radiation safety certification · the nrc solicited asnt to develop a radiation safety...

NDTMA 2015 Annual Conference

Radiation Safety Certification – Understanding the Industrial Radiography Radiation Safety Program Garry L Balestracci Balestracci Unlimited Charlestown, Rhode Island

Golden Nugget Hotel, Las Vegas, NV February 10-13, 2015


IRRSP § In 1994 a Public Hearing was held to present “Central or 3rd Party Certification” to the industry § The NRC solicited ASNT to develop a radiation safety certification program similar to the one that had been established by the State of Texas § Representatives from the State of Texas and Louisiana were on hand to answer questions § The idea was to establish a minimum safety standard for industrial radiography. § I had always taken great pride in my company’s radiation safety program and I resented the idea that I would need to “dumb down” my program to meet the minimum standard



IRRSP § None of the regulators on hand were willing or able to provide any concrete statistics as to the safety improvement that the certification program had achieved § The industry especially in the gulf coast region had safety problems § I tried to apply for an exemption from the program and it was denied so this is basically how we got to “3rd Party Certification” § The first examination that I sat for was in my opinion a dismal failure § Questions had no answers or more than one answer and some were based on outdated regulations § I sat down with the program chairman to discuss my concerns and I was told that if I was that smart I should become part of the committee and come fix it



IRRSP § This seems to be the way the committee was populated § The committee now has a diverse composition

§ Members from NDT Companies (a major defense contractor) § Equipment manufacturers (a source manufacturer) § Military/Civilian representatives (a navy trainer from an East Coast weapons facility §  Professional Trainers (a representative from a well respected training facility § Industry Equipment suppliers § More recently a representative from a large NDT Service Provider § Additional people from industry fill out the committee



IRRSP § The IRRSP Program consists of three (3) components

§ Part I – Qualification and Certification Requirements § Part II – Rules of Conduct § Part III – Committee Complaints and the Hearing Process

§ Certification will establish the individual has the required credentials § Certification alone does not qualify the individual to conduct safety duties § Three (3) types of certification are available

§ RAM (Gamma) only, X-Ray only or a Combination (Both) § This is not an examination based on your company’s O & E



IRRSP § IRRSP is based on Federal and State Regulations related to Industrial Radiography (10 CFR Party 34 and SSRCR Part E) § NUREG 1556 Volume 2 provides the rationale for some of the questions § The NRC Form 3 which is derived from 10 CFR Part 19 provides insight into the rights and responsibilities of radiation workers §  Many times comments are received which in essence say that is not my job, the RSO handles that or the shipping department handles that or we send out all our equipment to calibrated § While you may not perform all the separate processes, the list of required training demonstrates that you have at least a working knowledge of these topics



IRRSP § Some activities require special license authorizations, such as source retrieval, analysis of leak test samples, source changing operations and instrument calibration § While you may not perform all of the separate processes, the required training topics(10 CFR 34.43 and SSRCR Part E.17) demonstrate that you have some knowledge of the requirements or functions involved § e



IRRSP § Leak test periodicity and limits – Sources 6 months, exposure devices 12 months § The limits for both wipe (leak) test must be less than .005 micro curies of removable contamination § Leaking sources must be reported to the appropriate regulatory agency within five (5) days § Contaminated exposure devices must be returned to the manufacturer for evaluation and disposition § In most jurisdictions, survey meters require calibration every six (6) months or after repair (battery change is not considered a repair) § Some regulations specify 3 month periods or annual calibrations



IRRSP § Calibrations are to completed on each available scales using two points located approximately 1/3 and 2/3 of full scale and must be plus or minus 20% of the applied radiation levels § Calibrations are required to be performed using an isotope which has a similar energy to the radiation to be detected § Alarm rate meters and dosimeters have the same 20% tolerance with recalibration required within 12 months § Radiographers are required to ensure that equipment to be used is within the prescribed calibration periods § While a radiographer may not necessarily perform calibrations or leak tests, some knowledge is still required



IRRSP § The examination consists of 100 multiple choice questions, at some times provisional questions make up a portion of the examination § Provisional question are required to be “seen” by a number of test takers to demonstrate that they are psychometrically valid (Not too hard and not too easy) § 70% is the minimum passing grade and provision questions do not affect the examination test scores positively or negatively § Specific information to be during mathematical computations is provided § Use the provided information even if it does not coincide with the factors in use at your facility



