 7 Jan 15/90

(ata) SPECIFICATION NO. 105 B. Application Techniques (1) Multiple film techniques (a) Thickness variation--parameters (b) Film speed (c) Film latitude (2) Enlargement and projection (3) Geometrical relationships (a) Geometrical unsharpness (b) Penetrameter sensitivity (c) source film distance (d) Focal spot size (4) Triangulation methods for discontinuity location (5) Magnification localized (6) Film handling techniques C. Evaluation of Weldments (1) Welding method review (2) Welding discontinuities (3) Origin and typical orientation of discontinuities (4) Radiographic appearance (5) Welding codes and standards - applicable acceptance criteria (6) Reference radiographs or pictograms D. Standardsr Codes and Procedures for Radiography (1) ASTM E94/El42 (2) Acceptable radiographic techniques and setups (3) Applicable employer procedures (4) Procedure/radiograph parameter verification (5) Radiographic reports MINIMUM TOTAL HOURS 40 2-1 Page 8 Jan 15/90

(ata] SPECIFICATION NO. 105

1. MAGNETIC PARTICLE TESTING TRAINING COURSE A. Principles of Magnets and Magnetic Fields (1) Theory of magnetic fields (a) Earth's magnetic field (b) Magnetic fields around magnetized materials (2) Theory of magnetism (a) Magnetic poles (b) Law of magnetism (c) Materials influenced by magnetic fields:

(1) Ferromagnetic (2) Paramagnetic (d) Magnetic characteristics of nonferrous materials (3) Terminology associated with magnetic particle testing.

B. Characteristic of Magnetic Fields (1) Bar magnet (2) Ring magnet C. Effect of Discontinuities on Materials (1) Surface cracks (2) Scratches (3) Subsurface defects D. Magnetization by Means of Electric Current (1) Circular field (a) Field around a straight conductor (b) Right-hand rule (c) Field in parts through which current flows:

1 Long solid cylindrical regular parts 2 Irregularly shaped parts 3 Tubular parts 4 Parts containing critical holes (d) Methods of inducing current flow in parts 1 Contact plates 2 Prods (e) Discontinuities commonly discovered by circular fields (2) Longitudinal field 1 Field produced by current flow in a coil 2 Field direction in a current-carrying coil 3 Field strength in a current-carrying coil 4 Discontinuities commonly discovered by longitudinal fields 5 Advantages of longitudinal magnetization 6 Disadvantages of longitudinal magnetization 2-2 Page 1 Jan 15/90

(ata) sPecIF1cArION No. 10s E. Selecting the Proper Method of.Magnetization (1) Alloy, shape and condition of part (2) Type of magnetizing current (3) Direction of magnetic field (4) Sequence of operations (5) Value of flux density F. Inspection Materials (1) Wet particles (2) Dry particles G. Principles of Demagnetization (1) Residual magnetism (2) Reasons for requiring demagnetization (3) Longitudinal and circular residual field (4) Basic principles of demagnetization (5) Retentivity and coercive force (6) Methods of demagnetization H. Magnetic Particle Test Equipment (1) Equipment selection considerations (a) Type of magnetizing current (b) Location and nature of test (c) Test materials used (d) Purpose of test (e) Area inspected (2) Manual inspection equipment (3) Medium and heavy duty equipment (4) Stationary equipment (5) Mechanized inspection equipment (a) Semi-automatic inspection equipment (b) Single-purpose semi-automatic equipment (c) Multi-purpose semi-automatic equipment (d) Fully automatic equipment 2-2 Page 2 Jan l"'/90

I. Types of Discontinuities Located by Magnetic Particle Testing (1) Inclusions (2) Blowholes (3) Porosity (4) Flakes (5) Cracks (6) Pipes (7) Laminations (8) Laps (9) Forging bursts (10) Voids J. Magnetic Particle Test Indications and Interpretation

( 1 ) Indications of nonmetallic inclusions

( 2 ) Indications of surface seams

( 3 ) Indications of cracks

( 4) Indications of laminations

( 5) Indications of laps

( 6) Indications of bursts and flakes

( 7 ) Indications of porosity (8) Nonrelevant indications MINIMUM TOTAL HOURS 8 2-2 Page 3 Jan 15/90

(atal ~PEcIFIcAT10N No. 10s

1. OLTRASONIC TESTING TRAINING COURSE A. Fundamental Properties of Sound (1) Frequency, velocity, and wavelength (2) Definition of ultrasonic vibrations (3) General application of ultrasonic vibrations B. Principles of Wave Propagation (1) Modes of vibration (2) Acoustic impedance

-,j (3) Reflection (4) Refraction and mode conversion (5) Diffraction and mode conversion (6) Fresnel and Fraunhofer effects C. Generation of Ultrasonic Waves (1) Piezoelectricity and types of crystals (2) Construction of ultrasonic search units (3) Characteristics of search units (a) Frequency-crystal thickness relationships (b) Conversion efficiencies of various crystals (c) Damping and resolution (d) Beam intensity characteristics (4) Care of search units D. Ultrasonic Testing Methods (1) Contact testing (a) Straight beam (b) Angle beam (c) Surface wave (d) Lamb wave (e) Through transmission (2) Immersion testing (a) Straight beam (b) Angle beam (c) Through transmission (3) Modified immersion testing (a) Tests employing special devices (4) Resonance testing (a) Contact technique (b) Immersion technique 2-3 Page 1 Jan 15/90

(ata) SPECIFICATION NO. 105 E. Ultrasonic Testing Equipment (1) Description of basic pulse-echo instrument (a) Time-base (synchronizer) circuit (b) Pulser circuit (c) Receiver or echo-amplifier circuit (d) A-Scan display unit (2) Special Instructions (a) B-Scan display (b) C-Scan display (c) Monitors and recording devices (3) Scanning equipment (a) Manipulators (b) Bridges (c) Special scanning devices (4) Ultrasonic bond test equipment F. Operation of Specific Equipment (1) General operating characteristics (2) Functional block diagram of circuits (3) Purpose and adjustment of external controls (4) care of equipment G. Specific Testing Procedures (1) Selection of test parameters (a) Frequency (b) Search unit size and type (c) Water distance (for immersed tests)

(d) Scanning speed and index (2) Test standardization (a) Ultrasonic standard reference blocks (b) Adjustment of test sensitivity a

( 3) Interpretation of results '1111' (a) Acceptance standards (b) Comparison between responses from discontinuities to those from ultrasonic reference standards (c) Estimated length of discontinuities (d) Location of discontinuities (e) Zoning (4) Equipment performance variations 2-3 Page 2

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(ata J !:1PEcIF1cArI0N No. 10s H. Variables Affecting Test Results (1) Instrument performance variations (2) Search unit performance variations (3) Inspected part variations (a) Entry surface condition (b) Part size and geometry (c) Metallurgical structure (4) Discontinuity variations (a) Size and geometry (b) Distance location from entry surface (c) Orientation to entry surface (d) ~ype of discontinuity-reflecting characteristics TOTAL MINIMUM HOURS 24 2-3 Page 3 Jan 15/90

(ata J sPEcIF1cArION No. 10s

1. LIQUID PENETRANT TRAINING COURSE A. Introduction (1) Brief history of nondestructive testing and liquid penetrant testing (2) Purpose of liquid penetrant testing (3) Basic principles of liquid penetrant testing (4) Types of liquid penetrants commercially available B. Liquid Penetrant Processing (1) Preparation of parts (2) Application of penetrant to parts (3) Removal of surface penetrant (4) Developer application and drying
  • c.

(5) Inspection and evaluation (5) Post-cleaning Selection of Penetrant Test Methods (1) Advantages of various methods (2) Disadvantages of various methods D. Liquid Penetrant Test Equipment (1) Liquid penetrant test units (2) Lighting for liquid penetrant inspection (3) Materials for liquid penetrant testing (4) Precautions in penetrant inspection E. Liquid Penetrant Indications

  • (1) General (a) Reason for indications (b) Appearance of indications (c) Time for indications to appear (d) Persistence of indications 2-4 Page 1 Jan 15/90

(ata) ~PECIFICATION NO. 105

2. Factors affecting indications
a. Penetrant used
b. Prior processing
c. Technique used
3. Establishing acceptance standards
a. Lack of "standards"
b. Standards for repetitive inspection
4. Indication from cracks
a. Cracks occurring during solidification
b. Cracks occurring during processing
c. Cracks occurring during service
5. Indications from laminar discontinuities
a. Cold shut or fold
b. Forging Laps
c. Extrusion defect
d. Seams
6. Indications from porosity
7. Nonrelevant indications F. Inspection Procedures and Standards
1. Inspection procedures
2. Standards TOTAL MINIMUM HOURS 8 2-4 Page 2 Jan 15/90

(ata J sPEcIFIcATION No. 10s ELECTROMAGNETIC TESTING TRAINING COURSE

1. BASIC ELECTROMAGNETIC PHYSICS COURSE A. Introduction to Electromagnetic Testing (Eddy Current/Flux Leakage)

(1) Brief history of testing (2) Basic principles of testing B. Electromagnetic Theory (1) Eddy current theory (a) Generation of eddy currents by me~ns of an A-C field (b) Effect of fields created by eddy currents (impedance changes)

(c) Effect of change of impedence on instrumentation (d) Properties of eddy current

  • 1 Travel in circular direction 2 Strongest on surface of test material 3 Zero value at center of solid conductor placed in an alternating magnetic field 4 Strength, time relationship, and orinetation as function of test system parameters and test part characteristics 5 Have properties of compressible fluids 6 Small magnitude of current flow 7 Relationship of frequency and plane with current in coil 8 Effect of irrelevant permeability variations when induced in magnetic materials 9 Effect of discontinuity orientation 10 Power losses (2) FluxLeakage Theory (a) Terminology and Units
  • (b) Principles of Magnetization 1 B-H Curve 2 Magnetic properties 3 Magnetic field 4 Hysteresis loop 5 Magnetic permeability 6 Factors affecting permeability (c) Magnetization 1 Electromagnetism Theory a Oersted's Law b Faraday's Law c Electromagnetics 2-5 Page 1 Jan 15/90

(ata J sPEcIFIcAr10N No. 10s (d) Flux Leakage 1 Flux Leakage theory and principle

- a Residual b Active c Tangential leakage d Normal leakage fields

2. ELECTROMAGNETIC TECHNIQUE COURSE A. Read-out Mechanism (1) calibrated or Uncalibrated meter (2) Null meter with dial indicator (3) Oscilliscope (4) Alarm, lights, etc.

(5) Numerical counter (6) Marking system (7) Sorting gates and tables (8) Cutoff saw or shears (9) Automation and feedback (10) Strip chart recorder B. Types of Eddy Current Sensing Elements (1) Probes (a) Types or arrangement 1 Absolute 2 Differential 3 Reflectance (b) Lift-off (c) Theory of operation (d) Applications (e) Advantages (f) Limitations (2) Through, encircling, or annular coils (a) Types or arrangements 1 Absolute 2 Differential (b) Fill factor (c) Theory of operation (d) Applications (e) Advantages (f) Limitations 2-5 Page 2 Jan 15/90

( ata J ~PEc1F1cAr10N No. 10s (3) Factors affecting choice of sensing elements (a) Type of part to be inspected (b) Type of discontinuity to be detected (c) Speed of testing required (d) Amount of testing (percentage) required (e) Probable location of discontinuity

c. Types of Flux Leakage Sensing Elements (1) Principles of magnetic measurement techniques (2) Inductive Coil sensors (a) Theory of EMF induced in coil (b) Various constructions and designs of coils (c) Ceil's parameters affecting the flux leakage response (d) Sensing coil systems and connections (single and multi-element probes)
  • (3) Semiconductor sensing elements (a) Hall effect probes (b) Magnetoresistors (c) Magnetodiodes (d) Magneto Transistor (e) Magnetic and electric characteristics of semi-conductor sensing elements (4) Other methods of magnetic leakage field detection (a) Magnetic tape system (b) Magnetic powder (c) Magnetic resonance sensor
3. ELECTROMAGNETIC EVALUATION COURSE A. Rev-iew of Electromagnetic Theory (1) Eddy Current Theory (2) Flux Leakage Theory
  • (3) Types of Eddy Current Sensing probes (4) Types of Flux Leakage Sensing probes B. Factors Which Affect Coil Impedance (1) Test part (a) Conductivity (b) Permeability (c) Mass (d) Homogeneity (2) Test system (a) Frequency (b) Coupling (c) Field strength (d) Test coil and shape 2-5 Page 3 Jan 15/90

(ata] ~PECIFICATION NO. 105

c. Factors Which Affect Flux Leakage Fields (1) Degree of magnetization (2) Defect geometry (3) Defect location (4) Defect orientation (5) Velocity factor (6) Distance between adjacent defects D. Signal/Noise Ratio (1) Definition (2) Relationship to eddy current testing (3) Relationship to flux leakage testing (4) Methods of improving singal/noise ratio E. Selection of Test Frequency (1) Relationship of frequency to type of test (2) Considerations affecting choice of test

{a) Signal/noise ratio (b) Phase discrimination (c) Response speed (d) Skin effect F. Selection of Method of Magnetization for Flux Leakage Testing (1) Magnetization characteristics for various magnetic materials (2) Magnetization by means of electric fields (a) Circular field (b) Longitudinal field (c) Value of flux density (3) Magnetization by means of permanent magnets (a) Permanent magnet relationship and theory *

(b) Permanent magnet materials (c) Permanent magnetic design relationship (4) Selection of proper magnetization methods G. Coupling (1) "Fill-factor" in through-coil inspection (2) "Lift-off" and compensation in probe coil inspection (3) Flux leakage "fill factor" in flux leakage testing (4) "Lift off" in flux leakage testing 2-5 Page 4 Jan 15/90

(ata) ~PECIFICATION NO. 105 H. Field Strength and its Selection (1) Permeability changes (2) Saturation (3) Effect of a-c field strength on eddy current testing (4) Effect of field strength in flux leakage testing I. Field Orientation for Flux Leakage Testing (1) Circular field (2) Longitudinal field J. Instrument Design Consideration (1) Amplification (2) Phase detection (3) Differential of filtering

  • K. Applications (1) Flaw detection (a) Eddy current (b) Flux leakage (2) Sorting for properties related to conductivity (a) Eddy current (3) Sorting for properties related to permeability (a) Eddy current (b) Flux leakage (4) Thickness evaluation (a) Eddy current (5) Measurement of magnetic characteristic values (a) Eddy current (b) Flux leakage L. User Standards and Operating Procedures (1) Explanation of standards and specifications used in electromagnetic testing (2) Explanation of operating procedures used in electromagnetic testing TOTAL MINIMUM HOURS 16 2-5 Page 5

.Jan 15/90

37

~ ffl3 -1 P4 :%-s TECHNOLOGY , IN ~.- - -

35 Flagship Drive 31 January 1990 -~cR£1AR fi40rth Andover, MA 01845 OfF!~f;T~G';)i sr:iNICfelephone 508-683-5211 DOC L °£.~RANCH Telefax 508-683-9469 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20 555

Dear Sir,

This letter is in response to your notice of proposed rule making on ASNT Certification of Industrial Radiographers published in the Federal Register of 9 November 1989 (54 FR 47089 ).

From the public record, it is quite clear that the US Nuclear Regulatory Commission is concerned about the safety record of the industrial radiography industry. In a Notice published in the Federal Register on 10 January 1990 (55 FR 843), it states that the NRC has been concerned about the number of radiation overexposures among radiographers for several years. As stated in the supplementary information presented with this current proposed rule, the US Nuclear Regulatory Commission is determined to make every effort to improve the radiation safety record in industrial radiography. I applaud your efforts in this direction. However, I believe that the proposal presented is contrary to that objective.

Under the present regulations, a licensee must submit to the NRC a description of its training program, including a detailed description of the topics to be covered, the qualifications of the instructors and the means to be used to determine the radiographer's knowledge and competence. The NRC has the opportunity to make a judgement of the adequacy of the proposed training program and to require the changes necessary to meet its criteria.

Subsequently, through the inspection program, the NRC has the opportunity to review the implementation of this training program for adequacy and to require any changes deemed necessary. This proposed rule removes the training and qualification of radiographers from NRC oversight and places it completely in the hands of the industry being regulated. (The proposal is so bold as to state that this removal of NRC oversight will result in a cost savings to the industryl) Whereas the NRC is determined to make every effort to improve the radiation safety record in industrial radiography, and whereas the NRC is not presently satisfied with the safety performance of the radiography industry, it is quite difficult to understand the logic behind the proposal to give up its direct oversight of such a vital aspect as training and relinquish it to self-regulation by the industry.

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A Company of the Sauerwein Group I~I------

The problem is further exacerbated by the details of the proposal. The plan is to recognize the certification program of the American Society for Nondestructive Testing (ASNT). However, such a certification program does not, in reality, exist. Although a written program has been drafted, no person has been certified under this program. There is no assurance that such a certification program will be implemented in a manner meeting the objectives of the NRC. There is no NRC control over changes to the program after the rule making process. Furthermore, the ASNT has no history of commitment to radiation safety and has made no noted contributions to the radiation safety of the radiography industry. The purpose of the organization, as stated in its constitution, makes no reference to radiation safety.

One may argue that the proposed ASNT program is similar to the certification program already in use in the State of Te1as and conducted by the State of Texas Radiation Control Agency. However, administration of a program by a regulatory agency responsible for radiation safety is quite different to one administered by an industry organization. Prudence would dictate that, as a minimum, the NRC would monitor such a voluntary certification program for several years to assure its adequacy and measure its success in improving radiation safety before granting it recognition.

Granting total control over the qualification of radiographers to an untried and untested program administered by an organization new to radiation safety and controlled by the industry whose radiation safety record is unsatisfactory to the NRC is a serious mistake.

The published proposal is misleading. Although it clearly states that the NRC will recognize the ASNT certification program, it does not delineate this program, nor does it adequately describe the ramifications of the program.

The ASNT certification program places an extensive number of additional requirements on the radiographer above those presently required by the NRC, many of which have no bearing on radiation safety. The requirement that the radiographer comply with the ASNT certification program code of conduct is particularly onerous. This requires additional knowledge on the part of the radiographer, invokes additional governmental reporting requirements (presumably approved by OMB?) and places requirements on personnel conduct above any such requirements of the NRC. The application of sanctions, including revocation of certification, and thereby the right to participate in NRC licensed activities, rests with the industry, in the form of

RTS TECHNOLOGY, INC.11§11._____ _ _

A Company of the Sauerwein Group the ASNT certification committee. This committee is comprised of individuals who are involved in the radiography business. Under such a system, one can find himself being subjected to employment threatening decisions by his business competitors. One's certification, recertification and sanction can be decided by individuals who have a vested economic interest in the outcome. This hardly portends objective regulation.

Furthermore, the ASNT certification program requires the applicant to release the ASNT from any and all liabilities, claims, demands or causes of action whatsoever as a result of his certification. The individual is required to indemnify the ASNT and hold it harmless for any claims by third parties against ASNT as a result of their certification. The cost of such indemnification is not insignificant. However, it does not appear to have been included in the NRC assessment of the economic impact of this rule making. It is also not clear where the NRC receives the legal authority to require an individual to indemnify a private organization in order to participate in an NRC licensed activity.

The fact that these, and other, requirements related to the ASNT certification program were not appended to the published rule making is misleading.

Applying these requirements by reference, without subjecting them to the publication requirements of the rule making process seems less than forthright. However, since this has occurred, I request that you hold a public hearing on this rule making to provide a forum for a full airing of the ramifications of this proposal and to subject it to complete public scrutiny.

Many of the comments made above could be dismissed by the argument that the proposal presented is for voluntary certification by ASNT and that a radiography licensee has the opportunity to continue with the existing program. However, the NRC indicates in this proposal its consideration for making this a mandatory program in a subsequent rule making. This makes the existing proposal all the more onerous.

In May of 1982, the NRC issued an advance notice of proposed rule making on the topic of certification of industrial radiographers (47FR 19152 ). The NRC received a number of written comments on this notice. It also held a series of public meetings about this. The NRC finally withdrew this proposal in September of 1985 (50FR38011 ). In its notice of withdrawal of this rule making, the NRC stated "the Commission has concluded that there is no

RTS TECHNOLOGY, INc. Il;;l ~-----

A Company of the Sauerwein Group consensus that a certification program for radiographers would reduce the number of overexposures". Nothing is presented in this proposal to demonstrate why the NRC has completely reversed its earlier conclusion.

If the NRC now feels so strongly that a certification program is necessary, then it should conduct the program itself or have it conducted by another governmental regulatory agency. If a program were conducted by a governmental regulatory agency, such as the NRC or an agreement state radiation control program, then there would be no question as to the dedication of the program to radiation safety. The program would be conducted by experienced radiation safety professionals with no vested economic interest in the conduct of the program, and by individuals motivated toward improved industry safety.

I believe that NRC relinquishment of the oversight of radiographer training and qualification, this vital aspect of radiation safety, in favor of an untried and unproven program administered by an organization new to radiation safety and controlled by the regulated industry whose radiation safety record is unsatisfactory to the NRC is a grave mistake. I urge you to withdraw this proposal.

Sincerely,

.. DOCKET NUMBER

    • !)nPOSED RULE PR 3 7/r Tenneco Gas 5510 Sooth ,~t!/,./icci f?v Houston, Texas 77081USNRC

,J (713) 662-5300 "90 FEB -7 P3 :58 February 5, 1990 OFF!CE: OF SECRJTARX Secretary OOCKE i ING & St.t<V!Cf.

U.S. Nuclear Regulatory Commission BR .A.NUi Washington, DC 20555 Attn: Docketing and Service Branch Gentlemen, Tenneco Gas is one of the Nation's major transporters and sellers of natural gas.

