Industrial RadiographyIndustrial RadiographyAugust 8, 2007August 8, 2007

2:00 AM Edition2:00 AM Edition

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Safety QuestionsSafety Questions

What do What do rulesrules have to do with have to do with safety?safety?

Why are Why are requirementsrequirements so different?so different? How what can you do?How what can you do?

Who Rules?Who Rules?

Non-Profit Groups

American Society for Non-Destructive Testing (ASNT)

Conference of Radiation Control Program Directors (CRCPD)

Organization of Agreement States (OAS)

Who Rules?Who Rules?

X-rayState agency and the Conference of Radiation Control Program Directors (CRCPD)

Radioactive MaterialsUS Nuclear Regulatory Commission and State agency

34 Agreement States16 NRC States

4 States with Letter of Intent1 State planning to submit

Letter of Intent

ID

MT

WY SD

MN WI

MI

IN OH

PA

OK

WV VA

MO

WA

OR

CA

NV

AZ NM

TX

CO UT

NE IA

ND

AR

LA

KY

TN NC

NY

ME

FL

SC

GA AL MS

AK

HI

MD

NH

NJ

MA

VT

KS

IL

Enforcement ProgramEnforcement ProgramPurposePurpose

The purpose of an enforcement program is to:

promote and protect the radiological health and safety of the public,

employee's health and safety, and

the safety of the environment

This is accomplished by:

Ensuring compliance with rules;

Obtaining prompt correction of violations and adverse conditions that may effect radiological safety;

Deterring future occurrences of conditions adverse to quality;

And by:

Encouraging the prompt identification and reporting of potential safety problems;

Promoting improvement of the regulated entity's performance.

The BasicsThe BasicsCompatibleCompatible

CompatibleCompatible

The NRC categorizes rules that are adopted by states as A, B, C, D, or H&S.

CompatibleCompatible

A

Basic radiation protection standard or related definitions, signs, labels, or terms necessary for the common understanding of radiation principles. The state program should be essentially identical to that of the NRC.

CompatibleCompatible

B

Program element with significant direct trans-boundary implications. The state program element should be essentially identical to that of the NRC.

CompatibleCompatible

C

Program element, the essential objectives of which should be adopted by the state to avoid conflicts, duplications, or gaps. The manner in which the essential objectives are addressed need not be the same as the NRC, provided the essential objectives are met.

CompatibleCompatible

D

Not required for compatibility purposes.

CompatibleCompatible

H&S

Program element with a particular health and safety significance. The state should adopt the essential objectives of such program elements in order to maintain an adequate program.

CompatibleCompatible

Regulation Amendment Tracking System (RATS) lists the categories for each rule part.

For Industrial Radiography the following apply:

RATS ID 1997-5*

RATS ID 2002-2

*Supersedes 1991-2 and 1995-5

CompatibleCompatible

Sec. 34.Sec. 34.35 is revised to read:is revised to read:(a) Whenever radiography is (a) Whenever radiography is performed at a location performed at a location other than a permanent other than a permanent radiographic installation, the radiographic installation, the radiographer must be radiographer must be accompanied by at least one accompanied by at least one other radiographer orother radiographer or��..

BBConducting Conducting industrial industrial radiographic radiographic operationsoperations

34.4134.41

Summary of Change to CFRSummary of Change to CFRCompatibility Compatibility CategoryCategory

TitleTitleChangeChangeTo NRCTo NRC

SectionSection

nrc-stp.ornl.gov/rss_regamendents.html

CompatibleCompatible

Agreement State ApproachesAgreement State Approaches�� Implemented by referenceImplemented by reference��Adopt NRC regulations verbatimAdopt NRC regulations verbatim��Adopt NRC regulations with Adopt NRC regulations with

embellishments*embellishments*

* Can be challenged* Can be challenged

CompatibleCompatible

The Caveat:The Caveat:

Rules can be interpreted differentlyRules can be interpreted differently

The BasicsThe BasicsAdequateAdequate

AdequateAdequate

NRC Inspection Manual Chapter 2800

establishes inspection frequencies

Office Inspections Office Inspections ��Every year if authorized temporary Every year if authorized temporary

job sites. May include temporary job job sites. May include temporary job site locations.*site locations.*

��Every two years if fixed job site.Every two years if fixed job site.