IRRSP § The examination questions are selected by a computer program based on the criteria (template) that is designed to include the a sampling of the training topics required § Current statistics based on IRRSP 1st time test takers for 2013 indicate a 62% pass rate § Agreement State examinees exposed to the State of Texas examination have demonstrated a slightly lower pass rate § In order to be eligible to sit for either examination the applicant is required to submit an application with evidence of the required training and on-the-job experience § Documentation of a practical demonstration signed by the RSO are required for each exam type (Gamma, X-Ray or Both)



IRRSP § IRRSP allows and encourages candidates to make comments regarding the content of any and all questions § We do not live in a perfect society, sometimes questions can be poorly worded or typos can be introduced as the test items are entered into the test databank or by the original author § Each and every comment is reviewed by three or more of the committee members § Valid comments are adjudicated and in the event of critical pass /fail circumstance the examination will be re-scored § The committee understands that this certification can directly affect a persons ability to work and make a living so mistakes are corrected in as timely a manner as possible



IRRSP § The committee meets at least three times per year and conducts a workshop to review comments, write new questions or attempt to improve this program § The workshops sometimes tend to loud and raucous with very spirited discussions § Not every member can attend every meeting/workshop but there is normally a good representation of core committee members and if necessary teleconferences are arranged for typically critical type questions or problems to get more varied input § The program was revised in 2010 and it has taken 4-1/2 years to finally get this revision approved § Additional addenda items are being submitted to the regulatory bodies to allow the use of computer based training



IRRSP § The validity of the content of the training will be the responsibility of the training provider and the licensee to ensure the training covers the required training topics § Hands on training dealing with proper operation and use of equipment will obviously still need to provided outside of the CBT environment § 320 hours of documented OJT are required for a Ram/Gamma Certification § 160 hours of documented OJT are required for an X-Ray Certification § A combined total of 480 OJT hours are required for Combination Certifications



IRRSP § IRRSP examinations are held at a number of locations, Authorized Examination Centers, ASNT Headquarters or can be administered privately by trained and authorized proctors § Proctors may not conduct examinations internally for candidates employed by the same company as the proctor § Proctors may not conduct examination activities for candidates that have received training from the proctor within 12 months § Additional proctors are continually being solicited to provide better service for the industry § Other examination opportunities are also being investigated § Some test centers and proctors may require a fee to offer the exams



IRRSP

§ Some significant changes have come about with the long awaited approval of ASNT-CP-IRRSP-1A, Revision 12 of the IRRSP Practice § Initial training must be completed within 5 years of the examination (a 20 year old training will no longer be accepted) §  Radiation Safety Training either given or received can be applied to satisfy the training requirement § Attendance at technical presentations specific to radiation safety can also be used to satisfy the training requirements (Examples include but are limited to the NDTMA Regulatory Session or ASNT Radiation Safety Sessions normally held at the Fall Conference and Quality Testing Show)



IRRSP § Applications may be submitted as hard copy, by email or via fax provided all the required information is provided § Digital “passport size” photos will be accepted § Payments can be made by email although not recommended for security reasons, by fax, by check or arrangements can be made by phone with the ASNT Accounting Department § These changes should reduce the turn around time currently associated with the application process § The licensee and/or applicant are responsible to ensure all the required information is provided (including signatures and supporting documents such as certificates of training)



IRRSP § The industrial radiography industry conducts operations in many geographic locations and inspect many different end products § Different locations or industry sub-type may use terminology that is not recognized universally § A radiographic exposure device may be referred to as a “gun”, a “pill box”, a “camera” or a variety of other names § The source capsule might be the “source”, the “pigtail” or other location specific designations § These differences in terminology sometimes create confusion and add to the difficulty of satisfactorily completing an exam. § Terms used on examinations are normally those referenced in regulation



IRRSP § Candidates should utilize the suggested reference materials § A number of study guides have been written to assist with proper preparation § Comments are encouraged to resolve questionable test items § This process is the primary method to resolve issues § Ten people can read a question and come up with a different interpretation of what is being asked. § I personnally have read and re-read examination items that may contain a typo or be missing a word and not notice § I understand the concept and my mind overlooks these sometime glaring errors



IRRSP § Some topics are considered “core concepts – information you would desire to have all radiographers answer correctly § This can skew the psychometric analysis (too easy too hard)) § It is only possible to ask a question so many ways and leads to the need to alter the language selected for the question stem or the distractors § This turns into a goldilocks nightmare

§ “This question is too hard” § “This question is too easy” § “This question is just right”

§ This can have a tendency to “raise the bar” for candidates



Thank you for allowing me to participate in the



radiation safety certification · the nrc solicited asnt to develop a radiation safety...

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