Tenneco Gas, through its various systems, operates 16,796 miles of gas transmission pipelines serving the major population centers of the eastern half of the United States.

Tenneco Gas maintains its own internal industrial radiography program consisting of twelve radiographers and five radiographer assistants or trainees. Additionally, Tenneco Gas maintains eight radioactive materials licenses from the NRC and several Agreement States.

We have recently reviewed the NRC proposed amendments to 10 CFR Part 34 as published in the Federal Register Volume 54, Number 216. While we support and are in agreement with a strong nationally accepted program for certifying radiographers, we do not believe the ASNT program will accomplish this end. The following are our comments and recommendations concerning this issue:

Program Compatibil;ty In addition to being an NRC licensee, one of the several Agreement State radioactive material licenses we maintain is with the State of Texas.

Texas has already established a proven and successful certification program for radiographers wh;ch has requirements that are stricter than those in the proposed ASNT certification program. We understand that the pilot program within the State of Texas was partially funded by the NRC.

2. Potent;a1 Confl;ct Of Interest We believe that ASNT has very good intentions in offering to help the industry and regulatory agencies with the problem of radiation safety training and the certification of radiographers. We also believe they would have a serious conflict of interest since they represent those already established in the business, many of whom are involved in the training of those who are entering the business.

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r l 3. Unresolved Issues of Concern

a. Who will have the power to revoke certifications and for what reasons?
b. What sort of documentation will the radiographer be required to provide to document initial and/or annual radiation safety refresher training?
c. Will annual radiation safety refresher training courses also have to be certified, and if so by whom?
d. Would a radiographer who has already been certified under a more stringent Agreement State program really be required to be certified under a less stringent ASNT/NRC program? This would seem to be detrimental to the interest of radiographer safety.
e. Would NRC licensees which presently have approved radiographer training programs and no past history of any viol ations that have been attributable to insufficient or inadequate radiographer training really be required to submit to ASNT/NRC certification on a mandatory basis? What purposes would this serve?
f. Why does the ASNT proposal only provide for two areas of radiographer certification? It would be less expensive for the radiographers and licensees if consideration were given to offering three types of certifications (similar to the Texas program), such as:

1.) isotope 2.) x-ray 3.) combination isotope & x-ray These and similar issues must be adequately addressed before any requirement for national radiographer certification can be effective.

4. Recommendations:
a. The NRC should fully recognize the Texas program and establish a reciprocal agreement whereby certified radiographers of licensees from the State of Texas, or other approved and established compatible programs, would be recognized by the NRC and other Agreement States, similar to the reciprocal agreement presently established for radioactive material licenses. This would prevent the unnecessary costs and redundancies of having multiple radiographer certifications.
b. The NRC should consider modeling their proposed radiographer certification program around that of the State of Texas, and consider the utilization of the Conference of Radiation Control Program Directors or other similar groups, without potential conflicts of interest, as the third-party organizations to provide radiographer certification administrative services.
c. The NRC might consider authorizing more than one organization to act as a third-party certifying agency for the NRC . This would encourage competition and prevent one organization from establishing a monopoly on radiographer certification which would be detrimental to the industry.

\ d. The NRC should require that any third-party certification organization for the NRC should not be directly or indirectly involved in any type of radiation safety training which could result in a conflict of interest.

We do not believe the ASNT program will accomplish the NRC's stated goals and feel that it will create great expense and problems for the industry.

If you have any questions, please feel free to call me anytime at (713) 662 -5353.

/": David L. Culbertson Staff Quality Assurance Specialist and Radiation Safety Officer DLC/gc/90018QAS cc : S. L. Clowney G. H. Lemmer A. T. Richardson File

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(lotmerly Standard Awl (Delr,e,y by second (for Extra Large or any pacl<ape over 150 lbs.) 9 0 ~U::1PICK*UP Rere,edAI 1 0 Regular Slop l>us.-.essdayt) 70 HEAVYWEIGHT" 100 30 200 ,.,,, 50 Release 30 D fEi~~1r 80 £=GHT" 11 0 D*op Bo, FedEx

'--Sla=hon:::__1,,_S....:ig:,,na~t..:.ur_e:_ _ _ _ _ _ _ _ _ _ ___:

Date/T ,me tlleiw,ry commdmenl may ' Oeciared Value Lmt $100 be later 11 some areas "Callo!delM!ly-. 12 ,i::i:::,ELIVERY ,, """"" Emp. No

TERMS ANO CONDITIONS MULTIPLE PACKAGE SERVICE DEFINITIONS negotiable instruments, and other items hsted in our current Service Guide On this A,rh*II. wn our IC"' Fn<tP.ral ~xr, ... ...,.., ,....,, *' . ,, ..... ff yt!u send more than one pac'kage o~ this A,rblll, you may fill in the total employees and ag lhP er. ,ts employees ~lared l/,llue fotall package~! to 81lceed the $100, $500 or $25,000 and agents per package lrna described abOve. (Example:!> paci(ages can ha'18a total AGREEMENT TO TERMS declared val\111 Qf up to $125.000.) _. .* L;

  • By giv,ng us you I< 11 theterms on this If more than on11 package IS Shipped on this &irll!II, our hab11!ty f0r10SSl;i< '*

A,rbJII and ,n our CL . , , ,lable on request If damage will be limited to the actual value ol 1he J)aekage{s) I09I or there Is a r,onfl,ct ootw,,,m the Ctlll'f!r)I Sefllice Gu1dA and this Awbtll. the damaged (not to exceed the lesser of the total declared value or the per.

- * - * * * "to al modify the term

  • package limrts described above). You have the responsibility of proving the actual loss or damage RESPONSIIILITYFOR PACKAGING ANO COMPLETING AIRBILL FILING A tLAIM ALL CLAIMS MUST BE MADE BY YOU IN WAITING:You must nofity us

.,, " td of your clairr w,tt]in stnct time limrts. See current Service Guide.

wrnght ~er M~ftom this A111)ill will resull n a billing based on our best We'll consfcleryourctaim filed rt you call andnotifyourCu-Seivice estimate of the-numt f'r Of pad<ades t..:ice1ved ram vou and an estimated Department at 800-238-5355 and notify us in wrrting as soon as oefaulf' ,sted by possible.

us W1th1n 90 days after you notify us of your claim. you must send us all, AIR TRANSPORTATION TAX INCLUDED relevant information about it We are not obligated to act on any claim until IF YOU ARE Ourt,= ,eC'Alde you have paid all transportation charges, and you may not deduct the Sect,on42l 0 amount of your claim from those charges.

MAKING AN MPS If the recipieQt accepts your package without noting any damage on the LIMITATIONS ON OUR LIABILITY delivery record, we will assume that the package was delivered in good SHIPMENT, APPLY ANO LIABILITIES NOT ASSUMED Our I1ab1lity for"" t, you, pac, ag limited , your actual condition In order for us to process your claim. you must, to the extent possible, make the original shipping cartons and packing available for THE SELF ADHESIVE damages or $100. ,e 1s yo, higher authorized vatu We do not.p,ovlCle ca,go* ,all!bty nsuranco. but Id declare a inspection.

RIGHT TO INSPECT you may pay an ~ItIonal. charge Jru, <l;l<,h_,a4l.di!1()1\a1)\00 o1 ~e<t MPS COPY HERE value If you declare a l\,gher \13~ !llld'.,!111.v.:IM ad~1tio&,1 rjj'rge'.'Wr

.We 'lliY, at OUf opJ1Q(l, OJ)!!II an~ ,nseect Y0!Jr-pac~ges prior to or after 9ou give them to us lei (!enver ' .. ** * '

  • liability will be-the leaser ,,t,yourdeclarAd value or tl'W aolual value-of:yoor package NO C.O.D. SERVICES In ~ny event wP will not be liable for any damag,*s. v.+iether direct. We dOn't provide C.0.D. services.

inndental. special or , onsequent,al ,n excess of the neclatoo value of a RESPONSIBILITY FOR PAYMENT shipment, whetheI o rot I ederal Expres.s had knowledge that such Even rt you g,ve us different payment instructions, you will always be damages might b<J Ir urrr,<1 ncludIng. but not liMi!ed to loss of income 0

primarily* responsible for all del,very costs. as well as any costs we may or profils incur ,n either return,ng yo~r package to you or warehousing ~ pending We won *1 be liablP. for your acts or om,ss,ons, ,nclud1ng but not limited Jo d1sposit1on improper or 1nsufflc1P.nt par.king. securing, marking or addrnssing, or for (IUAUFIEO ACCEPTANCE tho acts or omissions of thn recipient or anyone else with an.,nterest ,n the package. Also. we won't be haIlle JI you or the recipocmt vtOlales any of the we reserve the nght to re)8CI a shipment at any time, when such shipment would be likely 101cause damage or delay to other shipmE!nfs, terms of our agreement Wn won't be liable f0< loss of or damage to equipAient or personnel. or ~ the transportation of which is prohibited by shrpments of cash, currer,cy or other proh1b1ted rtems law or rs in v,olation of a, ,y rules contained in !hrs A1rbill or our Service We won't ,pe liable for IOss. damage or delay caused by events we Guide.

cannot control. 1nclud1ng but not limited to acts of God. penis of the air, weather condi~ons r, echa111ca1 delays. acts of public enem10S. war.

MONEY-BACK GUARANTEE stnkes.avrlco.

  • hhreuthorrttes(1;iclud In the event of untimely dehvefy, Federal Express will at your request

,ng customs and quaran!l~o ,c, with ,arent authonty. and with some l1m1tations. refund or credit all transportation charges. See current SP.rvice Guide for further information.

DECLARED VALUE LIMITS FedEx Pak shipments is $100: For other sh,* . the highest declared value we allow is $25,000 unless your pa nta,ns ,terns of

  • extraordinary value," in which case the highest d alue we allow ,s $500. Items of Part #119501 "extraordinary value:* include artworl<. elry. furs. money precious metals. Rev,B/89

Tenneco Gas 5510 South Rice Avenue Houston, Texas 77081

MOS Inspection, Inc. I Corporate Office I FAX # 708 981-9396 I 800 638-5227

~ FEB -6 PS :18 February 2, 1990 OFF ICE: OF SECRETARY OOCKEi lNG & SEilVICL Secretary BRA NCI-\

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch RE: ASNT Certification of Industrial Radiographers

Dear Sir:

I have been in the NDT business for 34 years with one company and am Executive Vice President of MOS Inspection, Inc. During this time, we have grown from zero radiographers to approximately 300. We have always had an execllent safety program with good control and management has always had great concern for operating safely. This has been very expensive but has kept us out of trouble.

I totally disagree with those who say lack of training is the cause of over exposures. I believe you wil find the greatest cause to be the radiographer not following procedures, or equipment problems. You can give an indi-vidual all the training in the world but if he doesn't follow the procedures, it is of little value.

Everybody is using the State of Texas program as an example of success.

Up until the time they started this program, Texas was the most unsafe state in the union to do isotope radiography followed by Louisiana. Any changes made by Texas would have to show improvement but the program has not been in operation long enough to claim it is a success story. They are still having incidents.

I have been opposed to Central Certification since the start but I am very much in favor of doing something to improve the industry's safety record.

Some recommendations are:

1. Make it more difficult to get an N RC License.
2. More unscheduled audits by the N RC.

liA 5 r ti

    • nowfed9ad bf C8ltl.:.; ,

us...ti 2 Buffalo . Chicago . Cincinnati *Cleveland

  • Denver
  • Detroit
  • Hartford
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  • Indianapolis
  • Jacksonville
  • Los Angeles
  • Memphis
  • Milwaukee. Minneapolis* Norfolk* Philadelphia* Phoenix* Pittsburgh* Portland *St.Louis *(Corporate Office) Chicago--(800) N DT-LABS

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Page Two U.S. Nuclear Regulatory Commission

3. More enforcement. If somebody is deliberately working unsafely, he should not be doing radiography. We can get rid of the bad actors if you make it a requirement that all incidents be reported along with the name of the individual involved. You keep his record, if he has another incident you may want to ban him from doing any further radiography. Advise the industry of this and the individual - he would be out of the business.
4. Make it mandatory that two man crews be used.
s. There are companies in the business who have broken every law in the book where management was aware of what was going on. They were not spending the money to run a safe operation. They are still going

- this should not be, it is unfair to those who run safe operations, U.S.

Testing is an example.

6. Get somebody in this section of N RC who has been in the field and knows what he is up against, not a retired mi litary man going for a second retirement.

You are the enforcement agency. Nobody else can do your job for you.

We wi ll do our job and if you do yours, we will have a safe industry.

Very truly yours, MOS INSPECTION, IN C.

<?~Q_~

Ronald C. Faloon Executive Vice President RCF/vg

DOCKET NUMBER JROPOSED RULE PR .~' t-l sr- fR tf70~q_) OOCKETEO USNRC Secretary January 29, 1990 '90 FEB -6 PS :18 U.S. Nuclear Regulatory Commission Washington,DC 20555 OfFICr- Of SECR TARX i)OCKEi ING & Sti{VICf.

Attention: Docketing and Service Branch BRANCl-i

Reference:

10 CFR Part 34 RIN 3150-AD35 ASNT Certification of Industrial Radiographers

Dear Sir,

These comments are submitted to the commission for consideration

..APrior to the passage of the amendment concerning 10 CFR Part 34

, . .. Licenses for Radiographic Operations". It is so noted that this amendment is only intended for those applicants that wish not to submit an initial training program and have their Industrial Radiography Radiation Safety Personnel trained and certified by the ASNT, Inc.

Certification Program for Industrial Radiography Radiation Safety Personnel National Radiographer Radiation Safety Program I am in favor of a standardized radiation safety program. This in itself will save the applicants money and time when submitting a request for license. A pre approved program will also save the NRC money and should reduce the cost of the license. An NRC approved

  • packaged program at a reasonable price that can be administered by

. _ the licensee is the first step to a National Radiographers Certification.

Standardization of Emergency Oper ating Procedures It only follows that this is the logical step that needs to be taken for a National Standardized Emergency Operating Procedure. The money and the manhours that have been spent by applicants preparing and submitting these procedures to the NRC mustd be in the millions of dollars. The ti rftl money it took fort F NR to review thousands of programs woul g ~atly be reduced. ' -h procedure would free up the resources to better monitor the raa'l.ogr pher and licensees.

Page One of Thre AR S 199CJ

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Secretary,U.S.Nuclear Regulatory Commission Page Two of Three January 29,1990 Concerns: Responsibility and Liability

a. The NRC has approved the ASNT program. This mean the NRC accepts full responsibility for the adequacy of the program.

Currently Part I of the program sells for $1100.

The ASNT Catalog says there are 4 parts to the Program, however, there is no mention of the cost of Parts 2 through 4.

I have estimated the cost of ASNT training and Certifying an individual, including loss of income, expenses and benefits to be

$2500. This would put the cost to the industry around thirty million dollars.

b. The ASNT program does not have to be followed if the Licensee has an approved program. Will the option to use the licensee ' s program remain an option? Is the NRC going to allow applicants to continue to submit their own programs for initial training?
c. Third party Certification Agency is going to have the responsibility of testing and certifying the individuals. Yet there is no liability because it is still the licensee who is responsible for actions of the individual. The individual is still protected from the rath of the NRC and now certified by nationally recognized organization. The certifying agency should be responsible to keep accurate records on individuals that are later found to lack the ability to safely perform as radiographers. The individual employers are at the mercy of the courts if they dare give a derogatory report on a past employee.
d. The individual radiographer should be made liable for his/her actions. There should be penalties for violating safety procedures such as the removal of certification, temporary or permanent plus additional documented training and retesting before a certification is issued.
e. Those states tqat have mandated two person radiography teams have less safety. violations than those that allow a single radiographer to operate a source. There are many stories in the industry about what single person has done to get the job done just to save a buck. Those licensees that use one person to go out into the field are taken alot of chances.