AdequateAdequate

Performance based inspections Performance based inspections ��whatever that meanswhatever that means

InspectorInspector��s equipment s equipment �� varies, but varies, but in Iowa and Minnesota it is in Iowa and Minnesota it is equivalent to the radiographerequivalent to the radiographer��ss

LicenseeLicensee��s Responsibility for State s Responsibility for State Inspectors Inspectors -- varies, so radiographers varies, so radiographers should askshould ask

AdequateAdequate

Most Agreement States have a peer Most Agreement States have a peer review process review process �� NRC may notNRC may not

Be cautious of recommendationsBe cautious of recommendations

Ask questions if you donAsk questions if you don��t t understandunderstand

AdequateAdequate

NRC Integrated Materials Evaluation Program (IMPEP) reviews implementation of inspections

Conducted a minimum of every four Conducted a minimum of every four yearsyears

AdequateAdequate

The Caveats:The Caveats:

The inspector may not identify a The inspector may not identify a deficiencydeficiency

The inspector may not choose to cite a The inspector may not choose to cite a deficiencydeficiency

Rules can be interpreted differentlyRules can be interpreted differently

Talk to the inspector�s supervisor or manager if you disagree with a finding

The BasicsThe BasicsAudits and InspectionsAudits and Inspections

Program AuditsProgram Audits

A licensee must periodically, at least A licensee must periodically, at least annually, review the radiation annually, review the radiation protection program content and protection program content and implementation.implementation.

Program AuditsProgram Audits

The rules do not specify who should The rules do not specify who should complete the auditscomplete the audits

A sample audit is in most Industrial A sample audit is in most Industrial Radiography Regulatory Guides.Radiography Regulatory Guides.

Job Performance ReviewsJob Performance Reviews

Must be performed every Must be performed every six monthssix months

Radiographer Job PerformanceRadiographer Job Performance

The radiation safety officer The radiation safety officer or designeeor designeemust conduct an inspection program of must conduct an inspection program of the job performance of each the job performance of each radiographer and radiographer's radiographer and radiographer's assistant to ensure that:assistant to ensure that:�� this rules, this rules, �� the license requirements, and the license requirements, and �� the licensee's operating and the licensee's operating and

emergency procedures are followed. emergency procedures are followed.

Radiographer AuditsRadiographer Audits

The inspection program must include The inspection program must include observation of the performance of each observation of the performance of each radiographer and radiographer's radiographer and radiographer's assistant during an actual industrial assistant during an actual industrial radiographic operation, at intervals not radiographic operation, at intervals not to exceed six months.to exceed six months.

What is ComingWhat is ComingNational Source Tracking National Source Tracking

SystemSystem

National Source Tracking National Source Tracking SystemSystem

August 28, 2006August 28, 2006

The NRC requests that all states The NRC requests that all states conduct an inventory of some sources conduct an inventory of some sources including:including:

IridiumIridium--192 sources 192 sources -- 216 mCi or 216 mCi or moremore

CobaltCobalt--60 sources 60 sources -- 81 millicuries 81 millicuries or moreor more

National Source Tracking National Source Tracking SystemSystem

December 12, 2006December 12, 2006

The NRC completed final The NRC completed final rulemaking for the National Source rulemaking for the National Source Tracking SystemTracking System

Increased ControlsIncreased Controls

Fingerprinting andFingerprinting andSUNSISUNSI

FingerprintingFingerprinting

Implemented for all NRC licensees with Implemented for all NRC licensees with Increased ControlsIncreased Controls

Some state impedimentsSome state impediments

Sensitive Unclassified Sensitive Unclassified NonNon--Safeguards InformationSafeguards Information

SUNSI requires information SUNSI requires information management.management.

Things to be controlled: Things to be controlled: �� LicensesLicenses��Reports containing:Reports containing:

Addresses of storage locationsAddresses of storage locationsSource informationSource information

Sensitive Unclassified Sensitive Unclassified NonNon--Safeguards InformationSafeguards Information

Precautions:Precautions:��DonDon��t email copies of licenses t email copies of licenses

(unless the information is encrypted)(unless the information is encrypted)��Ensure that faxed copies go to the Ensure that faxed copies go to the

intended personintended person��Secure SUNSI information when not Secure SUNSI information when not

in use. in use.

The BasicsThe BasicsPersonnel MonitoringPersonnel Monitoring

Personnel MonitoringPersonnel Monitoring

�� During radiographic During radiographic operations, individuals operations, individuals must wear on the must wear on the trunktrunkof their body:of their body:�� Direct reading Direct reading

dosimeterdosimeter�� Alarm ratemeterAlarm ratemeter�� Personnel dosimeter Personnel dosimeter

processed by a processed by a NVLAP processorNVLAP processor