\

Secretary , U.S. Nuclear Regulatory Commission Page Three of Three J a nuary 29,1990 Mandatory Third Party Certification I like the idea of third party certification if it could be done loca l ly with a minimum of travel expense. Bonded, qualified agent s of t he ASNT could be made available in each ASNT Section around the country to admin ister the exam in a timely fashion. This would also give licensees a more convenient way to certify new employees that meet the necessary requirements without having to schedule time in Ohio .

~~~ .... ~

- Thomas Jof f e MQS Inspection,Inc.

230 Murphy Road Hartford, CT . 06114

MOS Inspection, Inc. I Corporate Office I 2301 Arthur Avenue I Elk Grove Village, IL 60007 I 708 981-877~

FAX# 708 981-9396 I 800 638-s220 0CKET NUM~£R @_;

{J!i-~~ R~~o~3tf oiet.~'le

  • 90 FEB -6 PS :20 February 2, 1990 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch

Dear Sir:

I have been a member of the IRRS Committee since its inception, and I am the president of possibly the largest licensee in both non-agreement and agreement states combined. These functions have deeply involved in the issue of Central Certification.

Your promotion of the certification program in the State of Texas which is now considered to be the goal of al I regulatory agencies is a major concern to me. The reciprocity that is granted under the Texas Certification program is next to nothing. This type program, if enacted in all 29 agreement states will impact the viability of our company.

Therefore, my support for Central Certification is truly forced, that is, if the regulatory agencies each have their own program with no reciprocity whatsoever, national firms such as ours would suffer.

Therefore, I would support Central Certification as the only viable alternative as opposed to 29 agreement states certifying personnel.

Philosophically, I do not agree with the certification of radiographers either by regulatory agencies nor by a central agency. The mere fact that an individual is capable of passing a test does not make him a safety minded person. Next, I quote from your publication (NU REG /-

B R0032, Volume 5, No. 38 - Week Ending September 24, 1985) Para-graph 7 - "After further consideration of this matter and a review of the public comments received on the matter, the Commission has concluded that there is no consensus that such a program would reduce the number of overexposures to radiation resulting from radiography activities and that it would be time-consuming and expensive to imple-ment." What has changed in our industry? It is my belief that our industry's safety record has improved.

Buffalo . Chicago . Cincinnati *Cleveland

  • Denver
  • Detroit
  • Hartford
  • Houston
  • Indianapolis
  • Jacksonville
  • Los Angeles
  • Memphis
  • Milwaukee* Minneapolis *Norfolk *Philadelphia* Phoenix *Pittsburgh *Portland* St. Louis *(Corporate Office) Chicago-(800) N DHABS I

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Page Two U.S. Nuclear Regulatory Commission Secondly, statistics that have been published after Canada's Central Certification actually shows that the number of incidents increased rather than decreased. Thirdly, details regarding the downward trend in exposures in Texas since radiographers began preparing for tests is extremely misleading. This downward trend resulted mostly from a downturn in the economy of Texas and not safer radiographers.

The cost of $1,000 per radiographer will have a tremendous impact not only on small licensees but also on the large ones. You are dealing with an industry which is extremely cost and price sensitive. People sell radiographers anywhere from $15 to $30 per hour. Consider the fact that you pay your automobile mechanic and plumber $45.00 per hour, our billing rates are extremely low. The licensee who now adheres to good radiation safety practices i.e., training their people, auditing, providing proper equipment will now be impacted by an additional charge on top of what they already spend. MOS which has 300 radio-graphers plus an additional 100 x-ray technicians is spending approxi-mately 12% of our operating income on its radiation safety program.

The impact that certificat ion would have on the profitability of our company as well as many others would be a disaster. Yet, the big questions is will safety really improve? I do not believe so!

This will also drastically impact the supply of skilled radiographers available to the American industry. Many employers will say, we will not spend this money, we will only hire a certified individual or pirate same from other companies. This will put the pressure on individuals to certify themselves. Other occupations will be more attractive to some of the better people. In my opinion, there were many vested interests in pushing Central Certification under the guise of improved safety. I am not sure that some personnel of the unions, NRC and ASNT truly believe that safety would improve but rather had other motives.

At the last meeting, before the Commission representatives from the NRC and ASNT were present. I feel that expanded representation by the radiographic industry at that hearing would have better served the Commission.

Safety is a state of mind, a philosophy. If top management in an organ-ization does not exhibit and live safety, the technicians that work for them will not either. We as management must show the lead.

The regulatory agencies must expand their enforcement activities.

The ASNT survey of persons showed that the industry believes that increased enforcement would be the major thrust in improving safety.

Page Three U.S. Nuclear Regulatory Commission I would like to put forward some suggestions for your consideration in lieu of Central Certification.

a. random drug testing of all personnel involved in the radiographic industry.
b. mandated requirements for two man crews.
c. regulatory listing of all persons involved in violations of severity Level I.

I appreciate that you have given me the opportunity to voice my opinions in regard to Central Certification. I am committed to improv-ing safety for our employees and the general public but do not consider Central Certification as the means to achieve that. The cost will be far too great for to little return.

Very truly yours, MOS INSPECTION, INC.

i':1-ot.~

President HVD/vg

DOCKET NUMBER CHERNE P,ROPOSED RULE SINCE 1916

(.5'-/ Fie. ~Z~{fo9 U5NRC C HE RNE CONTRACTING COR PORATION POST OFFICE BOX 97S

'90 FEB -6 p ~ ~Q ;P HONE 612-944-2650 MINNEAPOLIS* MINNESOTA 55440 TWX 910-576-2788 ui:-FtC!:. OF SECRJ.TAR"'.

').0CK[11 NG & Sr. t<Vlf.f.

' BRANCH January 29 , 1990 Secretary U. S. Nuclear Regulatory Commission Docketing and Service Branch 2120 L Street NW {Lower Level)

Washington, D.C. 20555

Reference:

INDUSTRIAL RADIOGRAPHER CERTIFICATION PROPOSED RULEMAKING Gentlemen:

Cherne Contracting Corporation supports the proposed rule changes to 10CFR Part 34 regarding recognition of ASNT Certification of radiographers as an alter-native to the training and qualification activities as is currently required.

Third party certification of radiographers has the potential to significantly improve safety awareness and performance in the radiography industry. This pro-posed rulemaking will provide the radiography industry , users of radiography ser-vices, and the NRC the opportunity to more accurately define the costs and benefits of third party certification towards radiation safety performance. The NRC initiative to provide this option to the industry is commendable.

Cherne Contracting Corporation is a national construction firm, performs radiography under a NRC license, and is also a user that subcontracts radiography to independent testing firms on many projects. We expend signifi-cant resources to ensure that our radiographers, and those of our subcontrac-tors, are properly trained, understand their duties, and are motivated to perform their safety duties in the manner prescribed. We believe that this expenditure of resources has contributed to our record of no radiation inciden-ces in the 10 years that we have had a license.

We are of the opinion that third party certificati on will provide a higher level of assurance that radiographers seeking employment with us, or working for our subcontractors, have received the required training and , mo re importantly, understand the basic radiation safety principles and importance of individual conduct . In addition, the ASNT Certification will provide a level of assurance that the radiogaphers will subscribe to the company values for personal conduct and individual ethics.

The cost impact, as estimated and presented in the proposed rulemaking , appears to be excessive in view of the current status and direction of the ASNT program.

Should ASNT be able to utilize its volunteer members as examination monitors 5 1990 REC'D CORPORATE OF'F'ICE-9855 WEST 78TH STREET-MINNEAPOLIS,,Ml~NESOTA 5?5344 FEB 2 J9.90

U. $ . NUCLEAR REGULATORY COMMISSION DOCK f.T ~8 & SERVICE BR1,NC H O~h ~ F THE SECRETARY 0~ TH- COM1v1ISSl0 1~

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CHERNE CONTRACTING CORPORATION U.S. Nuclear Regulatory Commission January 29, 1990 Page Two and conduct the examinations at its local sections, the costs for administra-tion, travel, and lodging could be significantly less than that stated.

Accordingly, we believe that a cost analysis of the certification program is premature at this time and that this proposed rulemaking, if accepted, will allow for an accurate assessment of the costs should a future rulemaking requiring third party certification be forthcoming.

A study of cost impacts should address the costs to the users of radiography services. After all, they are the organizations who will eventually pay the identifiable certification costs of the licensees and they also bear costs as a result of radiation incidents. In addition the direct and indirect costs to both the licensee and the user associated with a radiation incident (including but limited to lost production, insurance, and loss of image} should be con-sidered. The costs of a radiation incident borne by a user of radiography ser-vices are probably as severe, if not more severe, than the costs experienced by the licensee.

Should the proposed rulemaking pass the public comment, Cherne Contracting Corporation will encourage its radiographers to obtain the ASNT Certification and will encourage our radiography subcontractors to do the same for their radiographer employees.

Sincerely, ORPORATION ety and Quality

P,ROPOSED"iiUL{ r11. 3 tJ D ~

~ 01F~L./7oz-9 ~

~""';' COCKETEO USNRC CONTINENTAL AIRLINES "90 FEB -6 p 4 :02 RESERVATIONS PHONE 398-3000 STAPLETON INTERNATIONAL AIRPORT DENVER, COLORADO 80207 OFF!CE OF SECRETARY OOCKET I G \ Sfi,Vl(T JanLtary 30.. 1990

,RM!Cl-1 NLtclear RegLtlatory Commission Attention
Docketing and Service Branch Washington, DC 20555

Dear Sir,

The comments to follow are directed to the proposed rLtle changes of the

_ N.R.C., 10 CFR Part 34, ASNT Certification of Industrial Radiographers.

These rule changes were published in the Federal Register, Vol. 54, No.

216, Thursday, November 9, 1989. Pages 47089 thru 47091.

Continental Airlines is opposed to these proposed Rules changes for the following reasons.

The personnel that are qualified to be radiographers have been in our inspection department working as inspectors. They carry an Aircraft and Power Plant license issued by the F.A.A.

Third party certification is not needed at Continental . We have in place a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> radiation safety course. All inspection personnel who are scheduled to work as assistant radiographers, are given this course before they are allowed to begin work.

A on the job training, of a sLtfficient time period to qLtalify them, is W received before their names are submitted to the appropriate licensing agency, as a radiographer.

The proposed rule makes 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of on the job training mandatory prior to qualifing as a radiographer. This is an excessive amount of time for for the personnel that we use for this work. We are able in all cases, to qualify these personnel on the safe handling and operati on of the equipment in 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> .

Attached to this letter as back up for the above statment, are film badge reports from our Denver, Houston, and Los Angles maintenance bases. They will confirm the low radiation doses being received by our radiographers.

Tests to assure the personnel are qualified to become radiographers are in place. '

In our program, requalification is required if an individual does not work as a radiographer for 1 year or an individual shows on the quarterly review that he /she is not working in compliance with the applicable fe~eral or state regulations. AR 1990 I ac fa 1,J

IA. &. NUCLEAf-<

DOCKET 1N OFFIC E. '-'

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The expense of recertifying 40 radiographers by a third party is considerable. It is not just the cost of the test. The cost of lost time on the job is considerable . At Continental~ These personnel perform many other N.D.T. functions . Their absence from their assigned work area increases our costs by either adding personnel to the work force or working personnel overtime to cover in their absence Continental Airlines takes the position that the proposed rule should be rejected.

- Sincerely yours,

~~

Richard L. Rohrig Manager~

Non-Destructive Testing

ACCOUNT NO PIIOCESS NO wr ~ ~-WE PAGE II()

CONTIN!::NTAL AIRLINES 86435 Q270 2 1:11~0 12~9:89 8 1 ATT~ RICHAKD ROHRIG DENVER INSPECTION 8250 EAST SMITH ROAD Accredited by the 0 DENVER CO 80207 National Bureau of Standards through~

Tech/Ops Landauer, Inc.

RADIATION DOSIMETRY REPORT 2 Science Road, Glenwood, llllno1s 60425-1586 (312) 755-7000 After November 11, 1!?89 use area code (708) 1 PR 4294 - 54324 CUMULATIVE TOTALS (MILLIREMS)

., UIIUlEll NUMBER l!ICEl'HlM DATE OF f- BIRTH PARTICIPANT SOCIAL ffi PART OF 1'8\MISillllE DATE BADGE REPORTS PEBll!lr MOO IO NAME SECURITY :I:

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NUMBER  :, 111 IW RElilJ TO 3ct DATE OTR MO YR

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800638 5227

- 3 J l PROPOSED RULE _ T ~

Formerly MAGNAFLUX Quality Services

  • su FEB -6 A9 :39 January 30, 1990 OFF!C!: OF SECRE TARY OOCKEiiNG & SEilVICF BRANG~

Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch

Subject:

10 CFR Part 34 ASNT Certification of Industrial Radiographers Gentlemen:

The proposal to use ASNT as the "certifying agency" may serve to somewhat standardize radiographer certification. However, unless all Agreement States accept ASNT as the certifying agency, standardization will be lost. Licenses operating at multiple locations will be subject to greater cost as they pay each Agreement State accepted agency and ASNT to certify each radiographer. This additional cost will be without the benefit of improved safety. The scenario is likely since the Agreement States have not yet committed (and a fe w are opposed) to using ASNT as the certifying agency.

The effectiveness of the radiographer certification program will remain a licensee implementation and regulatory enforcement issue. Title 10 CFR Part 34 and license conditions currently require radiographer training. It is obvious some of the licenses that have utilized unqualified radiographers had little concern for regulatory compliance and the safety of personnel. This new proposed regulation certainly will not change their attitude.

Very truly yours, MQS Inspection, Inc.

~~~r Corporate Radiation Safety Officer ELB/deh Enclosure CC: E. Banfield File MAR 5 1990 AcknowfedQlld ht clMI~::: 0 .,. al, $ a z a Buffalo* Chicago

  • Cincinnati
  • Cleveland
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  • Los Angeles* Memphis
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AmericanAirlines MAINTENANCE & ENGINEERING CENTER OOCKETEO DOCKET NUMBER ~ 3, 1 USNRC PROPOSED RUL£_.;,.*-~A fl-ll ~T.._.., 1 (St/-F/C_ 1029 "90 FEB --5 p ~

1/15/90 SECRETARY, U.S. NUCLEAR REGULATORY COMMISSION ATTN: Docketing and Service Branch Washington, DC 20555

Subject:

Certi£ication 0£ Industrial Radiographers, 10 CFR Part 34 Contingent upon an analysis a£ the costs and bene£its a£ third -

party certi£ication and demonstrated success 0£ the American Society £or Nondestructive Testing (ASNT) Certi£ication program, the Nuclear Regulatory Commission <NRC> is considering the initiation 0£ a subsequent rule making which would require third-party certi£ication 0£ all radiographers. Under the proposed certi£ication program, the ASNT will purchase the exam £ram the Texas Bureau 0£ Radiation Control (TBRC>. In the next £ew paragraphs I will summarize the cost and problems associated with this proposed program, and alternatives to third-party certi£ication.

1. Cost/problems associated with proposed program The ASNT has said the total cost 0£ certi£ication will be bout $1000 per individual. Initial plans by the ASNT, call

£or the test to be conducted in Columbus, Ohio by personnel 0£ ASNT headquarters on a once per month basis £or ten months during each year. Companies such as American U) Airlines promote £ram within, mechanics to inspectors.

CD A£ter spending considerable time and money to quali£y an inspector, by contract, he is £ree to bid £or another job C within the company. American Airlines presently has 15 radiographers that meet the requirements £or isotope radiography. emaer *the proposed ASNT Certi£ication program, X-ray (machines> will come under the same requirements as isotopes. This will require certi£ication 0£ 67 additional inspectors. The requirement 0£ documented 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> 0£ on -

job-training (OJT) £or x-ray and 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> £or isotope radiography, will make it time consuming and more expensive to quali£y radiographers. American Airlines uses the same inspector £or both X-ray and Isotope radiography. At £ield stations where x-ray or isotope radiographic inspections are not required on a daily basis, it will become impossible to quali£y an inspector in a reasonable time period.

Also questionable is the process by which an inspector is

~~ R~ 1~0 1 ~ bicaM:::; ..;;;;i".;;;;;r;:,;:a::.-.-...

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certi£ied. The steps required to certi£y an individual are as £ollows:

a. Submit application plus required £ees £or each individ-ual to the ASNT.
b. ASNT will review the quali£ications and pass the request on to the CRCPD. 1
c. The CRCPD will provide the Texas exam to a proctor.

The proctor may be an employee 0£ the state health department or a quali£ied ASNT member, depending upon that states program.

d. A£ter completion 0£ the examination, the proctor will send the test to Texas £or grading. The Texas Department 0£ Radiation Control will noti£y the ASNT the results 0£ the test.
e. The ASNT will then noti£y the individual the results 0£ the test. I£ the individual passed, he will be provided a certi£icate. At present, the proposed certi£icate will be good £or a period 0£ £ive (5) years, but Quality Services International (QSI>* has suggested reducing it to three (3) years.

Under the ASNT proposed program, a candidate £or renewal must document continued active permanent employment in radiography £or at least 24 0£ the last 36 months. In addition, the renewal candidate must document at least eight (8) hours 0£ annual £ormal classroom training on radiation sa£ety topics, including new sa£ety regulations or requirements. I£ these renewal criteria are not met, the candidate would be required to repeat the examination process. These requirement greatly exceed the current regulations. In addition to taking the examination, the individual must sign a statement agreeing to the Rules 0£ Conduct and ASNT's right to revoke their certi£icate. The individual must attest that the application is true and correct. And he must agree not to hold ASNT responsible (Hold harmless agreement> £or any £uture actions connected with their certi£icate.

A program such as the one being proposed may be acceptable 1 The Con£erence 0£ Radiation Control Directors is a non-pro£it organi2ation that will broker the Texas examination.

  • Quality Services International, contracted with ASNT to develop a business plan £or the National Certi£ication Program

£or Industrial Radiographers.

2

£or some smaller NDT companies that £allow construction projects. They would like to hire radiographers a££ the street. Large corporations, such as American Airlines, will have increased training cost associated with promoting mechanics to inspectors (radiographers) £ram within the company.

2. Alternatives to third party certi£ication
a. Why change the present system? The majority a£ the licensees have a good radiography program. American Airlines has not had a serious violation in the 18 years that we have been licensed by the NRG. The NRG has the authority (GFR Title 10, Part 2) to prosecute an individual; no additional regulations are needed.

En£orcement 0£ the regulations uni£ormly to all licensees would be su££icient to minimize radiation exoosure to individuals. In the past, the NRG has chosen to hold the company responsible, not the individual. Now under the proposed certi£icati on program, they will expect the ASNT to revoke the certi£icate 0£ any individual £ound guilty £or certain violations.

b. A second alternative could be a Flexible Gerti£ication.

Under this method, the ASNT proposed certi£ication program would be optional. Small companies could hire only radiographers that have a current certi£icate, while large corporations might choose to remain the same as we are today.

c. A third alternative, would require the Radiation Sa£ety 0££icer to be a member 0£ management and be held more responsible £or compliance with the license. Many sa£ety o££icers lack proper authority to control t h e radiation sa£ety program within their company. This has previously been discussed with the NRG and Oklahoma Department a£ Health.

In summary, under the proposed program, the ASNT will receive the greatest bene£it through monetary gains. In the interest 0£ reducing the cost to ASNT, they are considering termination 0£ the contract with the TBRC and developing their own examination a£ter the initial start-up period.

This may not be acceptable with the Texas Bureau 0£ Radiation Control or other agreement states.

The small contract NDT shops will bene£it by not being required to have a training program, while the large corporations will be penalized by increased cost. The cos t to American Airlines £or certi£ication 0£ 82 ins pectors will be $82,000. Additional cost associated with renewal is 3

unknown.

Licensing of programs such as radiography must be regulated by a regulatory agency, not by a non-orofit organization with board members appointed by other board members. The cost of implementing a national certification program such as the one being proposed (estimated 12,000 radiographers at

$1000 each) will be $12 million. With renewal every 3 or 5 years, this will be big business for ASNT and very expensive for the NDT companies. It should be noted that with the additional requirement for certification of X-ray radiographers, the numbers will increase significantly.

Requiring 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> OJT for X-ray and 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> OJT for Isotope radiographers is excessive. The fact remains that it has never been shown that proper enforcement of the present regulations will not accomplish better results than the proposed program. The Texas certification program has not had sufficient time to prove that it will significantly reduce over exposures. Yes, the numbers of incidents are down, but due to the lack of new construction in the oil industry, the total number of radiographers is way down.

Delegating the enforcement authority to a non-pro£it organization that requires a Hold Harmless agreement, will create legal problems that may have unpredictable results.

Under the ASNT*s proposed fee structure, they propose reducing the cost of the examination for members by the cost of membership, thus providing an incentive to become a member. Finally, it doesn*t make sense to restructure a program that basically has worked well £or the majority of the licensees. If a certi£ication program is implemented, it should be controlled by a regulatory agency, not the ASNT. ac:::;,U A.A. Hale Vice President, Engineering cc: J.E. Martin C.H. Eads B.W. Nethercutt l!

VIOi 4

U. S, NUCLEAR REGULATORY COMMISSION DOCKETING & SERVICE BRANCH OFF ICE OF THE SECRETARY Of THE COMMISSION Docu r11 ent Statistics Postmark Date ~ / 1 Cc;ip1es Receive_d_+- , - ,- -------.

Add1 Co ~1es Repr oduced__,£./ ,__ _ _____

~pecial D1i.trlbution R:rb5 f? oe c Rt P.e-=,DR =-

o;_i+, --- -*- -

  • 12:08 ATA WASH 4TH FL NO.011 002 -

47089 Propoaad Rule* , ..... ...,.,.

Vol. 14, No. Z10 t111* ~ Of .,.. FED&AAL AS01STE~ &.OOIIQ*~ Mall writtvn ~nurumt* lo: The b!e;h 11ctlvity r,uilaac:.liva 1oi:r~*

t':l'll'lt.- ~ to tt\11 r"':llle "' tt\A s.er*ta"f, U.S. Nud-, R-e,al tot')' ulM i.n lft~O,tl'iAt ,11tlin!"IIJ'l~)t p~IUl 0,0pc,Nd INua,a of NIN Md eomm1.. 1oa. WHMneton. DC IO!H, HriO'IH MIQrd* lf r11diatian ad*ty ntOuitllOl'lt- ~ ~ o f Ntll notioH tt*t1ttn11: D,;ui'lt tl"I 11d s...,ir: llr*nch. proc.dUNI ate I\CJI adh~red tc, 11 to Oi\11 lll1AIHtld lltPSON II\ Deliver aammenta to: 2120 L Street. r:so-roualy. A algniflcanl fracliCl1 cl

~ I Y to ~ M In IN rulf NW. (Lc,wer Lev*ll, WHhinslan. DC. oec-.1'J'& tional c,ver1xpr,11uraz and 1eriou1 m11Ung prior to thl *~tion of tt'O final 1\1l81l.

he~Hn 7';30 ,m. and 4:11 p.m. Feder11: radiat:on injuries reported to the ~"RC Covtmmtnt workd1yt- and the St1h11 ha\*t ocC1.1rred In

=========:.--=~=====-

NUCLUA RCQULATOll't Ccple af c:lraft rP.platary analyai, and eammnl* nr:ived t:aay be

  • ir.c!c,trtel r11dlo9r11riliy nr111tAtlM&. !b!

.§t;te o!Toa. dettuffllnad that 41.

COMMIUION axamia*d ah tha .._"RC Public Docllfflen! ~N",...,t ~r II ll f'IVIIP,.tc nAUPII n IU'tad

  • koom at auo L Street. NW, (Lower t~111 11 f! In 1981 were altributa e to

,om PtrtM IA,vtl), Wa*hln!f<m. De. lncfo1trlal ra d\ogra hie O t 'i'!Je

,cul PUIITHal lNIIDIIIIATIOtl C:ONTACT: mm H on * ' fffl'llnl!l'd lo wnrk wi!l, RIN SI SO.&ml Alan K. llDcldein. Offim of Nuclear t;\f lietn1t** and tne State* to max.e Retwatary Aaean:h. U.S. Nudu every eficrt to improve the redietion AIN'T Gel"UflN1i9n et 1nauIV11t P.c-,,.ilatory Ccamm!Hlaa. Waabinglan, ufaty rt1cord in induatri11I r11diQBP11phy.

Aadk,lflphera DC 201H. t.l*pboat (301) fiM7fO. 'Mila mll'mA"lnA 111 r.oni*tanl with 1:uJ

.&HNi;:v: The Nuclear llesulatocy complement* other recant NRC action&

Cofflnliulo~ au.ch II the i,ropo1td radioaraph)'

Baaqr0UAd Qt\1ot 11rety rule and the prnioual,v IUMMAIIY: T'li1 Nw:lar Regu.lalol')' C\&ffltnt NRC Haled IQVe9 pub!t,bed quarterly p9rf'ol"'IJ'l nr,,1 Comm!uion ~ t i to amend It* rdiDsP11JJh1 licenaiea NlqWN!ll\r:!IIU {tD tr,,pect1on r*qvirem.-nl (t M .11(d)).

re11ulatlo111 at 10 CPR part M, "Ucan1ea CPR M.t1) epecilJ that aa applican~ will lnvutl111tln11 hy tnA NltC and for Rtdioaran_y and Radilticn Safety h*v* *" ad*qu*** P'Clf"'I"' fo, 1Pal11l"8 ~. . m*tlt S.t tu b1ve tntll~*t11,I tft11t R1quinm1nt1 for Rldiasraphic r dioarapbm and wiU 11.1bmil to fl."RC

  • lnaciequat* \1'Qinin1 i& ortan
  • malat Opuationa." to provide license schedule or deacription of the program r:or:trihutinR far.tor to radiography ap~:ic.u:'"l!t lhe c,pUon lo flrfil'nl lhu.t all ()f &ncll.ldtng intttal ttatnina. penodlc 11cciuc:n1.a. Prupo:tul, 11,,1 r1:91.1ire thlrd-their active radiograpben will be retraining. an-the-job training. and the puty certt fi"ca(ra'n of radl~ *yg:n hau r.P.rt1f1ed tn radlauon 1arety by lhe means to be uaed b)' the IIC;f!naee to 6,cfoi,e"*1mrcd h,r &Be CC __ Ad Amencan Societr for Nondaat:ructive dr.tr.m1ine tt,e tad1ograpber'1 knowl13d8" Uoca~loar&phy Stft@dDi Camm(ttec Te&ti~ tASSTJ prior to cornmencing Ol'ld undc:nhu:\dms of. and ability to and A.Sl'r.ln 1987. the Tua, f.lul'f!au of cu hes u radiographen, in lieu of r.omply "'1th, CommlNlon "'~llattnna Ra~ a:.wn e uul tl,)J Implemented a c:urnint llcensln! tl!qu.ir~mr.nl tu uLmil 1111d li1,;tm11in,:c ~~"i~ment,. *ncl th~ com;,rcb.cn&ive tc:iiting pn15ram lut tJC!s~r:pliuna of plannd initial radial.ion rad:ograpber1 u a m"11n, of improvinJI nfety trainins *nd qualification c:peratin9 nd emeraency procedures of the applicant. Section ~ .:n(al epecifiea a:\d vel'lfytng tratntn,f and radi11tion proced:ll'ea. Tba Cormniaaion believee conditions undtr which en lndtvldual \a HAlcty pr c:tit;n in the industry. To date.

that the ASST "'Certification Progra.m pernutted to *(:t rtt

  • radic,srapher. ln apprr.rxim11tdy 2.000 individual.a hllve for lnr.Jwstriiil Radiosraphy RadiAtio:1 addition. appendi>i. A or part 3e outhnes beer. fl'!!ih!tl tmrl is~ued industrial Sdety Pencmnel" provides an the radtat10n protection tntnlng rad10t(f"i1phy ID ~11tdl!I by that State.

QCceptabie method or enaW'Ull that 11adiogt:,~hM11 1,e adequately trained 1n req~mentt. Preliminary evalWttion of the The N~t: itt ~ropoiint to per,nu ~!fec.tlveneas of the Teu1 progrilm i, the radiation aafaty aubjecta listed in applicanta ta affirm. in lieu of aubmittins encouragins, There it *n ltsclicaUon of a.

appendix A of 10 CFR part 34. The intent ducnptiona of their i.aiti*l radiation downward trend in <>"Co'!re:11:.pasurea 1ince

,,r this Jll"Opoted rulem1king It to eafe:-y training ar,d radiOlfaphet Tt~H r,(ilosraphP.rt be9an preparing reco11nite tlut prorram and to encouragP. qualification program,, that all for the examination. hut the data are net indUAtrial radior-11phy litcnHn to lndivlduala permitted to won. aa y~l definitJve. lnapecton report purticipale In the ASNT program. Thia radiographers will be certified in obsirrving radiographers ltl.ldYiruz 11fety J>n.>fHJll!i.l rulll! al u aulicita C&Jatment on r&d.Jatlon aafety through the lnduatrial traJw..g documents and a attnera1 the ooa!s and beoeftt1 of third-party Radiography Radlatlon Safety Ptr&ollllel improvamant in fob site performance.

radiation safety certlflcat1on which wil l Program of the American Society £or The ASN'ra .. C,rtific41tion1 Pffll"'m be used by tbe CommJslian in its Nond11truct1va Taatins (AS.".&). Inc. for Industrial R~dig3r pby R*di*tigp conalderauon of a planned 1ubaequen1 prior to commencing duties u Safety Peraonnel" wa ppzovsd by ii.I rul~kins tbat W()\lld n=qun rad.iastaphet11. CoDli ta Board of Ditectura ln March of 1889, The rndiop-apher cert1flt.ation. .ana i alt pr°"'o1m. which would u.u & wdtlen DATK. Th~ puul.Lc (;Otlw1111ul perh:uJ 1htrd- an nomlnotfQ11 dr.vclnpr.d *ncl veallJated expire* Pebniary '* ttllft. ~uummt& demonstrate bv tne ~tate of texa1. nae been racetnd ah-.r tlala de le will be calion reviewed widely, NRC beadquartar1 and ccnlldend it tt a, pnctk.al to do 10, bu, RM,cional ltaff pruv!dad exttaliva the CammJnJoa t. ebll! to uaure au ~ Dl * ~ would comment on the prosram. The AINI' uun&dwall1111 uul~ tor ~1111'8 i;q uilnt-piu11 ~ Uun uf iill PRJF*m will ulte=r ca:rtdlcaatua fw bt,lh

,_lved OQ GI" belate thJ. date. ~ dlajra,&.-.. tscuop* *nd a..-.y ~Nf1J-. Applte.ttw for Cosf AAJd tJ'Al~.f; fr  ?

12:08 ATA WASH 4TH FL NO.011 003 -

  • c e .

t...-.i Repts I VoL M. No. 218 / Thunday, NnVl!mbar It 1818 / Pn>paeed Rule Gcrdfi~timt ~Uffl Joa.w~tiOft of optio11 to aMrm tkat aD hullvlcluala Th, Al.-tr 11dmatet lllatat mm17 at 40 bolU'I of GJtHrV9ffl ...... ,.. *atma ** radiav,aplaen will h. ee,tin.d t!Ul00 r ~s,h- cauld ht involved radla11011 ..-Cat) toplca 1pedli*d li1 1ft radi,Ho11 .. r~ tuouc)I Ille hld111fft*l In cutiflcat~ 1'111 total oa,t to the ASNT lbscludhla uioN *b)M:ta Duthn.d Rediglf"&Jlft)' bdiation S.tety hnonnel lndutu,, it **tirn*r*d to be ..., mUUon 1,1 *ppeadix A ol to CfR pert M), pro,ram of the Amarlc1n loclety for In 1CIID d0llar1 bued on 1 ~year dot1wntRl1\i9n of 630 lioun of clinvt NondHtructin TatiQf. Inc. prior ta period begird\1n8 l.n 1981, w11,-.cu. wtta nd!ognphr IIIIUl'C comm1u,clna dulin u radiQFaph,sa. Th* P."RC baline1 that velv.n&.ar,,

wMltr IN ~trvl 9'- NRC << Thl1 would ha l4 hw af th i:wnAt partidpatton m. the A8NT otl'tlflaa&r\

A,roelMflt 8'-I* Uoea.ee, UMl ,.oor ot ,eq11iNJMt1t lo, aubmittiJll l dtlt!l'lpdan pr~,-em ftu tha potentlal ta 1uc;Gc11llll compl*tlOft ol a pnatSeal DI tla.e applJcam*, WU.) tralniq and *isnllleetly impl'dve ufety IWINntll e,cazninaUoD oo ta!tt)' proc:eow.* tHt.ina P"'SN"' on radJatlon aalety and pr/onnane.,

admuuatereti l,y an i"9ti~llan 1ubieet* U11eu tn *Dendix A of to CFR rcoopiaM b1 Iha AL'ff. ASNT pan M. h ia aot th* lnCent of t>ua t..l'r~ ~ c.,.....

rico,mua 1overmntc1 or pm,1 ui rulemakin3 ro waiva tba traiAlna !XONiloll lro1t.lM\oN that art llcanaed by th N'RC ntqulremeuia Q\ltliMd In I :JU1. I M..31 'Mt11 NRC h.ae d*termlned th11! 1hi1 o* an Armnent &tale fr. the IIM t>f end appea.cwc. A ol 1.0 CJ."R put M. T\11 ~ r\>1:,l..1u0n u tlt type of action daacribed NdJo,rapliy IOW'CH. rvl laa wculd net clt1itnp Hlfl11hwment1 ,..

  • r-.Alf!ttnrical axclualon ift. '10 CR on approval of an appllc:1\1011 ,nr ror ra<boe,eplsu' ... ,,tants. Uld ~U2.(r.J(~l(I). Tllerefore. neilner itn flc:ation by AS~"T. a e41ndt~1te dHcriptil;uu er pmodic rettalftlq and *nvtronnu*nlcl lmpaot *h1lemer.l nDr 111
  • oc,raphcr wo"1c tbt11 be allsinl* ta tra!.ninf 111 opa.. tiq w eTK~...-nq, ..,,virnnmPl'lt&l a11e11ment hat Mlffl take th* State of T,x.. writt,m J)PODld\ll'H w1:11.Jd ccmtfnu* tn 1-. r11*11r*NW4 fM r. 11 proposed rule.

examination. The tJ1aminatJon would be required.

admlnlttered hy t!ie ASNT o* the P1,erwers JllMIMNI Act 8ta....-t Conference or Jladiatiao Control f\lhlffLJemaldag Pro1rum Du~h.)te (atCPDJ. Th~

ex.mhmUun ~"uni ta~tion protection llu* proposed Nie a.h,o '°"~

comm1:nta on the coata and benll!ftta ot 11t'W Thia pn,pu,e<l riile dol!I not eo11tatn 11 or em.e.od~d !l\fomaticm collection

""ituln-u~lt aubjctt to tne Paperwel'k principlt:1. retl,llatima, baaic tQ1;1pment 1hi.rd.party radiation aafoCJ c~tian Reduction Act of 1980 {44 U.S.C. 3501 el operation, nd radl1tlon H1fP.fy wh1d1 will be UHd b~ the Cclmmiaaion eq.). btsttn, rtqttirementa wste procedure, 1pp!icable la lnduttri.itl in ill con,idtlauon ol planned approved by the Of!\ce of Manap.ment ndiography. maddition. a e,.,ndJdAtP. aubaequeut ntlmaklq that wowJ and Bu*111pproval number 11-...otlO.

mutl sigr, an adcnowl.J8"mcnt lhat tie/ rP.qun r;ulli,arapher cen4lcati04.

~ ,P. will abide by 1M AS!\, Rt.1 !,i111 of

* ,.!cHlon~l Conduct.

Cert lftc,ittan ta for* porivd .,f S yca.H,

.,.,_ Replator, AAalysif Tut" CommJNlott bae pniparecl * *Jl and a candidate for re~al muat The ASl's'T hat ttUiuted the ~ t If) resu\*~ *nal)'*l* on th!* prapoNd the induttry for ce~tion to hi regulation. The an1}yt11 nunine* theo doCW1WDt oontinoed 11r.tive J)ennanenl approximately $1000 per nwuv.. J,lhu, r:011t1 and benefit. of the allem tiv4!f t!mployment in ndiopphy fot at IN1t nut or tiw laat 36 montht. Jn addtttnn, whi<.Ja indade. o m fee. and COII\I, con,ldered by the Commi11,ioa. 'l11e l l't't'IIIWII cndida~ muat document t i;t ij 'hourt t'lf 1nnual tannill ch1HM0tn 11.ilnins on r diat.ion 1.if1ty tor,l(;t inLl12d1n1 new *f~ r.ru}1Jtion, ut travei. and admini,tnatiYe co1t1 and IOIJ,i1na 11 IM lHbDI aite. Certili1:aUOn i, fQT

  • period or 5 ,,.,., U1d cudida1e for renewal muat ~ n l draft 111 1Jli* us available fu, lnapec:tion In uie ~'RC ~bli~ Document Jtoc,rn. Z12JJ L Bl?HI NW. (Lower Lnel).

Walhingtan. DC. Stnsle copi** of th*

requi~menta. U then renewal c.Titr.n.i continued acuve permanent emplo)'mtnt dnaft 1maty1i1 m 1 be obtAhMN! fl'offl are not .,,et, the candi.iot1 "*ould h~ la radiograpbJ for 1\ lc"l 2t out of the Alan JC. Roe<:kleln. Offiw of Nuclear r~uired to Npur the 6.aminatton 1111 36 montba. in addition. the renewal RP.auiatort Resetrch. U.S. Nu1.le..,.

p 1'QCf!st. c.aucbdate mt>>t doclment at Jeut 8 R~ul*tory c.ammislion. Wahlqton.

hSNT pl11n to imrlr.n:tmt an mhlal 'houra of anr111al formal cl;,nmom DC '-D!!i:i, T,l.,'hnne (30'1) 49W74Q.

tr111l of iii' 1;ali:1~lion pr~r11m in tratlnin& on radian ;n iutrr:t:1 ,,,µ:ca Tho Canw1i*slon reql'.le,it* publle Dcccmi.>l.:r or 1989 lt '* *icr.e'=ted that the includi111 new aaf4,ty J'tiUlst!or.a or 1.onunent on I.hi draft regulatory progrilm will bt hally capable of tequlttmt!Ota. If lheH R~we,.l Clil~rll .na1y1i1- Cnrnmenta on the cltaft **

eertlfyln3 approxime1ely 10,000 are oot m*L ~ c.tQdiaate would be *n* l)'Sil may bt tubmitled to lht NNC!"'

r~ cUosrepturrw 111iiithin %iu 3 )'~*r... l'he requirod to nrpcat 1M eumirlatioll H indicated \l'T'ldf}f rh-. ADDnall NRC ataff will moruti,r th,. 1n1l program procen. The NRC expecui llN of the haadi113 pnot 10 lnltlatir-1 ru~eraakL,g "*hlch J\SNT certific:.tioo program by the Raaw-taty flexibility C.rtwa&IM would mah third-~"Y Cf!rttncauan

  • ticcnec * .,,uoHt wawd DOt affRt r~qolrt.m*nt. licenaee lrai.ml\8 oottl beeluae prnent Ba*ed upoo the informetioa aniJ.abl,:

More d*taJed inionMtion 11!J111td1n1 ~C regu)atiom rwqlAlR wlnifta and at thit liqt' uf the Nlemakin9 lh, certiliuU~ Pl'otrillDI la 1v&iwl,le would eonlinut to do ao. and becuGH pt'QCeemng and in accon;:tanc* l8'ilb lhe from th. Arnsri~ 8o(~ty for tlle ASL\, el~biJH, NquJJ'ementJI Rtlf~l*lory Flexibility A01, I U.S.C.

Nondutructin Tl!Sting. me., '6153 include do11:111Uoted. trainiq. Sumc eo&(b~ tlle Commlu1on certifi** tbl. lf Arlin<<ta Pl~ P.O. Dox W18. amalJ l'lldUCtiOD 1D C011 wtU be prv1nulpted, lhi* rule will not haw

  • Colwnbua. OhM, uz~1&. a11&ociatfd WI~ tbt IPPlk*don prucn111 aianlfltont econoouc bnpael \lpoll *

~u*e if* nadwamphy bceaN t111b1twiU*l number or *mall M\UtsH.

DtecripUo1 of Prv,oNd Ameodmml applicant elec:ta to have ill Th* prapmied rule M:Juld affect all The propoeed umDdmfflt tu 10 CFR radtograpban auti1lcd. tht' appitMnt lnd;aau-ial ~pay lic:.enN

~Ul wawd appl..!d~=r,Uc*mt.t lor would nvt bl" &o I\Jbqu.t datailad appl.ica:nm. Cmttnu,, licen1t applicanbl NRC llld1111mu r l;CflQML cia.criptiau af 8 , ...... bailial ndi~tiDJl re reqllftd ander 10 CFll pert N,U(h) ne Dl'QOHd i.htwauld ,nn.Nis aafety tnillq ud ..... JIIOll'UD to provide dwztpdam r,f iDiti-1 r a ~ , ~ ..pl.ic:ant.&M connn1 the topica li1ted In appendix A. training. tnUna and ,-riock Nfety

.2 :09 ATA WASH 4TH FL NO.011 004 r

Fadltal . . . . / Vol. H. Na. Z19 / 'nuuwday. Novem.bef 0, 1980 perfonn1nc1 appr111al1 of all radio11r11phtr1 tn their mplor. Th*

    • t For tht rH1on1 out ID lh1 pte*a1ble and Wide, tb1 authniit, nf Ille iiropoaed nalt wOMld add
  • pnwlatnn Atomic lln11r11 Act of HM. 1&1 minded.

that wauld p,m.11 **tltutioll of A9NI' tht Ent!'8)' lua,wanluHl"lft Ael 191,&,or ctrtiRcahon far ~lain111.11nt ** 1m*nit1111, and J U.8.C. IN. tilt NRC ta ,ubmH detailed DI iDJtia1 t, propo1tq to adopt the followtne r1d,1tton 1&!1r, tn.taiDf ud tattma an1f!!ndm.1ftt to 10 CFR part M.

prac111dW'l11D liaDlt appm:adane.

De~*uM th, c:a.t Df A5NT oerdation li'AAT l'-1.JCINIU POlll ptr t-adiogra~r 11 eedmatad at 9'ADIOQAAftHY AND AAOIATION appl'Osimatal)" '1Clll for * ~OltlOD UFETY tUCU,A1¥EHTI FOR pertod rd a,..,. ull l'ell'UfteltlOn RADIOGIUPHIC OPIAATIONI without rw- min +:ioa ii 111:lmatad at 11;,proxim&t1ly 1104? pr ncM,...pt.cr. t. The aulhority cHatlon for pa,t ~

Aid the potati&l .-pnwema& 1n 11l1ty continue, to H d II foll0\l'i1:

Wvar-to ... and perlormance ii Au-ttr- S.c.. n, 1IJ1, 111. 1N. N lkal.

con,idertd l.o be aipilira~t. &be owrall ens...._ ,a. ..... mended <a u.a.cuus.

inci11atry beu 6'- an canaiclered to DOI. IQl. W3): tee. lot,* Stat. U4&, RI outw*iab tba ec:onmn.tc tmpae1 Gil nuul am111ndtd (42 U.S.C. 58'1),

industrial rtdi"81'1PAY 1Jcan1NL Sectien IU1 aJao iNIMd udef NG. aot. M Howtnr. lb. ~RC 11 INkina aomment, Stat, tU& (U U.1.C. IMI).

end ltJMHt1d m~.c:aUoftt of lh* For the PIUJ>ON* of Ne. m.

  • Ila\. 15&. H propoaed n&le °bcul&N CJf th11 wtdelr amecd~d (U ~.S.t"- 227:1}; 11 a&Q. MJt.

dlffnina conditiona unda, whleh am 11 M.M. IU.&(a). (h). a11il (llt. UM, M.tt, tUJ lndu1trlal m!Joarapby licemf!!H op"*l*- (*l nd ID!, ,u1 SUI{*). (c:~ 111d (411, SUt, IUL and M.4t(a). {It) and (c~ an.d NM * .,.

Any 1mall mtity.1ul.!111ot lo tbi, re,wation '-N.ch delarminu tll*t. IN111d udu 1ec. iett.. ltat. Na."

bac ull of H* ,1.1.. It i.a liklr ta be*r I amendad (61 U.1.C. art(b)): and II IUt(c!),

.1lesiroportionate 1dHrH eoonoauc: IUI (C) liD4 (di. N.& 14.ZT, IUl(b).

tmpact. 1hculd notify th* Commia!on tir SU!lf 11~ IUl(c). K.J8 (b} aacl (el, aad lnll in a CO!!Ur\e:n that indic:at..- 3U,td) IN ilud lllldar NG lllO. 11 lta~

11!0. H e#lfnd<her'1 k.nowledS9 ud by the oommnt,r. and UDderstand1nt of thea 1ub1ec:t1. the

...L {t) How the rqulatior\, It modlfted. appllca~t afhnna that all htdividwll1 7' would etill adequately protee1 th public *~ ling aa radiographers will b certWed h,u'lith and 11.f*t1. th"""'"' tu Certlllcat10fl Pfo8l*twa Cur Bad[ftt Anal.,. lnd11.lria! Ldlop-.phy bcliatbna Bat~

Pe"'onnel or tile Aawtaan Bodet)' lot The NRC hat detmnined that lhe Nondv1tructtn Tetnq. hie. prior to backf1t !'\Ile. 10 CFR 50.100. do.a not com.menctna dr.iliH ** radio,rapher1.

apply ta tbi1 pn,po,ad rule. alld (~1 paragraph doe. oot rvline a th~~rure. tbt a baddit ~lJaia i* not lic;en1ee from compliance with &lae r1quinld for th1' p!'O?Oaed rule. becauae ttat.ni"8 reqwremcntJ of t 34.31(a) or thee ammdmsnte do not in'Y0lvt any thi1 part.)

provtelon* whlch would iaq,aae hackfit* * * *

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  • ~.....u...----

The Light company P.O. Box 1700 Houstongoex,rB7'Z.Oll f'l.2~ 28-9211 Houston Lighting&: Power Secretary, U. S. Nuclear Regulatory Commission Attention: Docketing and Service Branch Washington, DC 20555 Comments on 10CFR Part 34 (Proposed Rule),

"ASNT Certification of Industrial Radiographers" Houston Lighting & Power Company (HL&P) submits the following comments in response to the proposed rule concerning ASNT certification of industrial radiographers. HL&P does not disagree with the proposed rule as written, the intent of which is to recognize the ASNT program and to encourage industrial radiography licensees to participate in the ASNT program. However, HL&P does not concur with the proposed initiation of a subsequent rulemaking which would require third-party certification of all radiographers .

HL&P radiographers are currently certified by the State of Texas in accordance with the state regulations. The proposed ASNT program was patterned after the Texas program, but it is not as strict. Requiring third-party certification of all radiographers would result in HL&P radiography personnel having to be certified by both the State of Texas and the ASNT.

This would pose an additional and unnecessary financial and administrative burden on HL&P .

Rather than requiring third-party certification, HL&P proposes that each Agreement State have the option of accepting such certification or administering their own program. State administration of the program would provide greater assurance of compliance with the provisions of the certification process .

If you have any questions, please contact Mr. P . L. Walker at (512) 972-8392 or myself at (512) 972-8530. ~ .

/ / l . i0u~ett Manager

~

Support Licensing MAM/PLW/nl

-~ bJ Glill~Z o ob cc el aW J tis Al/023 . Nll A Subsidiary of Houston Industries Incorporated

( U. $. NUCLEAR RlGU :\TO< r ,, ,' * ,N DOCKETI NG

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~ DEPARTMENT OF HEALTH 00* * . _@

4815 WEST MARKHAM STREET

  • LITTLE ROCK, ARKANSAS 72205 usi~'lo TELEPHONE AC 501 661-2000 M. JOYCELYN ELDERS, M.D.

BILL CLINTON "90 FEB -1 GOVERNOR DIRECTOR A9 :57 January 22 , 1990 Secretary U.S . Nuclear Regulatory Commission Washington, D.c. 20555 Attn: Docketing & Service Branch Ref: Notice of NRC Proposed Rule Making: " ASNT Certification of Industrial Radiographers The Arkansas Radiation Control Program offers the following comments on the proposed rule making.

A few years ago, many of the Agreement States encouraged the NRC to pursue rule making relative to industrial radiography. When that rule making did not occur, the State of Texas took the initiative to establish a comprehensive set of regulations to address several concerns noted with this use of radioactive material. These regulations included a testing/certification program, but also -focused on other safety issues . While the evaluation of the Texas program is preliminary, there is strong suggestion that it is reducing exposures. It also appears that a certification program alone is not the paramount reason for exposure reduction. A discussion of these points is contained in a letter to Mr. Harold Denton, Director of the NRC's office of Government and Public Affairs from Mr . Dave Lacker , Director of the Texas Bureau of Radiation Control, dated January 9, 1990.

While the NRC' s proposed rule on certification signifies rek indled .int~re.r1.~-J>1/41,./ ,ir the NRC in radiography regulations, it falls far short of wha t may be needed ,,, ~

to increase radiation safety in the industry, and worse, may actually divert attention from more pertinent safety issues. We concur with the position of the State of Texas as described in Mr . Lacker ' s letter to Mr. Denton and urge the Commission to reconsider the proposed rule.

Finally, we reiterate a statement made in the letter from the Organization of Agreement States to Chairman Carr, dated November 16, 1989. Rules that are to become matters of compatibility for the sta tes shouJd be developed in close cooperation with the states through some ty pe of joint rule making effort.

U. S. NUCLEAR REGULATORY COMMISSION DOCKETING & SERVICE BRANCH OFFICE OF THE SECRETARY OF THE COMMISSION Document Statis .ics l

Postmar, Date I  ?- ~

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This is particularly true for radiography in that as the Agreement States have the concentration of radiography licensees, we have developed the commensurate level of regulatory experience. The expertise derived from this experience should be utilized.

Greta J. Dicus, Director Division of Radiation Control & Emergency Management GJD: j i

- cc: Carlton Kammerer

Post Office Box 1 536 MORGAN CITY, LOUISIANA 70381 Phone 504-631-2426 Phone 504-631-2837 JOEL MOREAU, President PHONE 446-6861 January 26, 1990 Secretary, U.S. Nuclear Regulatory Comission-Washington, D.C. 20555 Attn: Docketing and Service Branch Ref: Comments on Proposed rulemaking ASNT "Certification Program for Industrial Radiography Radiation Safety Personnel"

Dear Sirs:

My name is Billy Juneau and I serve in the capacity of "Radiation Safety Officer" for Global X-Ray &Testing Corp. in Morgan City, LA.

Our Company is solely owned by Mr. Joel Moreau and we employ about 45 people in the field of Industrial Radiography using radioisotopes and x-ray machines.

My comments on the above referenced topic express our concern with two problems in 11 Third-party 11 certification:

1. Verification of the validity of required safety training programs.
2. Economic impact on small businesses.
1. Verification of safety training programs.

It is my understanding of the present propose

  • rgarat *:-0ns tha.-.-----

licensee will have two options to provide certification of. ~i ~d. t 1 regulations: o~, 3,.~ **

A. The licensee may submit descriptions of initial safety training ;.

and qualification procedures to the NRC or an agreement state

  • for approval and verification.

B~ The licensee may omit the above notifications and provide a state-ment that all personnel shall be certified in radiation safety through ASNT's IRRSPPA-1A program.

U. S. NUCI.IM' lllQUI.At'ORV COMMISSION DOCKmNG a SaMCE BRANCH OFFICE OF THE SECRETARY OF THE COMMISSION Document Statistics Postmark Date { f~ G:,

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The regulations now in place in Louisiana require that any formal training program address the topics outlined in CFR Sec. 34.31 App. A, the licensees Operating and Emergency Procedures, practical examination in the use of the company's equipment, refresher training and a method to determine the understanding of the foregoing. These various subjects are reviewed and witnessed by Louisiana Nuclear Energy Division personnel and verification of the program's effectiveness is thereby provided As I understand the proposed regulations, the licensee could choose to eliminate the preceeding requirements by stating that personnel will be required to be certified by the ASNT certification method before acting in the capacity of radiographers. It seems to me that choosing the ASNT certification option would also eliminate some of the verifica-tion procedures presently in place. After speaking with Mr. Ronald Selner at ASNT headquarters, it is my understanding that ASNT committees would review documentation of training methods leading to the ASNT Exam and certify their validity. I do not believe that this method will provide adequate overview of the initial safety training programs of the licensees. I also believe that this method will be subject to misuse if the verification is done by volunteer ASNT members, since the membership is largely composed of employees from NDE:companies which are in competi-tion with each other.

I am sincerely in favor of centralized testing for industrial radio-graphers; however, I believe this should be a function of the NRC and the agreement states. This belief is substantiated by the results shown in the state of Texas.

2. Economic Impact While $1000.00 per radiographer for certification may sound insignifi-cant to some people, this represents quite a burden on small companies at a time when the economic outlook in the Gulf South is so depressing.

Competition for the much smaller amount of work now available in the Petro-Chem industry for NDE work is very keen and profit percentages are now at their lowest point.

This $1000.00 is also an added financial burden when added to the esti-mated economic impact of recent NRC regulations concerning equipment changes and added monitoring devices.

I feel that a centralized certification examination could be administered by the NRC and agreement states for a much lower total cost. At present the Texas Examination fee is $50.00. When costs of housing,Itravel and meals are added, this estimated cost is no more than $200.00 per radio-grapher for our personnel.

==

Conclusion:==

It is my opinion that ASNT certification will cause more problems than it solves and that the possibility exists for abuse and misuse of the regulations.

This could possibly lead to less effective safety training than presently exists.

I do not feel that it is in the best interests of the industry to delegate regulatory authority to what is basically a voluntary industry society.

I also feel that there will not be a significant increase in the effectiveness of safety training by using this methods when compared to the increase in cost.

Sincere

~

Billy Juneau , Vice President and Radiation Safety Officer BJ/dlc

DOCKET NUMBER PROPOSED RULE -

PR 3 t/  !!

~5 TULSA GAMMA RAY, INC. (51 /-~ f'7tJf'9 l'OCK.* . ~

11 27 SOUTH LEWIS - USN1/ tO TULSA, OKLAHOMA 74104 C 918/585-3228 FAX# 918/584-5598 "SU JAN 30 A11 :29 JAMES C. MOSS PRESIDENT SECRETARY, U.S. NUCLEAR REGULATORY COMMISSION Docking and Service Branch Washington, D. C. 20555 Gentlemen:

Reference your Proposed Rules dated Th ursday, November 9, 1989, 10 CFR Part 34, ASNT Certification of Industrial Radiographers. I respectfully oppose the NRC 1 s particiaption in this program.

I am not in accord with the ASNT involvement in the radiographer cert if ication program relative to radiation safety.

I sincerely feel that it will cause to create a dependence on ASNT and lessen the individual employers dedication and responsibilities for radiation safety.

The cost to comply will impose a severe hardship pn my company and many others without any improvement in radiation safety.

Thank you.

Sincerely yours, TULSA GAMMA RAY , INC.

- ,-.,.. ///

>-- ~'??'7. . Moss 7 nt j t

'Acknowfedgecf I;, eailci:::,:;,wiu O ; al 100 a

U. S. N UCLEAR REGULATORY COMMISSION DOCK LTI NG & SERV ICE BRA NCH omv OF THE SEC RE I At<Y Of- I HE. COMMl::.SiON Docum ent Statistics Postmar k Date {/ ,5i. C:i Copies Recelved-'"'7 1-/. .----------*-

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DOCKET NUMBER PROPOSED RULE PR 3'f FRANK MALEK & ASSOCIATES 705 Beech Drive Montgomery, Texas 77356 COGKCTEO (409) 588-2580 USN C "90 JAN 29 P2 :45 January 21, 1990 OF ICE OF SECR lA Y D CK TING Rvtcr:

DRANO~

Secretary U.S. N.R.C.

Washington D. C., 20555 Attn: Docketing & Service Branch Gentlemen:

As a licensee in Texas, I feel the training,testing and certi-fications as conducted/required here in Texas more than meets your proposed rule requiring third-party radiography certifica-tion.

And the cost of $1,000.00 per radiographer whether paid by the radiographer or the licensee is way-out of line. Texas' fee is $50.00 - how much of the $1,000.00 goes to the ASNT?

Can/will ASNT revoke a certificate if a radiographer is found guilty of a non-compliance incident? The State of Texas has already revoked several radiography I.D. cards.

Since many radiographers (2,000 in and out of Texas) now have Texas certificates and your ASNT program is based on Texas' program; why do we need another certificate?

If the NRC insist on using the ASNT group - fine - but give the industry the choice of using the Texas agency or the ASNT. The end result is the same - a safety certified radiographer.

Sincerely, Frank Malek Copy: Texas Dept of Health N.D.T.M.A.

FM:mam

U. S. NUCLEAR REGULATORY COMMISSION DOCKETI NG & SERVICE BRANCH OFFICE OF THE SECRETARY OF THE COMMISSION Document Saltiatlcs Postmark Date I/ 2. 3 Ccap1es Received i- l Ad<M Coi::,ies Reproduced 'f:

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Texas Department of Health .24

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Robert Bernstein, M.D., F.A.C.P. 1100 West 49th Street Robert A. Maclean, M.D.

Commissioner Austin, Texas 78756-3189 Oe,P.utv Commissioner (512) 458-7111 Oft!CE; F $~CfJTVtlio.fessional Services "lJCKE I ING & .)t. i{ lCt *

. . u BRANCH Hermas L. Miller Radiation Control

  • Deputy CommissJPJler (512) 835-7000 Management andiatministration

(...

January 9, 1990  ::::0, c.:

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{..*:-

r Mr. Harold Denton, Director "

Office of Governmental and Public Affairs Mail Stop Wf-17-FZ U.S. Nuclear Regulatory Commission

-.. ~l Washington, D.C. 20555

Dear Mr. Denton:

This letter is to inform you of a serious concern this Agency has regarding the effectiveness of the third-party industrial radiography certification program currently under consideration by the Nuclear Regulatory Commission (NRC) and the attention which is being placed upon the industrial radiography safety exam itself. Our concern is that undue emphasis is being placed upon the safety exam as the means to achieve our mutual goal of improved radiation safety in industrial radiography when, in fact, the exam has played a part in the overall rule which has resulted in improvement of the safety record of Texas radiographers.

The revision of Texas Regulation for Control of Radiation (TRCR) Part 31, "Radiation Safety Requirements and Licensing and Registration Procedures for Industrial Radiography," was developed over a period of five years with careful consideration given to radiography safety problems. During this time, the Agency reviewed overexposure data and determined that the majority of industrial radiography overexposures could be attributed to failure to follow established safety procedures, equipment malfunction, or inadequate safety training. As a result of this data, rules were promulgated which address these problems with the intent of improving the safety record of the industrial radiography industry. TRCR 31.15 establishes miniml.lll standards for radiographic equipment, TRCR 31.30 requires two qualified radiographers at temporary field sites which provides an added measure of safety in the event of an emergency at a field location, and TRCR 31.20 was revised to correct training inadequacies.

To be qualified in Texas, an individual must successfully comvlete a ~0-hour safety training course prt,1od to operating any radiograph'ic equipment, have at least two months o ocumented on-the-job training, demonstrate competence in the use of radiographic equipment, pass the Agency-administered safety exam, and possess an Agency-issued I.D. card indicating successful completion of the exam. It is not the intent of the Agency that possession of an I.D. card be the sole indicator that an individual meets the regulatory requirements. However, possession of an I.D. card gives the individual radiographer direct responsibility for observing safety procedures because the Agency may revoke or suspend an I.D. card.


. . f

    • - ,.l I

. I U. $. NUCLEAR REGULATORY COMMISSION DOCK ETING & SERVICE BRANCH OHICt. OF THE SF.CRE I M{Y Or l HE. COMMISt;iOr.J Document Statistics Postm ark Date CQf)1es Received

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Mr. Harold Denton January 9, 1990 Page 2 The changes to TRCR Part 31 became effective in October 1986. The enclosed figure shows that overexposures to radiographers are on the decline and that radiographer trainee overexposures have dropped off dramatically. This improvement is a result of all the industrial radiography rule changes implemented in 1986, not jus~he exam requirement. The Agency uses the exam requirement as a compliance tool. Successful completion of the exam indicates compliance with the rule requiring an understanding of radiation safety principles and provides an indication that the radiation safety training received by the individual is adequate.

To date, the Agency has suspended one I. D. card, and two others are being considered for enforcement action. In each case, the individual passed the exam. This indicates the individuals had an adequate knowledge of safety principles but demonstrated a willful disregard of the rules. For this reason, the Agency feels that any exam or third-party certification requirement must be accompanied by rules similar to TRCR Part 31 and must be administered by a regulatory body which has the statutory authority to promulgate rules and impose enforc~ment actions.

The requirements in TRCR Part 31 are proving to be effective in im proving the safety record of the industrial radiography industry in Texas. This Agency is proud of our industrial radiography exam program but recognize that the exam is j ust one aspect of a multifaceted approach to regulating industrial radiography safety. We are concerned that other parties involved in this issue may not be fully aware that the success of our program is dependent upon a cohesive rule package.

If you have any questions concerning this issue, please contact me.

You s trul y, i ~

-toavid

~ K. Lacker,

-7/(~J)'--

1 Chie f Bureau of Radiation Control Enclosure cc: Carlton Kammerer Charles Hardin, CRCPD Robert Doda, USNRC Region V Agreement States

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Department of Human Resources HEALTH DIVISION 17Z()7 NEIL GOLDSC HMIDT GOVERNOR 1400 SW 5th AVENUE, PORTLAND, OREGOt'W2QIN 24 p3 :27 (503) 229-5797 TDD-NONVOICE: (503) 229-5497 OF Ff CE OF SECKETARY OOCKfilNG & 5EHVICf" January 17, 1990 BRANCl-i Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTN: Docketing and Service Branch This is in response to the Nuclear Regulatory Commission's notice of proposed rules regarding third-party certification for industrial radiographers (IO CFR Part 34).

The Federal Register, Volume 54, Number 216, dat ed Thursday, November 9, 1989 refers to the American Society for Nondestructive Testing (ASNT) as being a certifying third-party. Oregon has no particular problem with the ASNT training industrial radiographers for the purpose of passing a certification examination. However, it should be made very clear that ASNT would not necessarily be the only third-party organization who could be recognized for training industrial radiographers. There may be several organizations capable and interested in becoming involved with this training.

There should be no discrimination among trainers. Private training facilities, along with the ASNT, must be allowed to train radiographers as long as their program meets the guidelines of the Texas test.

Thank you for the opportunity to comment on this proposed rule.

Sii;,J ~

Ray D. Paris Manager Radiation Control Section RDP:clh cc: Carlton Kammerer, NRC Director, State, Local and Indian Tribes Program Jack Hornor, NRC, Region V State Agreements Program 5 1990 AN EQUAL OPPORTUNITY EMPLO~ ER . fed'gec,.by*-,-:. -.;;:;

Mailing Address: P.O. Box 231 , Portland , OR 97207 Emergency Phone Voice (503) 229-5599 - TDD-Nonvoice (503) 252-7978 24-26 Rev. 5/88

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ULTRASONIC SPECIALISTS INC. CO(;Kl1EO (713) 453-0486 USNRC P. 0. Box 24368 FAX NO. (713) 451-2770 NONDESTRUCTIVE TESTING SERVICES Houston, Tx. 77229-4368 OfFfCf. Of SECRETARY DOCKETING 5ERVtcr:

BRANCH Secretary U.S.Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch

Subject:

Proposed NRC Rule (10 CPR Part 34 RIN 3150-AD35)

It is our understanding that if the above becomes law, our presently certified personnel in the states of Texas, Louisiana, Mississippi and Alabama will be required to re-certify under the ASNT program.

If this is the case, I regard the change as being unfair and discriminatory toward a small business such as USI. Most of the companies in this business are too small to absorb the high costs of a new certification system ,

particularly if there will be no provision for acceptance of those allready in the trade.

We have been thorough in the training and certification processes applied throughout our market area; and now, to think that all of our work should be negated by a new law is very upsetting, especially if the charges for certification run as high as $1,000 per technician.

That would be another $65,000 to go with an estimated $160,000 of additional cost which we will incurr in order to meet other more stringent regulations for radiation safety equipment.

So pardon me if I am not too thrilled about the prospects for this industry, when you fellows in the rule making side cannot be more considerate of the costs which your changes cause us. I urge you to make some provision for companies which have paid the price to operate with high standards.

Yours Truly,

~c{J,~~

Lloyd A.Gray Operations Manager & RSO (318) 837-3981 (205) 666-0364 (504) 292-3661 P. 0 . Box 90754 779 Lakeside Dr. Unit C 11616 lndustriplex Blvd. # 18 Lafayette, La. 70509 Mobile, Ala. 36609 Baton Rouge, La. 70809

I -

rr 1 estzng

  • Lab oratories
  • LocKEirn @

BX uSNRc P.O. BOX 4239 V P.O. BOX 652 P.~OX1i o 14)1? P12 :26 BAYTOWN , TX 77520 TEXAS CITY , TX 77592-0652 BATON ~u~lkfuaM 713-422-3656 409-945-2207 504-291-0916 0H!C~ OF SECRETARY DOCK(ilNG & SfilVICf.

DOCKET NUMBER PR J L~ BRANCH

/RO POSED RULE .---:,

January 1a, 1990 cst1 r 1<. 4 '70r1)

Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Service Branch Gentlemen:

After reading the new proposed legislation of ASNT's involvement in central certification, we as owners and managers see no useful purpose for this, other than to line the pockets of the ASNT. We agree that training, testing and certification if conducted on a local level can prove to be successful and beneficial to the industry.

We have completed our training, testing and certification through the Bureau of Radiation Control in Austin. Any additional requirements to this issue would serve no purpose and prove to be unfair, unjust and devastating to the industry.

We, as management, intend to do whatever is necessary to prevent duplication of regulations.

We anticipate a response to this letter, and appreciate your cooperation in this matter.

Respectfully, fYl.0, /Y\J~

Mark D. Meadows Radiation Safety Officer MDM:nm cc: R. Allison C. Weber Acknowredged by card*

  • or::* 1124 *
  • C4 I,: ...

0 3. M!CLE.A.P. RtGULATORY COMMISSIOti DOCKETING & SERVICE SECTION OFFICE OF THE SECRETARY OF THE COMMISSION Oocur1cnt Stat 1st 1cs

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1\ EDWARDS PIPELINE TESTING, INC.

OOC:KETED USNRC

'SO JAN 22 Pl2 :37 DOCKET NUM R p 3 cJ '. \ii PROt J..;,1..,J ,, ~t -/~---,,. OF F'ICE .@e_fiti~ yAiYi DOCKETING & Sfi<Vfr.r '

1990

( £ lJ FI< 41 O~q) , BRANCH .

Secretary, u.s.Nuclear Regulatory Commission Washington, DC 20555 Attn: Docketing and Service Branch Re: Proposed Rules 10 CFR Part 34 RIN 3 150-AD35 (ASNT Certification of Industrial Radiographers The changes proposed in this rule will cause many drastic changes in our industry as we l l as an additional e xpe ns e . A burd e n many nondestructive testing companies cannot endure.

I conceived the idea of "3rd Party Certification". In fact, I endorsed the letter to the NRC from ASNT. As strongly as I support third party certification, it is very difficult for me to accept your proposal as it is written. Our original and main purpose was to have the NRC and the various state agencies unite and form ONE radiation safety program. As of this date this has not happened.

There is no agreement between ASNT/NRC and the Texas Heal th Department or any other state agency. There is no agreement between ASNT and any agency for written or practical exams. It is apparent to the companies that do business in Texas that the Texas Health Department have no forthcoming plans of changing their program.

To continue to push ahead with your proposal as it is written could cause havoc in the nondestructive testing industry. As it stands, any agreement state could decide to instigate their own program.

Nondestructive testing companies could end up testing radiographers any number of times. As I previously stated, I am strongly in favor of third party certification. But, only on basis of that certification being honored irregardless of what state a radiographer is working in. It is not feasible for a radiographer to be certified by the NRC and again by the state of Texas and again by every other state that decides this is a good source of revenue. The cost to test in the state of Texas is approximately

$300.00 per person. It does not require a degree in mathematics to realize the revenues involved in the testing 1000 or more radiographers.

1205 South Gillette, Tulsa.Oklahoma 74104 918/582-1781

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I am totally against third party training being mandatory .

Irregard les s of where a radiographer is trained, he would still be required to pass specified certification test. Our company has utilized third party training for our last four training programs.

However, I still have a choice.

In reference to your articles on page 47091, A - E, I have some specific comments.

A. No small company can survive $1,000.00 per man the first year.

The cost may be spread over several years but you win or lose o n the financial statement each year. I would estimate the average small company hires between 50 and 75 employees each year. $50,000 to 75,000 is a huge burden, even if spread over several years.

B. A small company has fewer actual working days (on job sites) to expense the cost to. Their only choice is to raise their rates and let the oil companies absorb a large portion of this burden.

A small company that doesn't have the equipment to compete on the large extended projects will have to increase their rates to the extent many could be out of business.

c. My comments are contained in my letter.

D. My comments are contained in my letter.

E. If a radiographer is tested utilizing an adequate program it would be of no consequence which agency's name is on the certification. The benefit to the safety of the public would remain the same. The difference would be the cost of $1,000 to test with ASNT or $300 to test with the state of Texas.

Basically, I would say this proposed rule was probably hastened along and not adequately contemplated because of the anticipation of the potential revenues. Whatever agency ultimately performs the certification stands to profit considerably. This, however., is no justification to adopt an ill prepared regulation.

Please consider the following:

1. Do the Agreement and Non-agreement states have any type of agreement to work together or accept certification from each other?
2. Does ASNT and the state of Texas have any type of agreement to work together or accept certification from each other?
3. Has ASNT's written test, practical test and a feasible testing location been determined?
4. Will the Texas certification and ASNT's certification be transferable and acceptable in all the states without any changes in their present programs?
5. No amount of training and certification is going to force any radiographer that is lackadaisical in his practice of safety requirements to be thorough. The ONLY way to insure public safety is for the individual to be responsible for his incontinence. This would include fining the individual for infractions and if necessary the removal of his card.

In summary, let the companies decide on who trains the radiographers. Let there be only one certification required. One certification that will be honored in both agreement and non-agreement states. In addition, don't force companies to test with the ASNT at the cost of $1,000.00 per person when they can already test in the state of Texas for $300.00. And, let the individual radiographer suffer some of the consequences of his own behavior.

As you can easily see, I feel there is much work left to be done on this proposal. It's main purpose is admirable but it's design is inadequate.

Very truly yours, Don Earl Edwards DEE/ml

Schonberg Radiation l'OLKETED@

USNi~C Corporation "90 JAN 19 p 4 :SS DOCKET NUMBER PR . ~~

P~o~st70/~E4 7 o8 fl January 15, ~~~@rPJGSt~JTA t Dl 9A-USNRC . 190 BRANO{ VICf.

Secretary, USNRC Attn: Docketing and Service Branch Washington, DC 20555 Gentlemen, I would like to learn whether the intention of NRC is to take over the state regulatory functions regarding X-ray equipment operations.

There are two elements to the operation of any radiation devices or sources. The first addresses competence in achieving results meeting a need. This requirement is a customer driven and regulated function. The second element is safety. The states have had cognizance of radiation safety for X-ray devices of all types. The NRC has responsibility for isotope radiation safety.

Is it the intent of NRC to enter the X-ray operation or safety regulation arena?

Please clarity the proposed amendment 10CFR34. If it is just to be applied to isotope operation, then I suggest your amendment be renamed to reflect isotopic radiography, as distinguished from X-ray radiography.

Very truly yours Russell G. Schonberg President 3300 KELLER STREET, BLDG. #101

  • SANTA CLARA, CA 95054
  • PHONE: (408) 980-9729
  • FAX: (408) 980-8605

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January 10, 1990 USNR C c5'1 rr<.1/,o~q)

Secretary '90 JAN 17 Al1 :30 U. s. Nuclear Regulatory Commission Washington, D.C. 20555 attention: Docketing and Service Branch OFF!CE Or SECRET.t.11Y OOCKC1 ING t, Si-_ilVICf.

8HANCl-i RE: Radiation Safety Training and Certification of Industrial Radiographers by Third Parties Gentlemen:

I strongly support mandatory training and certification of industrial radiographers by third parties for the reasons outlined below.

I believe that the typical, small service companies involved with indust rial radi ogra phy fl agrant ly violate the purpose and intent of recommended practices for employee training in radiation safety. Furthermore, the service company employees are aware of these violations by their companies and this knowledge has a very negative impact upon their attitude toward radiation safety for themselves and the public. Since I work in an industry where industrial radiography is common practice, I am convinced that my risk of excessive radiation exposure from industrial radiography operations far exceeds my risk of exposure from nuclear power plant operations.

I have had some contact with both state and federal regulators for industrial radiography over the past twenty years in industry.

While I think there has been some improvement in the attention to radiation safety over that period, I do not believe that these regulation groups have either the will or the support from industry to force appropriate radiation safety training within the service company industry. Therefore, I support mandatory radiation safety training and certification by third parties as the only realistic solution to this problem. I have cited some examples below of things I have seen and been told to illustrate why I think that the cost of the third party training is not really a factor in enacting this regulation.

This following incident occurred in a west Texas pressure vessel (ASME Code Sect VIII) fabrication shop where I was present several years ago. A radiographer entered the shop just prior to morning break time and proceeded to set up for a radiograph of a repair weld which had been made on one of the pressure vessels. When I inquired what was about to be done, I learned that the plan was to make an exposure of the weld during the break in order to avoid taking the vessel out of the shop to a remote location for the

_ JAN 2 3 1990- . t-* page 1

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exposure. Typically the employees moved away from the vessels in order to take some refreshment and relax for a few minutes.

First, I noticed that this radiographer had no survey meter visible and this really concerned me as the work area was very congested for radiography to be underway. When I butted into the proceedings and began questioning the radiographer about the survey meter, I found that he also had no film badge or dosemeter in the area. As I began to get more and more concerned, I was told that this young fellow's safety equipment (film badge, dosemeter and survey meter) were all located as his home. This fellow assured me that he didn't need all that stuff because he was really good at his job and he was always careful. I happened to know that this "radiographer" was less than 20 years old and had about 1 year of experience in the business. At that point I told the kid that if he cranked out his Ir 192 source there in the crowded shop with no safety gear, I was going to fly to Austin and do my best to get him and his company barred from industrial radiography for life. So he shut down and went home to get his gear. It was obvious that this kid had no appreciation for the risk to himself and certainly no concern for me or the other people in the area. I also discussed this with the owner and operator of the servi ce company and I believe that the guy neither knew nor cared about the long term effect of radiation exposure to his employees or the public. I also believe that the owner wanted inexperience employees who had no appreciation of what risk were involved since they would work cheaper and get more done in a day.

This incident was described directly to me by a young employee of a industrial radiography service company. After about one month of on-the-job training with his company (his first employment in industrial radiography) this fellow was sent alone with a truck to a location near Marathon, Texas which was a considerable distance from his base in Odessa, Texas. During the process of shooting a few small diameter pipe welds there, the end came off his source guide tube. This problem allowed his Ir 192 source to exit the end of the guide tube and the control cable to disconnect from the control crank gear. A situation like this makes even well trained and experienced radiographers sweat but this kid was alone, several hours drive away from home base, out of radio contact range and afraid to tell the management at the customer's location for fear that his company (and he) would be fired for the accident. This fellow told me that he first removed and hid his badge and dosemeter. Then he walked up to the end of the guide tube and used his hands to re-insert the source back into the guide tube far enough for the control cable to be engaged by the gear. The only good news was that the job was to shoot small diameter pipe and his source was down around 5 curies. I asked him what ill effects occurred to his body. He told me that the skin on his hand was burned and looked much like a heat burn for several days. He also said he felt nausea but didn't know if that was due to the radiation or the fear and tension the accident caused. I don't think that this fellow had any real appreciation that the large exposure might have very serious long term effects page 2

upon his health. Also, he had no idea of what he could or should do to mitigate the effect of the exposure.

The following incident was described to me by a good friend who had heard it from the assistant radiographer who related the tale to my friend. The incident was said to have occurred at a pipe line construction location (I think road crossing change out) near Corpus Christi, Texas. Girth welds were being radiographed with what is called a pipeliner camera (source container straps to pipe with shutter movement rather than source movement through a tube).

Apparently some of the lugs and chain for attachment of the camera had broken and interrupted the progress of the job. Apparently replacement exposure equipment was not quickly available and there was pressure to complete the radiography so that the pipeline could be covered. The assistant told my friend that the radiographer told him, the assistant to get in the ditch and hold the camera in position during the exposure. Apparently the assistant knew enough to know that this was a real risk so there was some disagreement about this solution to the problem.

According to what the assistant told my friend, when the radiogra phe r tol d the assistant to hit the ditch or be fired, the assistant gave in and held the pipeliner camera in position during one or more exposures to complete the job. I believe that the source strength in this incident was fairly high as the job involved large diameter and heavy wall line pipe welds. I do not recall what my friend told me about the short term symptoms this excess radiation exposure caused in the assistant.

HY observations about costs vs benefits for third party training.

In these three reports cited above, one common factor was exploitation of inexperience and ignorance of very young persons who typically consider themselves relatively invulnerable to physical harm anyway. I submit that there is an unknown and potentially very large long term cost to our society when industrial radiography is allowed to occur like this. I submit that we have no way to associate long range health effects with incidents like those described above.

I believe many workers around industrial radiography are exposed with no knowledge of what is happening to them and so there is no record of over-exposure. The young fellow who pushed the source back into position first hid his film badge and dosemeter so there was no record of that over exposure. If he someday develops a malignancy in his hand or arm, he may not even remember the incident or make a connection. The assistant who held the camera in position was told to hide his film badge and dosemeter so this overexposure was deliberately concealed. If this assistant eventually develops a malignancy, he will likely make the connection because my friend spent several weeks trying to convince the fellow to file a wrongful injury suit at the time but the kid was afraid of the consequences to his employment. In any case, the same service company was involved in all three of these page 3

incidents and I think is now out of business. Unfortunately, this company was one of the "boom businesses" which "trained and certi fi ed" a fairly large number of new employees in the industrial radiography business. The attitudes these people learned about radiation safety during the first few days and weeks on the job will die slowly, no matter where they work. I believe this is a serious problem in our society.

comments about radiation safety in health care industry. As I became involved with industrial radiography some 20 years ago and learned more about radiation safety, I became very concerned and angry about the lack of concern about radiation safety in industry and the lack of effective regulation for radiation exposure. This made me more aware of what happens in the health care industry. I have encountered health care workers involved with "human radiography" who were just as ignorant and unconcerned as pipeline radiographers. Several years ago I was taking a pre-employment physical which required a chest x-ray. I requested a shield for my lower torso and the technician became openly hostile about my request. The technician finally found a shield for me, which was obviously infrequently used and that was very difficult to use because of broken straps. The doctor running this physical exam business, which profited from doing many federally required DOT physical exams, was clearly hostile to me when the technician reported my request to him. He was even more hostile and threatened to sue me after I complained to the state health department about the operation of this x-ray business. I strongly support a similar program for third party radiation safety training and certification for health care workers, as I believe that the risk and potential cost to society there is even greater than for industrial radiography. I strongly believe that there are persons in health care management (such as the doctor running this exam business) who are just as unconcerned about the public's exposure to radiation as are the worst owners of industrial radiography service companies.

In summary. I believe that if the visual or print media really understood the risks that industrial radiography posed to the employees in that industry and to the public and then actively distributed that information, there would be a public outcry for increased regulation equal to or greater than the protests related to nuclear power plants. I think that the reasons that this has not happened is that the radiation safety story really doesn't package up very well in the "McNews" format which is so dominate today. While a ruptured power plant might make a nice "McNews" headline, someone whose hand or gut is slowly rotting away doesn't make a tight 45 second spot on the evening news.

The notice in the Federal Register refers to statistics for reported overexposure incidents, and this is natural since there are no hard data about the unreported overexposure incidents.

However, I believe that the unreported incidents, like the two page 4

second-hand stories I have cited above and the one potential incident I observed first-hand, are where the major health risks are located. As long as small service companies control the radiation safety training of their employees, the attitude that the regulations are just there for show will exist. State and federal regulators need to clearly demonstrate that the rules are there to be followed and for a good reason. One way to make a clear statement about the intent of the radiation safety regulations is to place the responsibility for the radiation safety training and certification in the hands of a third party who has no financial gain from sloppy safety practices.

page 5

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USNRC "90 JAN 17 P12 :20 OFFICE OF SECRETAHY DOCKETING & StflVICf:

BRANCH January 10, 1990 Secretary, U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atten: Docketing and Service Branch Re: Federal Register Vol. 54 No. 216 Nuclear Regulatory Commission 10 CFR Part 34 RIN 3150-AD35 ASNT Certification of Industrial Radiographers

Dear Sirs:

We wish to take exception to statements made in the above noted document. Specifically, "Regulatory Flexibility Certifica-tion". The statement "the Commission certifies that, if promul-gated, this rule will not have a significant economic impact upon a substantial number of small entities." Please be assured that this rule would have severe economic impact on all industrial radiography company "small entities". As a Texas licensee, our company has already incurred the expenses required to certify all our personnel to State of Texas requirements, which meet or exceed ASNT requirements. What is the point in retesting person-nel with the same test initiated by a third party.

With twenty-two industrial radiographers employed, and using ASNT estimated cost of $1000.00 per radiographer, our estimated cost would be $22,000.00. This expense could change this company from a profitable endeavor to a negative producer.

Although unaware of the exact definition utilized by the Commis-sion, I personally consider this "significant economic impact."!

If third party certification is adopted why can not radiographers tested by the State of Texas be accepted as ASNT certified?

Your response is eagerly awaited.

.,. NUCTfAR RfGUJ ATORY COMMIS51C l)OCKETll':G & StRVICf SECTION or~~-:E OF j;.;~ SECR'ETAH o.* T 1: ,..(* 1MtS5 1C'N

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A DET NORSKE VERITAS COMPANY 16203 PARK ROW, SUITE 120 "90 JAN 17 All :31 HOUSTON, TEXAS TT084 (713) 579-0561 1-800-643-8136 TELEX : 166670 t)f *1c:: OF SECR T~,HY FACSIMILE: (713) 579-6464 DOCKETING . StilVIC[

BRANOi January 9, 1990 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention Docketing and Service Branch Gentlemen:

In reference to the planned rulemaking requiring third-party certification and its impact on the industrial radiography industry in Texas, we, as a small business concern, wish to comment on the adverse economic impact that this proposed certification would have on our overall business as well as our day-to-day operations.

In 1989, our annual revenue was approximately $3,000,000 with an average of 20 revenue-producing employees. However, radiography represents approximately $75,000 of the annual income with 4 of the 20 revenue-producing employees performing approximately 5,000 radiographic tests.

With the implementation of third-party certification, our radiographer certification expenses would be increased approximately $700 per person. In addition to the increased expenses, ASNT certification would create a loss of revenue amounting to $1,500 (5 days) per radiography crew due to increased travel time versus a loss of revenue presently amounting to $900 (3 days) per radiography crew.

However, the proposed regulation could be modified whereby agencies who are recognized by the State of Texas could be allowed to administer these tests as well as ASNT, therefore, reducing the travel time and expenses incurred with ASNT certification.

Additionally, we could maintain our present level of revenue loss (3 days) while certifying our radiographers in the State of Texas.

The detrimental effect of ASNT certifying radiographers is that ASNT publish their test questions; therefore, we feel that our certified radiographers would not be capable of adequately protecting the public health and safety in the same manner as they are presently able to do by achieving their certification from the State of Texas.

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U.S. Nuclear Regulatory Commission Page 2 January 9, 1990 In summary, we feel that third-party certification by ASNT will have a s ignificant economic impact on our business due to the high costs. More importantly, the requirements listed in TRCR Part 31 which are applicable to our Texas radiographers are stricter than those in the ASNT certification program; and therefore, we are highly concerned about the proposed improvement in safety awareness and performance.

Sincerely yours,

  • \ ........ ~&,.,,.,J J~s W. Lawson
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Homer L. Wilson Radiation Safety Officer cjb 7ADM255

PR OOCKET NUMBER PROPOSED RULE

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-SU JAN 16 P4 :14 Secretary, U.S. Nuclear Regulatory D'anuahy.. --11;.. . 1~ 9 0 :

Commission CJFFtcr_oF ,SECR TARY Washington, D. c. 20555 DOCKf 1,ING & SL ilV/Cf BRANCH ,

Attn: Docketing and Service Branch 2120 L. Street N. W. (lower level) Washington, D. c.

Proposed Rule Making 10 CFR Part 34 ASNT Certification of Industrial Radiographers The proposed rule to require third party certification would produce unjust hardships on the airline industry. The air carriers have developed and adopted training programs that reflect ASNT guidelines tailored to airline industry specifi cs . These are programs t hat were approved by NRC Agreement States, for each operator. These training programs have been formalized and presented as; Air Transport Association - Specification 105.

Airline radiography programs employ experienced aircraft inspectors who have been trained in the safe use of radiographic equipment. United Airlines for example conducts 4 to 5 isotope inspections and 40 - 50 x-ray inspections per week at SFO. United Airlines has experienced no personnel over-exposures, has received no safety violations, and has passed State of California Radiation Safety audits. The airlines have a radiation safety record that cannot be matched by the radiography industry as a whole.

United Airlines welcomes uniformity of training and if necessary, legislation to mandate that training. However, we also believe the airline maintenance industry has taken upon itself to create training programs and adhere to them.

The ASNT program offers no improvement in the current airline program, it would only add increased costs and planning problems.

United Airlines strongly recommends the adoption of rules making third party certification an option in lieu of the operators own approved certification program.

Bo Scoble NDT Manager San Francisco International Airport, San Francisco, California 94128 United Airlines

0. 5. NUCLfM RECULA fORY ('OMMISSIOti DOCKETING & SERVICE SECTION OFFICE OF HIE SECRET ARY OF THE COtvW.ISSION Postm :1 r1: D,,,",

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{ SL/ff '-/?081 TERRYE. BRANSTAD, GOVER NOR ARTMENT OF PUBLIC HEALTH MARYL. ELLIS, DI RECTOR January 8, 1990

'90 JAN 16 p4:14 OFF!C ** OF SECR TARY OOCKfilNG SE.ilVtt.r ORANCJ.i Secretary U.S . Nuclear Regulatory Commission Attention: Docketing and Service Branch 2120 L Street NW (Lower Level)

Washington, D.C. 20555 4ltro Whom It May Concern:

This letter is our response to the U.S. Nuclear Regulatory Commission's (NRC) proposed amendment to 10 CFR Part 34, "Licenses of Radiography and Radiation Safety Requirements for Radiographic Operations," publ i shed in the Federal Register, Vol. 54, No. 216, Page 47089, Tuesday, November 9, 1989 .

First , we are in favor of uniform credentialing of individuals who perform industrial radiography and as a regulatory agency have no problem recognizing a private organization (American Society of Nondestructive Testing (ASNT)) as one, but not the only, mechanism of gaining a credential. We have serious reservations relative to the NRC's proposal of mandating only one organization as a certifying body and then forcing,

-I through the mechanism of "compatibility," the agreement states to recognize only that private organization.

would like to take this opportunity to convey some of our thoughts in support of the last statement made in the previous paragraph. I realize that the current proposed regulation does not mandate the acceptance of the ASNT, but since NRC chose to point out its intention to embark on a second phase of regulation making, we want our reservations to be recorded early in the rulemaking process.

1. We take exception with the implication of licensing of radiographers as indicated in the title of FR publication Vol. 54, No. 216 , Page 47089, Tuesday, November 9, 1989. To the best of my knowledge, a nongoverment entity cannot license persons to conduct a function.

Does this mean that the NRC is delegating its authority to license to a private organization? I'm sure that the majority, if not all agreement states, would not be willing to take such action.

2. One major selling point expressed by the NRC and others is that the ASNT is a three-phase program (education, practicum, and written examination). In my opinion, practicum is not necessary to meet the goal of regulatory agencies of protecting the public health and safety. In fact, I believe that by mandating such a program we would only be creating a dynasty for a private organization. I think a more reasonable program is to set and enforce an educational standard which
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is currently done. The one phase not done is to mandate a nationwide standard test to assure that the education a person receives is at least initially retained. It is also necessary to retest in a reasonable period of time to assure that the education gain is not lost. Mandating of continuing education is also a recertification phase which should be required.

In the above paragraph we have been somewhat hard on the practicum phase. We don't wish to imply that practicum is not a means of testing to assure the production of a quality radiograph. However, we believe that it is unnecessary to assure good radiological health and safety practices. We feel that it is a costly phase which is not necessary to meet a radiological health regulatory agency's goals.

As indicated, we have no problem recognizing voluntary participation by industrial radiographers in the ASNT program. Our main objection is the mandatory issue. The NRC can do as it wishes in its areas of authority, but to require it in states through the mechanism of compatibility is totally unreasonable without justification. One program is not always the answer. It is our opinion that a few NRC staff members a re trying to ram this down peoples' throats, and have not done their homework. In Iowa we have several credentialing programs which recognize private organizations, but they do not mandate that persons must belong. The reason they don't is that legal counsel feels that a private organization can't enforce laws nor can a regulatory agency dictate what a private organization does to its membership; the "fox in the chicken coop " principle.

Some of these comments may be considered "somewhat off the wall." It is our opinion that we had little choice. The NRC provides a monumental pile of data but the most important data was not provided, namely the standard Aand criteria the ASNT/NRC will be following to credential industrial

  • r adiographers. We reserve our final comments on the NRC regulations until the standards and criteria are available. We can't concur or support, even in part, something we are not privy to.

In conclusion, Iowa supports the mandating of qualified persons performing industrial radiography. We further support the concept of a private organization being one means of becoming qualified. What we cannot support i s membership in a private organization being the only means of becoming qualified, especially when the criteria to be met is unknown.

If you have any questions, please do not hesitate to contact me.

Sincer e l y, t~o :tttJ Donald A. Flater, Chief Bureau of Radiological Health 51 5/ 281-3478 DAF/bf cc: B.J. Holt CRCPD

IJ RECD International Inc.

P.O. Box 3-C

  • San Antonio, Texas 78217 5680 E. Houston Street
  • San Antonio, Texas 78220 V tKtiED

'9() JAN USNRC 12 p3 '17 Telephone (512) 662-5700

  • Telex 272 532 RECO UR
  • FAX (512) 662-5875
  • uF"F!CE .)~ SECRETARY DOCKET NUMBER PROPOSED RULE PR 3Y.- wUCKET1NG
  • S[flVfCf" f.lHANCH -

January 8, 1990 c rv rR '-/1 o89)

TO: Secretary, U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch FROM: RECO International Inc., License No. 103483 Radiographers: Norman J. Collins No. 00004 Arthur J. Carr No. 01075 Raymon S. Linares No. 01672 David L. Friddle No. 00959 RE: Proposal to Amend the Rules to Nuclear Regulatory Commission Regulation 10 CFR Part 34.11 "ASNT Licensing of Radiographers"

Dear Commission:

The proposal to amend the regulation 10 CFR Part 34.11 of NRC Rules, to allow the American Society for Non-Destructive Testing (ASNT) to license radiographers under third party certification is unwarranted.

We are of the opinion that the ASNT should serve onl y in its current capacity; establishing minimum guidelines for safety, procedures and practices regarding radiographic activities - NOT as a certifying or governing body.

In the State of Texas, radiographers are required to obtain a license through the State Department of Health before using any radiographic source by demonstrating, by examination, a fundamental knowledge of radiographic saf ety practices, radiographic procedures and equipment requirements pursuant to Texas Regulations for Control of Radiation Part 31, which exceeds the requirements of ASNT Reconnnended Practice No. SNT-TC-lA. The l icensing procedure now in place in Texas costs $300 per person, not the $1000 esti mated by ASNT to certify radiographers. Texas has also experienced a reduction in the number of radiation exposures and in our view the program has proven itself a model guide for other states to adopt. ASNT is not a regulatory or governing body and is not equipped to provide anything more than minimum safety and practical guidelines.

To conclude, the licensing of radiographers is most effective and less no

fl.S. NUCLEAR Rl:GULATORY CO,v\MISSIOI'<

DOCKETING & SERVICE SECTION OFFICE c- TflE SECR.ET ARY OF r:, * -* ,\ 1 ,.A.IS510N Postmil!'i: D *e )-8--10 Co;>ie, R .,; * * }

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Page 2 January 8, 1990 expensive when left to the individual state under the guidelines established by the ASNT.

Sincerely,

  1. ~f?~

Norman J. Collins Radiation Safety Officer NJC:snnn

t; O(; KL 1r:D X-CEL NDE INC. USl-lRC P.O. BOX 12910 ODESSA,TEXAS

-go JAN 12 P3 :17 JANUNARY 7, 1990 OFF!C!-: Of SECRJTA Y

('OCKE i !HG & St.t<VIC f.

' BRANCH SECRETARY, U.S. NUCLEAR REGULATORY COMMISSION WASHINGTON, DC 20555 ATTN: DOCKETING AND SERVICE BRANCH DEAR SIR:

REGARDING THE PROPOSAL BY YOUR COMMISSION TO USE ASNT AS A CERTIFYING AGENCY FOR INDUSTRIAL RADIOGRAPHERS IT IS MY HOPE THAT RADIOGRAPHERS PREVIOUSLY TESTED IN THE STATE OF TEXAS BE EXEMPT FROM THE ORIGINAL ASNT CERTIFICATION AND BE PERMITTED TO RECERTIFY WITHOUT RETESTING. UNDER TRCR PART 31, TEXAS RADIOGRAPHERS ARE ALREADY MEETING THE QUALIFICATIONS LISTED IN THE ASNT CERTIFICATION PROGRAM.

X-CEL NDE IS A SMALL COMPANY WHICH RELIES ON RADIOGRAPHY FOR 90%

OF ITS INCOME. WE HAVE ALREADY SPENT MUCH TIME AND MONEY TO COMPLY WITH THE TEXAS REGULATIONS AND FIND IT IRRITATING AS WELL AS A FINANCIAL BURDEN TO RECERTIFY OUR RADIOGRAPHERS.

WE AT X-CEL ENDORSE YOUR EFFORT TO MAKE INDUSTRIAL RADIOGRAPHY A SAFER INDUSTRY BUT ASK THAT YOU CONSIDER THE AGREEMENT STATES THAT ARE ALREADY COMPLYING WITH YOUR REGULATIONS.

SINCERELY:

u~xa:µ WILLIAM K. ROGERS PRESIDENT X-CEL NDE INC.

JAN 2 3 1990 "

knowledi?ed by cari:f _-.;;;:;:;r;;:;:;;.~-*:*=-'

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MOS Inspection, Inc. I 1920 Oakcrest Avenue I Roseville, MN 55113 I 612 633-7616 MQS-~ Forme1/y MAGNAFLUX Quality Services December 6, 1989 0 89 DEC 29 A7 :38 Secretary 0Ff'!C!: OF :E CRETARY US NRC DOCKETING & S[ iNIC:f:

2120. L. Street N.W. BRANCH Washington, DC 2055 Attn: Docketing and Servicing Branch

Subject:

Central Certification Secretary:

We hqve a number of questions and comments as to central certification of radiographers.

I. Doe s this certification apply to xray?

If not we will be required to take two tests for the same thing.

II. As in ASME or Mil std. 410 require certification every 3 years "ASME" for work on Section XI and III. Why then can you certify for five years.

III. Under the present regulation our company provides us with the required training, and experience and/or verifies that we have a minimum of 40 hrs. training as well as 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct experience prior to qualifying us to work as radiographer with sealed sources.

What is ASNT going to do that would benefit the industry.

IV. Who is going to pay for an individual to be tested or supposedly trained by ASNT? The applicant or employer?

V. If you are going to follow a standard to qualify radiographers or assistant radiographers why choose Texas, which as the highest incident rate per radiographer of any of the 50 states.

VI. If a person has a certificate stating he is a radiographer per the central certificate system, would he/she still have to test with each individual company they work for? If you answer yes then this is a duplication of effort. If you answer no then the person would not be complying to that company's radiation safety operation emergency procedures.

Buffalo. Chicago

  • Cincinnati
  • Cleveland
  • Denver
  • Detroit* Hartford
  • Houston
  • Indianapolis
  • Jacksonville
  • Los Angeles
  • Memphis*

Milwaukee. Minneapolis* Philadelphia* Phoenix* Pittsburgh* Portland* St. Louis* (Main Headquarters) Chicago-(800) NOT-LABS GEO International Corporation

a. S. NUCLEAR RECULATORY COMMISSIOf.l DOCKET! G SERVICE SECTION OrFICE CF THE SECRET ARY o; n*~ (C,1M,IIS~ION Po~ mar~ r Copin~

AdJ'I

MOS Inspection, Inc. 1 230 Murphy Road DOCKET NUMBER Hartford, CT 06114 PR J'/

I 203 522-3253 0)

December 14, 1989 '89 DEC 26 Pl2 :17 Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Docketing and Servicing Branch

Reference:

10 CFR Part 34 RIN 3150-AD35 ASNT Certification of Industrial Radiographers

Dear Sir,

These comments are submitted for the Commission's consideration prior to the passage of the amendment concerning 10 CFR Part 34 "Li censes for Rad iographic Operations". These comments specifically address the fact that all active radiographers will be certified in radiation safety by the American Society for Nondestructive Testing (ASNT), in lieu of current licensing requirements to submit descriptions of planned initial radiation safety training and qualification procedures.

Comment #1 This individual encourages the Commission to recognize ASNT and their program as an alternative to providing internal safety training but only as an alternative. Each individual licensee shoul d still be required to produce qualification and safety procedures and administer same. Removing t hi s responsibility from the licensee only distances the company from the i nd ividuals ability. Not all companies have the ability to provide adequate training for radiographers and in these cases a third-party certification would be beneficial. The responsibility of employing and utilizing well trained and safe industrial radiographers will remain with the licensee, therefore, the administration of the certification should remain with the license holder. This will enable the employer not only make judgments on an individual's ability but his moral character. This is and always will be the most important aspect of radiation safety.

Comment #2 Since the licensee will maintain responsibility of the radiographer' actions, the company can only assure that this individual is adequately trained by administering its own program in addition to ASNT's. I am assuming that liability and responsibility for actions will not be imposed on the individual or ASNT but remain with the licensee. In this case, the proposed ruling simply imposes the additional financial burden of redundant testing upon t he industry.

J

~cknow 1 edred y Buffalo

  • Chicago
  • Giocinnati_
  • Cleveland
  • Denver
  • _Detroit
  • Hartford
  • Houston *. Indianapolis
  • Jacksonvil_le
  • Los Angeles
  • Memphis
  • Milwaukee* Minne,tpo11s
  • Ph1ladelph1a *Phoenix* Pittsburgh* Portland* St. Louts* (Corporate Office) Chicago-(800) NOT-LABS Recipient of the 8 Excelleh6e_Award 1987 Awarded the MOS 1986 Excellence Award

er ('('1 '* '": "' ~ ,~ ..

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  • I Add'*

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Secretary, U.S. Nuclear Regulatory Commisison Page Two December 14, 1989 Comment #3 The ASNT has estimated the cost to the industry for certification to be approximately $1,000 per radiographer, which includes exam fees and costs, travel and administrative costs and lodging at the testing site. My personal feelings are that this estimate is below actual figures. Please find my cost estimate for the re-certification of a radiographer currently trained and working listed below.

Radiographer labor rate Hourly $12.80 per hr.

Average at MQS-Hartford facility Benefits (28%) 3.58

$16.38 per hr.

40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> classroom X $16.38 = $ 655.20 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> travel X $16.38 = 262.08 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> examination time x $16.38 = 131.04 8 days subsistence x $25.00/day= 200.00 Motel-7 nights x (approx. $50.00/nite)= 350.00 Air travel to Columbus, Ohio 450.00 ASNT fees UNKNOWN

$2,048.32 If I estimate ASNT's cost for exams fees and administrative costs between

$300.00 and $500.00 this would bring re-certification costs to between

$2,348.32 and $2,548.32 per individual. The ASNT certification program does effect the licensee's training costs since retraining would be required of presently trained personnel which currently do not require 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> retraining under the present system. Individuals currently not certified as radiographers would need training under the current system and I have removed the 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training portion from the below cost estimates.

Using ASNT's figure of 12,000 individuals involved and utilizing one-half as current radiographers and one-half as new applicants the figures are significantly larger than ASNT's estimated 6.7 million.

6000 radiographer's being re-certified under the new program x $2,548.00 = $15,288,000.00 6000 new applicants not trained prior to ruling x $1,892.80 = 11,116,800.00 Cost to industry in 1989 = $26,404.800.00 dollars based on a 30-yr. period This amount of training burden will most definitely be a hardship on a small industry like industrial radiography.

Secretary, U.S. Nuclear Regulatory Commission Page Three December 14, 1989 Comment #4 The system currently being utilized in Texas is an excellent start with well documented results. The difference between what is proposed and the system currently being utilized by Texas is that the regulating agency is also administering the certification. If the individual states would adm inister this proposed program, it would be more effective in promoting the downtrend in overexposure that everyone in the industry would certainly welcome. Costs would be controlled by reduced travel expenses and monitoring would be more easily achieved. Each state could more effectively monitor licensee's activities.

If the individual radiographer was more responsible for his own actions it would promote safer working practices. When a radiographer violates safe operating practices not only should the licensee be responsible but the individual radiographer should also shoulder his share of the penalty.

Training is extremely important in achieving a safe work environment but an individual's use of this training is the key to it being effective.

In closing, the desire for ASNT to provide training to the industry as an alternative is to be applauded but to make it mandatory would only cause unnecessary hardship on the industry it is trying to promote. The Commission would be wise to look to Texas for guidance and to approach the other 49 states to follow its lead. In addition, making the individual more responsible for his actions is mandatory for safety to succeed.

~tfully,

~ o-c~~"-L._,_.,,----V Rodney Re nho Facility Manager RR:sf

MOS Inspection, Inc. I 1920 Oakcrest Avenue I Roseville, MN 55113 I 612 633-7616 Formerly MAGNAFLUX Ouahly Services

'89 0EC 20 A8 :40 December 6, 1989 DOCKET NUMBER PR 3<J_ **"i'"P. ,j f F !L

  • DOL l"lt  ! H: * , , .f

~;c~:~ary PROPOSf~~U~\<. f) 0~;- )---- ~. N~ **

2120. L. Street N.W. l~ l r 4 Washington, DC 2055 Attn: Docketing and Servicing Branch

Subject:

Central Certification Secretary:

We hqve a number of questions and comments as to central certification of radiographers.

I. Does this certification apply to xray?

If not we will be required to take two tests for the same thing.

II. As in ASME or Mil std. 410 require certification every 3 years "ASME" for work on Section XI and III. Why then can you certify for five years.

III. Under the present regulation our company provides us with the required training, and experience and/or verifies that we have a minimum of 40 hrs. training as well as 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct experience prior to qualifying us to work as radiographer with sealed sources.

What is ASNT going to do that would benefit the industry.

IV. Who is going to pay for an individual to be tested or supposedly trained by ASNT? The applicant or employer?

V. If you are going to follow a standard to qualify radiographers or assistant radiographers why choose Texas, which as the highest incident rate per radiographer *o f any of the 50 states.

VI. If a person has a certificate stating he is a radiographer per the central certificate system, would he/she still have to test with each individual company they work for? If you answer yes then this is a duplication of effort. If you answer no then the person would not be complying to that company's radiation safety operation emergency procedures.

Conclusion:

We at this time are of the opinion that central certification does no one any good except that it puts money in ASNT's operating account *

.,\::C 3 1 1989 l~yea..RS Buffalo. Chicago

  • Cincinnati
  • Cleveland , Denver, Detroit* Hartford
  • Houston
  • Indianapolis* Jacksonville
  • cf?'Kf/'ef~tJ/ib.e R..

Milwaukee* Minneapolis* Philadelphia* Phoenix* Pittsburgh* Portland* St. Louis* (Main Headquarters) Chicago-(800) NOT-LABS GEO International Corporation

.~. NUCLEAR REGULAT OKY COMMISSION DOCKETING & S[R. VI CE SECTION OFFICE OF T E 'EC.. J;'ET ARY or Tr'E ( l , H c;s ION Postmark JJ--~<tl.f q --

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MQS Inspection, Inc. I 1920 Oakcrest Avenue I Roseville, MN 55113 I 612 633-7616 (j)

Formerly MAGNAFLUX Ouahly Services

'89 DEC 20 A8 :40 December 6 , 1989 DOCKET NUMBER Secretary OROPOSED RULE US NRC 2120. L. Street N. W.

lS'-1 FR.

Washington, DC 2055 Attn : Docketing and Servicing Branch Subject : Central Certification Secretary :

We h~ve a number of questions and comments as to central certifica t ion of radiographers .

I. Does this certification apply to xray?

If not we will be required to take two tests for the same thing.

II . As in ASME or Mil std . 410 require certification every 3 years "ASME" for work on Section XI and III. Why then can you certify for five years .

II I . Under the present regulation our company provides us with the required training , and experience and/or verifies that we have a minimum of 40 hrs. training as well as 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct experience prior to qualifying us to work as radiographer with sealed sources.

What is ASNT going to do that would benefit the industry .

IV . Who is going to pay for an individual to be tested or supposedly trained by ASNT? The applicant or employer?

V. If you are going to follow a standard to qualify radiographers or assistant radiographers why choose Texas , which as the highest incident rate per radiographer of any of the 50 states .

VI. If a person has a certificate stating he is a radiographer per the central certificate system, would he/she still have to test with each individual company they work for? If you answer yes then this is a duplication of effort. If you answer no then the person would not be complying to that company's radiation safety operation emergency procedures .

Conclusion:

We at this time are of the opinion that central certification does no one any good except that it puts money DEC~ 1989 ir;;;;;_*t~:;;R;

&~

Buffalo* Chicago

  • Cincinnati
  • Cleveland
  • Denver* Detroit
  • Hartford
  • Houston
  • Indianapolis
  • Jacksonville
  • Los Angeles* Memphis
  • Milwaukee* Minneapolis
  • Philadelphia* Phoenix* Pittsburgh* Portland
  • St. Louis * (Main Headquarters) Chicago-(800) NOT-LABS GEO International Corporation

"l NUCLfAR ~fCULATORY COMMISSI08 DOCKETING & SERVICE SECTION OFFICE OF THE SECRET ARY OF THE COMMISSIO~

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MOS Inspection, Inc. I 1920 Oakcrest Avenue I Roseville, MN 55113 I 612 633-7616 MQS Formerly MAGNAFLUX Ouahly Services

'89 OEC December 6, 1989 ,,~-; ~q DOCKET NUMBER PROPO.,.-D QULE PR 3u7 \ f Secretary US NRC 2120.L. Street N.W.

( ~ ~ f 'f(_ 90 081)

Washington, DC 2055 Attn: Docketing and Servicing Branch

Subject:

Central Certification Secretary:

We h~ve a number of questions and comments as to central certification of radiographers.

I. Does this certification apply to xray?

If not we will be required to take two tests for the same thing.

II. As in ASME or Mil std. 410 require certification every 3 years "ASME" for work on Section XI and III. Why then can you certify for five years.

III. Under the present regulation our company provides us with the required training, and experience and/or verifies that we have a minimum of 40 hrs. training as well as 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct experience prior to qualifying us to work as radiographer with sealed sources.

What is ASNT going to do that would benefit the industry.

IV. Who is going to pay for an individual to be tested or supposedly trained by ASNT? The applicant or employer?

V. If you are going to follow a standard to qualify radiographers or assistant radiographers why choose Texas, which as the highest incident rate per radiographer of any of the 50 states.

VI. If a person has a certificate stating he is a radiographer per the central certificate system, would he/she still have to test with each individual company they work for? If you answer yes then this is a duplication of effort. If you answer no then the person would not be complying to that company's radiation safety operation emergency procedures.

Conclusion:

We at this time are does no one any good except that Buffalo. Chicago* Cincinnati* Cleveland* Denver* Detroit* Hartford* Houston* Indianapolis* Jacksonville* Los Angeles* Memphis*

Milwaukee , Minneapolis* Philadelphia* Phoenix* Pittsburgh

  • Portland
  • St. Louis * (Main Headquarters) Chicago-(800) NOT-LABS GEO International Corporation

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MOS Inspection, Inc. I 1920 Oakcrest Avenue I Roseville, MN 55113 I 612 633-7616

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._ - ~H*.(.'

'89 OEC 20 A8 :40 December 6, Secretary US NRC 2120. L. Street N.W.

Washington, DC 2055 Attn: Docketing and Servicing Branch

Subject:

Central Certification Secretary:

We h~ve a number of questions and comments as to central certification of radiographers.

I. Does this certification apply to xray?

If not we will be required to take two tests for the same thing.

II. As in ASME or Mil std. 410 require certification every 3 years "ASME" for work on Section XI and III. Why then can you certify for five years.

III. Under the present regulation our company provides us with the required training, and experience and/or verifies that we have a minimum of 40 hrs. training as well as 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct experience prior to qualifying us to work as radiographer with sealed sources.

What is ASNT going to do that would benefit the industry.

IV. Who is going to pay for an individual to be tested or supposedly trained by ASNT? The applicant or employer?

V. If you are going to follow a standard to qualify radiographers or assistant radiographers why choose Texas, which as the highest incident rate per radiographer of any of the 50 states.

VI. If a person has a certificate stating he is a radiographer per the central certificate system, would he/she still have to test with each individual company they work for? If you answer yes then this is a duplication of effort. If you answer no then the person would not be complying to that company's radiation safety operation emergency procedures.

Conclusion:

We at this time are of the opinion 0 does no one any good except that it puts money

'II,

  • Buffalo. Chicago
  • Cincinnati
  • Cleveland
  • Denver
  • Detroit* Hartford
  • Houston
  • Indianapolis *Jacksonville*. Los Angeles* Memphis*

Milwaukee, Minneapolis* Philadelphia* Phoenix* Pittsburgh* Portland* St. Louis* (Main Headquarters) Chicago-(800) NOT-LABS GEO International Corporation

I.I. NUCLEAR RUiUI A !ORY C ) W~!t DOC 'ETING & ScRViCE SECTION OFFICE OF Tl ,E SECRET ARY OF THE COMMl::.t*:itl t . ,-,1~ ' C l )---1-J; Cc,pies ..1 ved )

Add' I C i:-*~~ Rr :-,r y pec:ial Oistributior PJJ K.. &JDJ

_______ R\) e ~lt ~c

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MOS Inspection, Inc. I 1920 Oakcrest Avenue I Roseville, MN 55113 I 612 633-7616 Formerly MAGNAFLUX Ouahly Services "89 0EC 20 A8 :39 December 6 , 1989 DOCKET NUMBER op i.

JV' '

Secretary US NRC (SL/ f~ ~I) 08q) Ji, 2120. L. Street N. W.

Washington , DC 2055 Attn : Docketing and Servicing Branch Subject : Central Certification Secretary :

We h~ve a number of ques t ions and comments as to central certification of radiographers .

I. Does this certification apply to xray?

If not we will be required to t ake two tests for the same thing .

II . As in ASME or Mil std . 410 require certification every 3 years

" ASME " for work on Section XI and III. Why then can you certify for five year s .

III . Under the present regulation ovr company provides us with the required training , and experienc e and/or verifies that we have a minimum of 40 hrs . t r ain ing as well as 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct experience prior to qualifying us to work as radiographer with sealed sources .

What is ASNT going to do that would benefit the industry.

IV. Who is going to pay for an individual to be tested or supposedly trained by ASNT? The applicant or employer?

V. If you are going to follow a standard to qualify radiographers or assistant radiographers why choose Texas , which as the highest incident rate per radiographer of any of the 50 states .

VI . If a person has a certificate stating he is a radiographer per the central certificate system, would he/she still have to test with each individual company they work for? If you answer yes then this is a duplication of effort . I f you answer no then the person would not be complying to that compauy's radiation safety operat ion emergency procedures .

Conclusion : We at this time are of the opinion that central certification does no one any good except that it puts money in ASNT's operating account .

II::L~#eR/

Af &-5 Buffalo , Chicago

  • Cincinnati
  • Cleveland
  • Denver
  • Detroit
  • Hartford
  • Houston
  • Indianapolis
  • Jacksonville
  • Los Angeles
  • Memphis*

Milwaukee

  • Minneapolis
  • Philadelphia* Phoenix* Pittsburgh* Portland* St. Louis* (Main Headquarters) Chicago-(800) NOT-LABS GEO International Corporation

a S. . n.u i:(.; "'ORY COMMISSI oocr.rr 'G & ~t VICE SECT ION OFFICE Cf T c SECRET RY Of *p;f COMMISSION Po tm D'l~

Copies R*-:: * *

~ckl' I C)pi f.

5',Kial Ois1r1bu ion

MOS Inspection, Inc. I 1920 Oakcrest Avenue I Roseville, MN 55113 I 612 633-7616 0

MQS Formerly MAGNAFLUX Quality Services

t... L .-: C. i ! ~

'..h~fr*.*

  • a9 DEC 20 AB :39 December 6, 1989 DOCKET NUMBER PR J ~ ,.,r, '-.

Secretary US NRC 2120. L. Street N.W.

Washington, DC 2055~

PROPO~r-1) P'II c~q F F (< 4,1 o&~

- -) OUCt-\l  !

I~ N1..,

1

  • V f Attn: Docketing and Servicing Branch

Subject:

Central Certification Secretary:

We h~ve a number of questions and comments as to central certification of radiographers.

I. Do es this certification apply to xray?

If not we will be required to take two tests for the same thing.

II. As in ASME or Mil std. 410 require certification every 3 years "ASME" for work on Section XI and III. Why then can you certify for five years.

III. Under the present regulation our company provides us with the required training, and experience and/or verifies that we have a minimum of 40 hrs. training as well as 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct experience prior to qualifying us to work as radiographer with sealed sources.

What is ASNT going to do that would benefit the industry.

IV. Who is going to pay for an individual to be tested or supposedly trained by ASNT? The applicant or employer?

V. If you are going to follow a standard to qualify radiographers or assistant radiographers why choose Texas, which as the highest incident rate per radiographer of any of the 50 states.

VI. If a person has a certificate stating he is a radiographer per the central certificate system, would he/she still have to test with each individual company they work for? If you answer yes then this is a duplication of effort. If you answer no then the person would not be complying to that company's radiation safety operation emergency procedures.

Conclusion:

We at this time are of the opinion that central certification does no one any good except that it puts money in ASNT's operating account.

DEC 3 1 1989

/22 l.:l-~-g; 9 .

~.f;Jhi Milwaukee

  • go. Cincinnati* Cleveland* Denver* Detroit* Hartford~- Indianapolis* Jacksonville* Los Angeles* Memphis*

inneapolis

  • Philadelphia* Phoenix* Pittsburgh
  • Portland
  • St. Louis* (Main Headquarters) Chicago-(800) NOT-LABS GEO International Corporation

UCUA "-

DOCKET u Offl,...f OF or rn~

Doc*1* 11 Postmark Da 1e / ;} - 0/ -<l 1 Copies Rec'"' v 1 )

Add ' I Copi. s R .

Special Distrib ution tro C PI T>,

MOS Inspection, Inc. j 1920 OakcrestAvenue I Roseville, MN 55113 j 612 633-7616 Formerly MAGNAFLUX Quality Services

  • ag 0EC 20 A8 :39 December 6, 1989 DOCKET NUMBER PR 31/ * .

Secretary PROP ') 'LE - -.____

US NRC 2120.L. Street N.W.

CSlf fR. l{')Oi~)

Washington, DC 2055 Attn: Docketing and Servicing Branch

Subject:

Central Certification Secretary:

We hqve a number of questions and comments as to central certification of radiographers.

I. Does this certification apply to xray?

If not we will be required to take two tests for the same thing.

II. As in ASME or Mil std. 410 require certification every 3 years "ASME" for work on Section XI and III. Why then can you certify for five years.

III. Under the present regulation our company provides us with the required training, and experience and/or verifies that we have a minimum of 40 hrs. training as well as 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct experience prior to qualifying us to work as radiographer with sealed sources.

What is ASNT going to do that would benefit the industry.

IV. Who is going to pay for an individual to be tested or supposedly trained by ASNT? The applicant or employer?

V. If you are going to follow a standard to qualify radiographers or assistant radiographers why choose Texas, which as the highest incident rate per radiographer of any of the 50 states.

VI. If a person has a certificate stating he is a radiographer per the central certificate system, would he/she still have to test with each individual company they work for? If you answer yes then this is a duplication of effort. If you answer no then the person would not be complying to that company's radiation safety operation emergency procedures.

Conclusion:

We at this time are of the opinion that central certification does no one any good except that it puts money in ASNT's operating account.

1 1989

~9£1 r'~37 1 2S'f~S . ~

  • Buffalo - Chicago
  • Cincinnati
  • Cleveland
  • Denver
  • Detroit* Hartford
  • Houston
  • Indianapolis *Jacksonville* Los Angeles* Memphis*

Milwaukee* Minneapolis

  • Philadelphia *Phoenix* Pittsburgh
  • Portland* St. Louis* (Main Headquarters) Chicago-(800) NOT-LABS GEO International Corporation

~ !. Lh lt,~;: ' ,..., "I COMM! Sl DOCKETING & StRVICE SE TIO OFFICE Of THE SECRET ARY OF THE COMMISSION Poslm8rk Da:e Copie~ Recc -.,cJ Add' I Cop*** R~ -,,

Special Di.!nbul1on

MOS Inspection, Inc. I 1920 OakcrestAvenue I Roseville, MN 55113 I 612 633-7616

(!J MQS Formerly MAGNAFLUX Quality Services

  • a9 0EC 20 A8 :39 December 6, 1989 UOCKET NUMBER PR 31/

PROPOSED RULE - -

Secretary US NRC ( &l/ f R '-f') 0 &'Cf) 2120.L. Street N.W.

Washington, DC 2055 Attn: Docketing and Servicing Branch

Subject:

Central Certification Secretary:

We hqve a number of questions and comments as to central certification of radiographers.

I. Does this c er tification apply to xray?

If not we will be required to take two tests for the same thing.

II. As in ASME or Mil std. 410 require certification every 3 years "ASME" for work on Section XI and III. Why then can you certify for five years.

III. Under the present regulation our company provides us with the required training, and experience and/or verifies that we have a minimum of 40 hrs. training as well as 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of direct experience prior to qualifying us to work as radiographer with sealed sources.

What is ASNT going to do that would benefit the industry.

IV. Who is going to pay for an individual to be tested or supposedly trained by ASNT? The applicant or employer?

V. If you are going to follow a standard to qualify radiographers or assistant radiographers why choose Texas, which as the highest incident rate per radiographer of any of the 50 states.

VI. If a person has a certificate stating he is a radiographer per the central certificate system, would he/she still have to test with each individual company they work for? If you answer yes then this is a duplication of effort. If you answer no then the person would not be complying to that company ' s radiation safety operation emergency procedures .

Conclusion:

We at this time are of the opinion that central certification does no one any good except that it puts money in ASNT 's operating account.

Buffalo* Chicago

  • Cincinnati
  • Cleveland
  • Denver* Detroit* Hartford
  • Houston
  • Indianapolis* Jacksonville
  • Los Angeles* Memphis*

Milwaukee* Minneapolis* Philadelphia* Phoenix* Pittsburgh* Portland - St. Louis* (Main Headquarters) Chicago-(800) NOT-LABS GEO International Corporation

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  • a9 D' 13 P3 :21 NUCLEAR REGULATORY COMMISSION 10 CFR PART 34 RIN 3150-ADJS ASNT Certification of Industrial Radiographers AGENCY: Nuclear Regulatory Commission.

ACTION: Proposed rule.

SUMMARY

The Nuclear Regulatory Cormiission proposes to amend its regulations at 10 CFR Part 34, nlicenses for Radiography and Radiation Safety Requirements for Radiographic Operations," to provide license appli-cants the option to affirm that all of their active radiographers will be certified in radiation safety by the American Society for Nondestructive Testing (ASNT) prior to commencing duties as radiographers, in lieu of current licensing requirements to submit descriptions of planned initial radiation safety training and qualification procedures. The Cormiission believes that the ASNT ncertification Program for Industrial Radiography Radiation Safety Personnel" provides an acceptable method of ensuring that radiographers are adequately trained in the radiation safety subjects listed in Appendix A of 10 CFR Part 34. The intent of this proposed rulemaking is to recognize this program and to encourage industrial radiography licensees to participate in the ASNT program. This proposed rule also solicits comments on the costs and benefits of third-party f iiJ/,slrl 11\ fAr

(. J ~ r.. / I( P3 ; r)t r 1 On I I-~- 8'1

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radiation safety certification which will be used by the Comission in its consideration of a planned subsequent rulemaking that would require radiographer certification.

DATE: The public conment period expires ( 9 0days} from date of publication.

Comments rec~ived after this date will be considered ff it is practical to do so. but the Coomission is able to assure consideration only for cooanents received on or before this date.

ADDRESSES: Mail written comments to: Secretary, U.S. Nuclear Regulatory Commission. Washington, DC 20555. Attention: Docketing and Service Branch.

Deliver conments to: 2120 L Street. NW (Lower Level), Washington, DC,

, between 7:30 a.m. and 4:15 p.m. Federal Govern111ent workdays.

Copies *of the draft regulatory analysis and connents received may be examined at: the NRC Public Document Room at 2120 L Street, NW (Lower Level), Washington, DC.

FOR FURTHER INFORMATION CONTACT: Alan K. Roecklefn, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Co1U11fssion, Washington. DC 20555, telephone (301) 492-3740.

SUPPLEMENTARY INFORMATION:

Background

Current NRC sealed source radiography licensing requirements (10 CFR 34.11) specify that an applicant will have an,adequate program for training 2

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radiographers and will submit to NRC a schedule or description of the program including initial training, periodic retraining, on-the-job \

training, and the means to be used by the licensee to determine the radiographer's knowledge and understanding of, and ability to comply with, COOJ11ission regulations and licensing requirements, and the operating and emergency procedures of the applicant. Section 34.31(a) specifies condi-tions under which an individual is permitted to act as a radiographer.

In addition, Appendix A of part 34 outlines the radiation protection training requirements.

The NRC is proposing to permit applicants to affirm, in lieu of submitting descriptions of their initial radiation safety training and radiographer qualification program, that all individuals permitted to work as radiographers will be certified in radiation safety through the Industrial Radiography Radiation Safety Personnel Program of the American Society for Nondestructive Testing (ASNT), Inc. prior to commencing duties as radiographers. Contingent upon an analysis of the costs and benefits of third-party certification and de110nstrated success of the ASNT certi-fication program. the NRC 1s considering the initiation of a subsequent rulemaking which would require third-party certification of all radiographers.

The high activity radioactive sources used in industrial radiography pose serious hazards ff radiation safety procedures are not adhered to rigorously. A significant fraction of occupational overexposures and serious radiation injuries reported to the NRC and the States have occurred 1n industrial radiography operations. The State of Texas determined that 42 percent of all overexposures rePQrted in that State in 1987 were attributable to industrial radiographic operations. The Cormiission is determined to work with the licensees and the States to make every effort 3

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to improve the radiation safety record in industrial radiography. This rulemaking is consistent with and complements other recent NRC actions such as the proposed radiography device safety rule and the previously published quarterly perfonnance inspection requirement (§34.ll(d)).

Investigations by the NRC and Agreement States have indicated that inadequate training is often a major contributing factor to radiography accidents. Proposals to require third-party certification of radiographers have been advanced by NRC staff. the Ad Hoc Radiography Steering Committee and ASNT. In 1987 1 the Texas Bureau of Radiation Control implemented a comprehensive testing program for radiographers as a means of improving and verifying training and radiation safety practices in the industry.

To date, approxi~ately 2,000 individuals have been tested and issued industrial radiography ID cards by that State.

Preliminary evaluation of the effectiveness of the Texas program is encouraging. There is an indication of a downward trend in overexposures since Texas radiographers began preparing for the examination, but the data are not yet definitive. Inspectors report observing radiographers studying safety training documents and a general fmprovement in job site perfonnance.

The ASNT's "Certifications Program for Industrial Radiography Radi-ation Safety Personnel" was approved by its Board of Directors in March of 1989. The program, which would use a written examination developed and validated by the State of Texas. has been reviewed widely. NRC head-quarters and Regional staff provided extensive c011ll1ent on the program.

The ASNT program will offer certification for both isotope and x-ray users. Application for certification requires documentation of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of classroom training in radiation safety topics specified by ASNT 4

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(including those subjects outlined in Appendix A of 10 CFR Part 34),

documentation of 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of dfrect experience with radiography sources under the control of an NRC or Agreement State licensee. and proof of successful completion of a practical examination on safety procedures administered by an institution recognized by the ASNT. ASNT recognizes government or private institutions that are licensed by the NRC or an Agreement State for the use of radiography sources.

Upon approval of an application for certification by ASNT. a candi-date radiographer would then be eligible to take the State of Texas written examination. The examination would be administered by the ASNT or the Conference of Radiation Control Program Directors (CRCPD). The examination covers radiation protection principles. regulations. basic equipment operation. and radiation safety procedures applicable to industrial radiography. In addftfon. a candidate must sign an acknow-ledgement that he/she will abide by the ASNT Rules of Professional Conduct.

Certification is for a period of 5 years. and a candidate for renewal must document continued active,permanent employment in radiography for at least 24 out of the last 36 months. In addition, the renewal candidate mst document at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual formal classroom training on radiation safety topics including new safety regulations or requirements.

If these renewal criteria are not met, the candidate would be required to repeat the examination process.

ASNT plans to implement an initial trial of its certification program in December of 1989. It is expected that the program will be fully cap-able of certifying approximately 10,000 radiographers within 2 to 3 years.

The NRC staff will monitor the trial program prior to initiating rulemaking which would make third-party certification a requirement.

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More detailed information regarding the certification program is available from the American Society for Nondestructive Testing. Inc.,

4153 Arlingate Plaza. P.O. Box 28518. ~olumbus. Ohio 43228-0518.

Description of Proposed Amendment The proposed amendlDent to 10 CFR 34.11 would apply to all applicants 4t for NRC industrial radiography licenses. The proposed rule would provide radiography license applicants the option to affirm that all individuals acting as radiographers will be certified in radiation safety through the Industrial Radiography Radiation Safety Personnel program of the American Society for Nondestructive Testing, Inc. prior to connencfng duties as radiographers. This would be in lieu of the current requirement for submitting a description of the applicant's initial training and testing program on radiation safety subjects listed in Appendix A of 10 CFR Part

34. It is not the intent of thfs ruletnakfng to waive the training requirements outlined in §34.11, §34.31 and Appendix A of 10 CFR Part 34.

This rule also would not change requirements for radiographers' assistants.

and descriptions of periodic retraining and training in operating and emergency procedures would continue to be required.

Future Rulemak1ng This proposed rule also solicits comments on the costs and benefits of third-party radiation safety certification which will be used by the Co111T1ission in its consideration of planned subsequent rulemaking that would require radiographer certification.

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Illll)act The ASNT has estimated the cost to the industry for certification to be approximately $1000 per radiographer, which includes exam fees and costs, travel, and administrative costs and lodging at the testing site.

Certfficatfon is for a period of 5 years, and a candidate for renewal must document continued active permanent employment in radiography for at least 24 out of the 1ast 36 months. In addition. the renewal candidate must document at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual formal classroom training on radiation safety topics including new safety regulations or requirements.

If these renewal criteria are not met, the candidate would be required to repeat the examination process. The NRC expects use of the ASNT certi-fication program by the license applicant would not affect licensee training costs because present NRC regulations require training and would continue to do so, and because the ASNT e11gib111ty requirements include documented training. Some small reduction in cost will be associated with the application process because ff a radiography license applicant elects to have its radfographers certified, the applicant would not have to submit a detailed description of a planned fn1tfal rad1atfon safety training and testing program covering the topics listed in Appendix A.

The ASNT estimates that as many as 12.000 radiographers could be involved fn cert1ffcation. The total cost to the industry is estimated to be $6.7 million fn 1989 dollars based on a 30-year period beginning in 1989.

The NRC believes that voluntary participation in the ASNT certifica-tion program has the potential to sfgnfficantly improve safety awareness and performance.

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Environmental Impact: Categorical Exclusion The NRC has determined that this regulation is the type of action described as a categorical exclusion in 10 CFR 51.22(c)(3)(i). Therefore, neither an environmental impact statement nor an environmental assessment has been prepared for this proposed rule.

Paperwork Reduction Act Statement This proposed rule does not contain a new or amended information collection requirement subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.). Existing requirements were approved by the Office of Management and Budget approval number 3150-0120.

Regulatory Analysis The Commission has prepared a draft regulatory analysis on this proposed regulation. The analysis examines the costs and benefits of the alternatives considered by the COOlDlission. The draft analysis is available for inspection fn the NRC Public Document Room, 2120 L Street NW (Lower Level), Washington, DC. Single copies of the draft analysis may be obtained from Alan K. Roecklein, Office of Nuclear Regulatory Research, U.S.

Nuclear Regulatory Co111111ssion, Washington, DC 20555, Telephone (301) 492-3740.

The Co1m1iss1on requests public coument on the draft regulatory analysis. Comments on the draft analysis may be submitted to the NRC as indicated under the ADDRESSES heading.

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Regulatory Flexibility Certification Based upon the information available at this stage of the rulemaking proceeding and in accordance with the Regulatory Flexibility Act, 5 U.S.C.

605(b), the Commission certifies that, if promulgated, this rule will not have a significant economic impact upon a substantial number of small entities.

The proposed rule would affect all industrial radiography license applicants. Currently. license applicants are required under 10 CFR Part 34.ll(b)to provide descriptions of initial training, testing and periodic safety performance appraisals of all radiographers fn their employ. The proposed rule would add a provision that would permit sub-stitution of ASNT certification for the existing requirement to submit detailed descriptions of initial radiation safety training and testing procedures in license applications. Because the cost of ASNT certifica-tion per radiographer is estimated at approximately $1000 for a certification period of 5 years and recertification without reexamination is estfDJated at approximately $70.00 per radiographer. and the potential improvement in safety awareness and performance 1s considered to be significant, the overall industry benefits are considered to outweigh the economic fmpact on small industrial radiography licensees. However, the NRC is seeking conwnents and suggested 110diffcations of the prop0sed rule because of the widely differing conditions under which small industrial radiography licensees operate.

Any small entity, subject to this regulation which determines that, because of its size, ft is likely to bear a disproportionate adverse economic impact. should notify the CoQllllfssion of th1s in a comment that indicates --

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(a) The applicants' size in terms of annua1 income or revenue, number of employees, and the number of radiographic tests performed annually; (b) How the proposed regulation would result in a significant economic burden upon the applicant as compared to that on a larger applicant; (c) How the proposed regulation could be modified to take into account the applicants' differing needs or capabilities; (d) The benefits that would be gained or the detriments that would be avoided by the applicant if the prop0sed regulation were modified as suggested by the corrmenter; and (e} How the regulation, as modified. would still adequately protect the public health and safety.

Backfit Analysis The NRC has determined that the backfit rule, 10 CFR 50.109, does not apply to this proposed rule, and therefore, that a backf1t analysis is not required for thfs proposed rule, because these amendments do not involve any provisions which would impose backffts as defined in IO CFR 50.109(a)(l).

List of Subjects in 10 CFR Part 34 Packaging and containers, Penalty, Radiation protection. Radiography, Reporting and recordkeep1ng requirements, Scientific equipment, Security measures.

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For the reasons set out in the preamble and under the _authority of the At001ic Energy Act of 1954. as amended. the Energy Reorganization Act of 1974, as amended, and 5 u.s.c. 553. the NRC is proposing to adopt the following amendment to 10 CFR Part 34.

PART 34 - LICENSES FOR RADIOGRAPHY AND RADIATION SAFETY REQUIREMENTS FOR RADIOGRAPHIC OPERATIONS

1. The authority citation for Part 34 continues to read as follows:

AUTHORITY: Secs. 81, 161. 182. 183, 68 Stat. 935, 948. 953. 954, as amended (42 U.S.C. 2111, 2201, 2232. 2233); sec. 201. 88 Stat. 1242, as amended (42 U.S.C. 5841).

Section 34.32 also issued under sec. 206, 88 Stat. 1246 (42 U.S.C.

5846).

For the purposes of sec. 223 1 68 Stat. 958, as amended (42 U.S.C.

2273); §§ 34.22. 34.23, 34.24, 34.25(a). (b). and {d), 34.28, 34.29, 34.3l(a) and (b). 34.32, 34.33(a), (c). and {d), 34.41, 34.42, and 34.43(a), (b) and {c), and 34.44 are issued under sec. 161b. 68 Stat.

J 948, as amended {42 U.S.C. 220l(b)); and§§ 34.ll(d), 34.25(c) and (d),

34.26, 34.27. 34.28(b}, 34.29(c), 34.3l(c), 34.33(b) and (e}, and 34.43(d) are issued under sec 1610 1 68 Stat. 950, as amended (42 U.S.C.

2201(0)).

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2. In§ 34.11, paragraph(b)(5) fs redesignated as paragraph(b)(6) and a new paragraph(b)(5) is added to read as follows:

§ 34.11 Issuance of specific licenses for use of sealed sources in radiography.

(b) ***

(5) In lieu of describing an initial training program for radio-graphers fn the subjects outlined 1n Appendix A and required in§ 34.31 of this part and the means used to determine the radiographer's knowledge and understanding of these subjects. the applicant affirms that all indi-viduals acting as radiographers will be certified through the Certification Program for Industrial Radiography Radiation Safety Personnel of the American Society for Nondestructive Testing, Inc. prior to commencing duties as radiographers. (This paragraph does not relieve a licensee from compliance with the training requirements of Section 34.31{a) of this part.)

Dated at Rockville. Maryland, this-3v'h0day ofQ~l989.

For the Nuclear Regulatory Commission.

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